United States Office of
Environmental Protection Emergency and
Agency Remedial Response
Superfund
Record of Decision:
EPA/ROD/R05-90/147
September 1990
Reilly Tar & Chemical
(St. Louis Park), MN
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.
REPORTDOCUMENTA~ON 1" REPORT NO. r ~ S. A8cIpIenr. Ac-.Ian lID.
PAGE EPA/ROD/R05-90/147
4. TItle........ I. IIepart D88
SUPERFUND RECORD OF DECISION 09/28/90
Reilly Tar' Chemical (St. Louis Park), MN
Third Remedial Action I.
7. Authoril' I. PwfonNng Orgonlatlon AopL No.
t. Porfonnlng Orgolnlullon ...... .... AdIhu 10. PIoiK'ITIIIIIWorII UnIt No.
11. ~C) or Or8n1(G) No.
(e)
(0)
I~ SponootIng Orpnluton ...... .... ~ IS. r.,.. 0I1Iepart . PwIDcI Co-.d
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. ~18ry -
II. AIIItroct (UmI1: 2IID wonlo)
The 80-acre Reilly Tar' Chemical (St. Louis Park) site is a former coal tar
distillation and wood preserving plant in St. Louis Park, Minnesota. The site overlies
a complex system of aquifers, including the St. Peter aquifer that provide drinking
water to area residences. The St. Peter Aquifer contains one municipal well, which is
used during periods of peak demand, however, the majority of the drinking water in St.
Louis Park is obtained from deeper aquifers. Surrounding land use is primarily
residential. From 1917 to 1972, wastewater containing creosote and coal tar was
discharged to onsite surface water, and as a result, small wastewater spills occured
into onsite soil. In 1972, the site was purchased by the city in response to complaints
about wastewater contamination, and the plant was dismantled. State investigations from
1978 to 1981, identified site-related ground water contamination. Two previous Records
of Decision (RODs) in 1984 and 1986, addressed remediation of specific aquifers, the
filling of a small onsite wetland, and offsite soil contamination. This ROD addresses
Operable Unit 4 (OU4), remediation of the St. Peter aquifer. A subsequent ROD will
address any remaining site problems as OU3. The primary contaminants of concern
affecting the ground water are organics including PAHs and phenols.
(See Attached Page)
17. ~~ .. DooaIpIGn
Record of Decision - Reilly Tar & Chemical (St. Louis Park), MN
Third Remedial Action
Contaminated Medium: gw
Key Contaminants: organics (PAHs, phenols)
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EPA/ROD/R05-90/147
Reilly Tar & Chemical (St. Louis Park), MN
Third Remedial Action
Abstract (Continued)
The selected remedial action for this site includes pumping an existing well screened
within the St. Peter aquifer and initially discharging the extracted water offsite to a
publicly owned treatment works (POTW); and ground water monitoring. Within 3 to 5
years, direct onsite discharge to surface water will be conducted if NPDES permit
requirements can be met. If requirements are not met, onsite treatment, possibly using
granular activated carbon, will be conducted prior to onsite discharge. The estimated
capital cost for this remedial action is $225,000 to $250,000, depending on the need for
onsite treatment. Annual O&M costs are estimated at $60,000.
PERFORMANCE STANDARDS OR GOALS: Extracted ground water must meet NPDES discharge
requirements for both discharge to a POTW and to surface water. Chemical-specific
levels include carcinogenic PAHs 70 ug/+, other PAHs 17 ug/l, and phenols 10 ug/l.
"
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1.
DF.;ClARATION
SITE NAHE AND u:x:ATION
.'
Reilly Tar and Chenucal COl~ration Site
St. Peter Aquifer
St. LDuis Park, Minnesota
STATEHENI' OF BASIS AND Pt.1RFVSE
This decision document represents the selected response actions for the
St. Peter Aquifer Reilly Tar and Chanical Corp:xation Site, developed in
Ci\::cordance with the Canprehensive Environrrental Resp:>nse, Canpensation
and Liability Act of 1980 \ CERCLA), as aJrended by the Superhmd
Amendments and Reauthorization Act of 1986 (SARA).
This der:ision is based uPJn the contents of the administrative record
for the Reilly Tar and Chemical Corporation Site.
The United States Environmental Protection Agency and the State of
Minnesota agree on the selected ranecIy.
ASSESSMENI' OF THE SITE
Actual or threatened releases of hazardous substances from the St. Peter
Aquifer at this Site, if not addressed by implementing the response
a<:t.i~ $elected in this Record of Decision (ROO), may present a current
or p:>tential threat to public health, welfare, or the environment.
DESCRIPTION OF REMEDY
The objectives of the resp:>nse actions awroved for the Site are to
protect public health, welfare and the enviroranent and to ca1;>ly with
a~licable Federal and State laws.
'The St. Peter Aquifer represents one operable W1it ",'ithin the overall
Si te strategy. This ranedy addresses only the St. Peter Aquifer, and
",'ill contain the spread of contaminated ground watel' of polynuc lear
Aranatic Hydrocarbon (PAH) Contamination in this ar-fUj tel'.
'11'1e major coop:>nents of the selected ranecIy include:
The interception and contai!"D"l'ent of contaminants t,,)'. pumping ~ 11
number W410 at a rate of 65 to 100 gallons rel' minute,
- The discharge from the well will initially be routed to the
sanitary sewer for treatment at the Metrop:>litan Waste Control
Commission (MWCC) wastewater treatment plant to remove contaminants
fran the collected ground watel'.
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'"
- Continued water level and water quality m:mitoring of the ground
water contaminant plume during PJIT1Ping rerediation activities.
This is not only to document the effectiveness of the ratedy but
also to deteDmine the need for on-site treatment.
- Within three to five years, MPCA anticipates. that the water quality
of ground water pumped from W410 will be improved sufficiently to
meet National Pollutant Discharge Elimination System (NPDES)
limits. This would allCM MPCA to route the ground water p.Jmped
fran W410 to a stom s~r for eventual discharge to Minnehaha
Creek. If necessary, an on-site treatment facility will be built
to ensure that the ground water meets National Pollutant Discharge
Elimination System (NPDES) limits.
STKIUroRY DETERMINATIONS
The selected Lernedy is protective of human health and the environment,
c~lies with Federal and State requirements that are legally applicable
or relevant and appropriate to the raredial action, and is
cost-effective. This remedy utilizes peDMnent solutions and
alternative treatment (or resources recovery) technologies to the
maximum extent practicable and satisfies the statutory preference for
renedies that employ treat:ment that reduces toxicity, nobility, or
volume as a principle element. As this L~ledy will initially result in
hazardous substances remaining on-site above health-based levels, a
review will be conducted within five years after catmencement of
renedial action to ensure that the remedy continues to provide adequate
~ pxotectio of - health am the e
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, .
RECORD OF DECISION
1. Declaration
2. Site Description, Site History, COITnRL~ity Relations
3. Scope and Role of Operable Unit
4. Surnl1.3.ry of Site Characteristics
5. Surnnill:Y of Site Risks
6. Description of Alternatives
7. Comparative Analysis
8. Selected Reredy
9. Statutory Determinations
10. Responsiveness Summary
"
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IIa.
IIb.
\,
-1-
SITE DESCRIPI'IOO
The Site is defined in Part C.1 of the Consent Decree and in Section
1.21 of the Reredia1 Action Plan as the 80 acre property where Reilly
Industries (Reilly) operated a coal tar refinery and wood preserving
plant. The Reilly Tar Site (Site) is located in the ~stern part of the
Twin Cities Jretrop:>litan area, in St. lDuis Park, Minnesota (Figure I).
The approxirrate location of this Site is ~st of Gorham, Re~.lic and
DJuisiana Avenues, south of 3200 Street, east of Pennsylvania .~venue and
north of Walker Street.
This Record of Decision (RCD) addresses the contamination in the St.
Peter .Aquifer underlying the Site. At the fomer Reilly Site,
approximately 65 feet of Drift and 30 feet of Platteville Limestone and
Glenwood Shale overlie the St. Peter .Aquifer. About one-half mile
southeast of the fomer Reilly Site, the Platteville and Glenwood
bedrock units have been rem::rved by erosion, and the Drift directly
over lies the St. Peter Iqilfer. 'n1e St. Peter .Aquifer is a layer of
water bearing saOOstone, approx.imately 100 feet thick. In the St. lDuis
Park area, it is used nDStly as a source of industrial process water and
secondarily as a source of drinking water during times of peak demand.
SITE HISIDRY
The Site history infoDnation surrmarized in this section is excerpted
frem the Proposed Plan for the St. Peter .Aquifer Report dated May 1990.
Between 1917 and 1972, Reilly Irrlustries (Reilly) operated a coal tar
distillation and 'WOOd preserving plant, koown as the Republic Creosote
Coopmy. Wastewater contain.inq creosote and coal tar frem plant
operations was discharged to ditches which drained to a swanp south of
the Site. Additional releases of creosote and coal tar resulted frem
drippings and spills onto the soil. '!be major constituents of coal tar
are pheoolic ~ and polynuclear aranatic hydrocarbons (PAH).
~ PAM ~ are carcirogenic and are of corcern when they
contrninate a source of drinking water. In this OOc\.Inent, the te1!11S
"cont.aminaJ:lts," "cont.arniI'Iated" or "cont.arniI'Iation" refers to that PAH or
pheoolics present in the soil or ground water at the Site.
Bee- of extenSive residential developtent in the area around.the Site
in tI8 1940' s am into the 1950' s, carplaints abJut shallow well
contamination and c:d::>r problEIRS became eamon. As a result of the
contiJB1ing problems with air emissions, soil and surface water
contamination, the City of St. Louis Park (City) and the MPCA, filed
suit against Reilly in 1970. In 1972, the City p.1rChased the Site frem
Reilly, and the plant was dismantled and rerroved. 'l11e City drowed its
lawsuit against Reilly as a condition of the sale.
In the mid 1970's, IDuisiana. Avenue was constrocted through the Site and
sane nulti-f5nily rousing units ~re constructed on the oorthem half of
the Site. 'tt1e Minnesota Pollution Control1qercy (MPCA), Reilly and the
City have observed soil and ~ water contamination by a variety of
coal-tar-related chsnicals on arxi in the imnediate vicinity of the
fomer plant site. In 1978, the MinnesOta eepart::ment of Health (MOO)
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began to analyze water fran municipal wells in St. Louis Park and nearby
cc:mmmities for trace concentrations of PAHs. Over the ti1re pericx:i fran
1978 to 1981, the MDH discovered unexpectedly high concentrations of PAH
in six City wells and one well in neight:oring Hopkins. As these wells
were found to be contaminated al:::ove acceptable drinking water levels,
they were closed.
After it was determined that ground water contamination had occurred,
the MPCA amended in 1978 its complaint in the lawsuit with Reilly to
include claims for ground water contamination. Subsequent legal actions
were taken by the federal and state governmental agencies against Reilly
under the Resource Conservation and Recovery Act (RCRA), CERQA, and the
M.in.nesota Environmental Response and Liability Act (MERIA). Both the
U..s. EPA and the MPCA agencies instituted administrative actions against
Reilly, pursuant to the applicable federal and state Superfund acts. In
these actions the U.S. EPA and MPCA agencies sought to cc:rnpel Reilly to
undertake necesscu:y remedial actions. Following the administrative
actions, negotiations which had previously broken down, resumed between
the agencies, City, and Reilly. A general aYl.eenent for the remediation
of the Site was reached in the s\.IlTtter of 1985. However, because of the
complex nature of the a':j!.e-e:lllent and the n\mber of parties involved,
final agreement was delayed until September 1986. This agteement is
'-'!Il1b:xtied in the Consent Decree-Remedial Action Plan (CD-RAP) entered by
the U. S. District Court for the District of Minnesota in the U. S. vs.
Reilly Tar (Case No. 4-80-469).
This remedial action is the latest in a series of remedial actions at
the site to be completed in accordance with the prescriptions of the
CA-RAP. Under a Record of Decision that was issued June 6, 1984, a
Granulated Activated Carbon (GAL:) treatment system was constructed to
treat contaminated Prairie du Chien Aquifer water fran St. Louis Park
municipal wells SLP10 and SLP15. The ~ system has been in operation
since July of 1986. Additional actions were taken under an Enforcenent
Decision ~nt (EDD) dated May 30, 1986. The EDD also in;>lenented
actions-"proposed in the CD-RAP. Remedial actions completed to date
under"the EDD include investigation, !TOnitoring, pumping, and treatment
in the lronton - Galesville, Prairie du Chien - Jordan, and the Drift -
Platteville Aquifers. Other actions in the near surface soils include
filling of a small wetland to prevent waterfowl nesting in a heavily
contaminated area, and a soils investigation between the Site and
Mirmetonka Creek to deteDnine the extent of soil contamination off-site.
~nitoring of the Mt. SiJron - Hinkley Aquifer is ongoing. Municipal
wells in the Mt. Sinon Hinkley Aquifer will be treated if !TOni toring
shcMs that drinking water criteria (defined on page 7) are exceeded.
'I11ere are no dcmestic wells in that deep aquifer. Both the 1984 ROO and
1986 EDD are available for review as a part of the administrative
record. .
CCH1UNITY RElATIONS
Various community relations activities were conducted to solicit public
ccmrent on the proposed plan for the St. Peter Aquifer. A fact sheet on
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f/
. .
III.
-3-
the proposed plan was nailed out in April 1990 (Attactment 11). MPCA
issued a news release on the prop::>sed. plan on May 2, 1990 (Attadment
'2). A notice of availability of the prop:>sed plan and announcarent of
the public ccmrent period ~re published in the Star Tribune newspaper
on May 4, 1990 (Attachrrent '3). The public ccmrent period extended fran
May 7, 1990, through June 8, 1990.
The Agencies also held a public meeting on May 16, 1990, at the City of
St. Louis Park council chambers to present the Remedial Investigation,
Feasibilit.y Study and the Proposed Plan for containing the spread of
contaminated. ground water. All of these docUJrents we.Ie made available
at the St. Louis Park Public L.i.b.raxy which is the repository for the
Site. Caments received during the public ccmrent period ~re
considered in the Agencies final decision in selecting a raned.ial
alternative. All \..'Ullll:ilits which wre received prior to the end of the
public caTItEJ1t per iOO, i1rluding those expressed verbally at the public
neeting, are addressed in the Responsiveness SUIt11W:Y in Section X of
this ROD.
SCOPE AND RJLE OF OPERABLE UNITS
This Record of Decision (ROD) sunmarizes the alteI:T1atives considered for
the St. Peter Aquifer and, in particular, fOIIMlly evaluates the
prefen1:!d alternative specified. in the Consent Decree - Remedial Action
Plan (CD-RAP) against the 9 criteria identified in Section VII of the
ROO. The preferred remedy consists of using well W410 as a St. Peter
Aquifer gradient control ~ll.
In accordance with the remedial objective stated in the CD-RAP, of
naintaining drinking water quality in the St. Peter Aquifer, this
alteI:T1ative addresses water quality in the St. Peter Aquifer. Section 8
of the CD-RAP dealt with the St. Peter Aquifer. Section 8.3, Remedial
Actions, specified that: "'!he Regional Jdninistrator and '!he Director
may; . for the p1rpOSe of preventing the further sptead of ground water
exceedinq any of the Drinking Water Criteria defined in Section 2.2,
~ Reilly to install and operate a gradient control well system
consisting of one or two gradient control wells". '!he St. Peter Aquifer
gradient control well will operate independently of other remedial
actiaus requimd by the CD-RAP for the purpose of preventing the further
spread of contanination. Remedial Actions taken at other areas of the
ReWy Site may, ha.Never, influerce the duration of this alternative.
For 8X111ple, mconstructing well W23, sealing nulti-aquifer wells,
operating source am gradient control wells in other aquifers, providing
treated drinking water, ani continuing to nDnitor groun1 water quality
will affect the operation of well W410 to varying ~.Lees.
The activities described in this IU) are int.errled to remediate the
contamination in the St. Peter Aquifer, which is one of the five
aquifers urxierlying the Site. '!he full range of Site related activities
that address other rsnaining contamination issues are specified in the
CD-RAP. One or JlDre future RX>s will address the remaining problems
presented by the Site. '!he Remedial Action for the St. Peter Aquifer
described in this cixument addresses the prin::iple threats to health and
. the enviroI'l11ent posed by the aquifer at the Site.
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IV.
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SUMMARY OF SITE QiAAACTERlSTICS
Contamination in the St. Peter Aq~ifer exists in the form of dissolved
concentrations of PAHs in the ground water. PAH may have arrived in the
St. Peter Aquifer through a combination of t~ likely pathways from
the Reilly Site. .'
1.
Dissolved PAns following ground water flow patterns from the
Drift-Platteville Aquifer through buried bedrock valleys or
fractures in the Glenwood Shale confining layer.
Dissolved PAHs following ground water f: ow patterns via
multi-aquifer wells tha~ serve as conduits far rapid ~aId
migration.
2.
3.
Direct introduction of coal tar n-aterials into well v.."23.
to'J..igration of PAHs through t.hE:!s,: three pathw?ys has created the current
plume of dissolved contaminants in the St. Peter Aquifer. Based on
these conditions, the primary potential effects of contamination are on
drinking water supplies and on the natural resource value of
uncontaminated portions of the aquifer.
The Remedial Investigation (RI), completed September 13, 1989, consisted
of the installation and m:mitoring of five wells, as required by the
CD-RAP, in addition to the monitoring of existing wells in the St. Peter
Aquifer. The locations of these wells are illustrated on Figure 2. The
goal of the RI was to define the area of ground water contaminated with
PAHs above the dri..nk.ing water criteria. (See section VII of the ROD
entitled "CClt1?liance with ARARs" for criteria.)
The results of t'NO rounds of gI:OUI1d water sanq;:>ling during the remedial
inves,tigation are shown in Table 1. ()11y municipal well SLP-3 and
rronitoring well W408 contain PAH concentrations below drinking water
criteria for both san1?ling rounds. For the most part, the criterion of
280 parts per trillion for "Other PAH" is the only criterion exceeded by
the other wells. However, wells W14 and W409, in the first round only,
exceeded the criteria of 28 parts per trillion for carcinogenic PAH.
Based on this ground water sampling, the current interpretation of the
extent Qf contamination in the St. Peter Aquifer is shown in Figure 3.
The results of an additional study that was needed to cClt1?lete the
Feasibility Study (FS) was subnitted to the Agencies on Novanber 15,
1989. This study was entitled "Report on the Pumping of the St. Peter
Aquifer at Well lDcation W410 in St. Louis Park, Minnesota" (W410
Report). The W410 Report documented the reconstruction of well W410
fran a rronitoring well to a pulT1?ing well, and its ability to control the
area of contaminated ground water. The W410 Report consisted of a
pumping test conducted in Septanber 1989 to study the aquifer's response
to p.mtping of the well. Data obtained fran the test was used to
calculate pumping rates necessary to contain contamination in the St.
Peter Aquifer. It was determined that a pumping rate of 65 to 100 gpn
for well W410 would capture the contaminant plun-e shcMn in Figure 3. A
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~~e:;c2: ~, ~~cella..'1e:;us ~.a~ Se.=i.es,
~S7, Plate 1 of 2, 3edrock GeQl~/,
by ,Bruce A. Bloamgren, 1985
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EXFL.,ANtoTION
LOCATION AND PROJECT WELL NUMBER
J/;,.
OBSERVATION WELL COMPLETED IN ST. PETER AQUIFER
.
OBSERVATION WELL COMPLETED IN, BASAL ST, PETER CONFINING BED
8
ST. PETER MONITORING WELLS CONSTRUCTED IN , 987
@
WELL IN WHICH WATER LEVELS WERE MONITORED WITH A DIGITAL
RECORDER DURING PART OF 1978-81
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BEDROCK VALLEY ICONTACT WHERE UNCONSOLIDATED DRIFT '
DEPOSITS OVERLIE ST. PETER SANDSiONE
Figure
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:1or.i.t::>ring I.'ell
LOC3:ior.s
-------
Well
SLP
W14
W24
W33
W122
W129
W133
W408
W409
W410
W411
W412
P116
TABLE 1
SlIMMARY OF ANALYTICAL RESULTS
\)
Total PAH Concentrations, ng/l
First Round (7/88) Second Round (10/88)
Other Care ir.--genic Other Care inogenic
PAH PA.:..J PAH PAH
8
95
3,309
16,430
142
88
52,370
151
2,192
1,288
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1,274
1,309
196
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57
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21
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2
159
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8
8
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10
438
3,622
12,455
2,246
290
29,830
34
890
1,435
1,161
209
3,770
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~.. 1.1 . ",I.. I I.'..
I.-
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5
PJ1'Ii>ing rate of 100 gpn 'NCUld exterrl tbe capture zone a1::alt 1/2 mile
dowrqradient of Well W410 (See Figure 3). Well W410 will be p..II1ped at a rate
of 65 to 100 gpn, deperding on the extent of contamination i11 the aquifer as
determined by conti11uous grourd water nonitorirg of wells to the east and
sootheast of the CUITently defined contaminant plurre. 'l11e FS Report was
su1:::6equently CClTi'leted on April 26, 1990, basa:j on the results of the well W410
Report.
v. ~y OF SITE RISKS
'!he grc:AJTd. water, soil and surface waters on and near tbe Reilly Tar site
have been irrpacted by site-related contaminants. '1hi.s doc:urts1t represents
the oojectives of response actions for one operable unit, the St. Peter
Aquifer, within the overall site strategy. '!be p.1I'pOSe of this section is to
discuss the risks posed by the contaminated groun1 water at the Site to hurran
heal th and the environment.
'!he exposure pathway of greatest ooncern for h1.Jl!'aI1 health is the ingestion of
contaminated groond water used for drinkin;J or cookin;. Although there is one
municipal well i11 the St. Peter Aquifer whid1 is used during periods of peak
demand, tbe majority of drinkin;J water in St. LcW.s Park is OOtained fran the
other deeper aquifers. '!he St. Peter Aquifer m.uricipal well is located
upgraclient of the DaVement of the contaminant plume and has consistently
produced water of good quality. Because of the infrequent use of this graJnd
water for drinkin;J and the historical record of good quality, exposure thrc:AJc;2h
ingestion of water fran the St. Peter Aquifer is not a primary conce.rn.
'!he remedy will contain the spread of contaminated groun1 water of PAH' s in
the aquifer by the interception and containment by ~in;J well number W410.
By containing the spread of contamination in the St. Peter Aquifer, the remedy
will preserve the quality of groun1 water in the rest of the aquifer and will
also reduce the potential of cross contaminatiat of deeper aquifers used for
drinkin;J water. 'Iherefore, the increase in envi.rcnnenta1 risk is negated.
VI. I:ESaUPl'ICfi OF ~
'!be objective' of the remedial actiat is to prevent, reduce, and control the
spread of contaminant in the St. Peter Aquifer.
~ 1 - NO AcrI.CN WI'l1i M:m'IaUNG
'D1e alt8mative of t.akin} no actioo to limit the spread of contaminated grourd
water has not been c::cn;idered in the FS and Plqa;ed Plan because this
alternative is not allowed un:ler the CD-RAP. Moreover, by takirq no action,
the first two evaluatioo criteria (overall protectioo of human health and the
environment and oarplianoe with ~licable or Relevant and ~ropriate
Requirements (ARARs» WQ11d not be met. Water quality data Presented in the RI
Report in:ticate total PAH OOJ'Centratia'lS 10 to 100 times higher than that
allowed in drinkin;J water. '!be no action alternative does not aQjresS the
risks presented by this contamination and, therefore, is not considered, in
this RD.
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g
VII.
-6-
ALTERNATIVE 2 - USE OF GRADIENT' CCNI'ROL WELL ( S)
The W410 Report described the use of well W410 for gradient control and
showed that pumping well W410 at a rate of 65 to 100 gallons per minute
will intercept and control the spread of contaminated ground water. The
discharge fran the well is contaminated with PAH and will initially be
routed to the sani tary sewer for treat:1rent at the Metropolitan Waste
Control Ccmnission (Mrl:C) wastewater treatJTent plant. Within three to
five years after the start of pumping, this will be changed to a stonn
se.-.er discharge that will eventually go to Minnehaha Creek. Before the
change fran sanitary to stonn se.-.er discharge will be allowed, a
detennination m.lst be made whether on-site treatJTent will be necessary
under a National Pollutant Discharge Elimination System (NPDES) perrni. t.
One of the requirarents of ~larenting this ranedy' s continued water
level and water quality ITOnitoring is not only to document the
effectiveness of the ranedy but a1so to deteDnine the need for on-site
treat:JTent.
CCMPAAA-"TVE ANALYSIS
The ranedial alternatives the City developed in the RIfFS were evaluated
by the U.S. Envirormental Protection Agercy and Minnesota Pollution
Control Aqercy using EPA's nine criteria. Si.oce the no action
alternative is not protective of human health nor does it meet ARARs,
only the preferred alternative (Alternative 2) will be evaluated against
the nine criteria which are as follCMS:
L
Overall protection of Human Health and the Environrent: addressing
whether an alternative provides adequate protection and describes
how risks are eliminated, reduced or controlled through treatrrent
and engineering controls.
CClTplian:e with Applicable or Relevant and Appropriate
Requiranents (ARMs'; addressing whether an al temati ve will meet
all of the applicable or relevant and awropriate requi.ratents or
" provide grouOOs for invoking a waiver.
2.
3.
IDng-teIm Effectiveness and Permanence: referring to the ability
of an alternative to maintain reliable protection of human health
and the environrent, over time, once cleanup objectives have been
IIIBt .
4.
Aeduction of Toxicity, M:>bility, or VohmE; referring to the
anticipated perfonnance of the treatment techoologies an
al ternati ve may Eltt'loy.
5.
Short-tenn Effectiveness; involving the period of time needed to
achieve protection and any adverse iJTpacts on Junan health and the
envuVJ8l1ent that may be posed during the construction and
iJrplementation period until cleanup objective are achieved.
IJrplementability: addresses the technical and actninistrative
feasibility of an altemative, including the availability of
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-7-
7.
Cost; including capital costs, as well as operation and
maintenance costs.
8.
Agency Acceptance; indicating whether, based on their review of
the RI, FS and Proposed Plan, the Agencies' agree on the preferred
alternative. .
9.
Community Acceptance; indicating the public acceptability of a
given alternative. This criteria is discussed in the
Responsiveness SI..IIT11'arY'
The following is a detailed analysis of each of the evaluation criteria
for the preferred alternative:
A.
Overall Protection of Human Health and the EnviroI1l1Ent
Using well W410 for gradient control provides overall
protection of human health and the enviroI1l1Ent by limiting' the
further spread of contamination wi thin the aquifer. No human
health risks have historically been associated with
contamination in the St. Peter Aquifer. Well SLP3 is the only
drinking water well that draws water fran the St. Peter
Aquifer within St. Louis Park. This well is located northeast
of the Site, Figure 2, and in the past has consistently
produced groW1d water of good quality. Continued m:mitoring,
as required in the CD-RAP, of wells SLP3 and W408 will
eliminate and/or control the potential human health risk.
The primary fW1ction of operating well W410 as a gradient
control well is to provide overall protection to
uncontaminated portions of the St. Peter Aquifer. By
, preventing the further spread of contamination, overall
, protection of the environment will be achieved.
"
B.
ARARs C~liance
ARARs for this alternative are defined in the CD-RAP, Sections
2.2 and 2.5:
Drinking Water. Criteria
Advisory
Level
Drinking Water
Parameter Criterion
The sum of benzo ( a ) pyrene
and dibenz(a,h)anthracene
3.0 ng/l*
5.6 ng/l
Carcinogenic PAH
Other PAH
15 ng/l
175 ng/l
28 ng/l
280 ng/l
*
Or the lowest concentration that can be quantified,
whichever is greater.
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-8-
The Safe Drinking Water Act specifies Ma.x..i.rnum Contaminant
Levels (M:Ls) for drinking water at p.1blic water suwlies.
Since M:Ls for PAl-{ ccmpounds were not developed through the
Safe Drinking Water Act regulations, it was necessary to
derive Driryking Water Criteria for the Site. This was
accomplished through consultations with experts and the
Minnesota Department of Heal th along with MPCA and EPA
representatives. These Drinking Water Criteria are not
considered to be an ARAR since they are not M:Ls. fio,.,Bver,
the Drinking Water Criteria are defined as a TEC (To Be
Considered.) TECs are advisories, criteria, or guidance that
were developed by EPA, other federal agencies or states that
may be useful in developing CERCI.A remedies.
The Drinking ~ter Criteria were first set out in the USEPA
Em in 198~and they represent an excess lifetime cancer risk
of 1 x 10 . This risk indicates that, as a plausible upper
bow1d, an individual has a one in one million chance of
site-related exposure to a carcinogen over a 70-year lifetime
under the specific exposure conditions at a site. This TEe
will be met by the preferred alternative by preventing the
spread of ground water exceeding these Drinking Water
Criteria.
Surface Water Criteria
-Daily Max.inun
Parseter
Coocentration
30-day average
Concentration
, Carcinogenic PAH
,
Other PAH 34 ug/l
PhenanthJ:ene 2 ug/l
Pheools
70 ng/l*
17 ug/l
1 ug/l
10 ug/l
. '!he CD-RAP specifies 311 ng/l, hc7wever, 70 ng/l is the current
discharge Limit for carci.r¥:lgenic PAH.
'!he Clean Water Act (00lA) and the regulations under it apply
to contaminated water (surface or extracted
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-9-
1m tially, puI1'p8d ground water will be discharged to the
sani tary sewer and then be treated at the K-a: wastewater
treatment plant. The 1+0: had issued a permit to the City of
St. Louis Park for this planned discharge (Attachrrent 14).
Publicly owned treatJrent works such as the ~ treat:Jrent
plant are required by the Clean Water Act pretreatment
regulations t.o 1 imi t the introduction of toxic or hazardous
substances which may interfere with the treatm:mt process or
pass through untreated to surface waters. The r-w:c permit
contains pretreatment limits for various contaminants
including PAHs. The discharge fran the Site will rreet the
r-w:C permit pretreatment limits. The ~ wastewater
treatment plant also has an NPDES permit which is included as
Attachrrent 5.
The operation of the St. Peter Aquifer gradient control well
will be governed by the use of these ARARs or other, rrore
stringent, limits established by the Agencies over tine. An
example of this is the change in the surface water criteria
fran 311 ng/l to 70 ng/l fran the time of the writing of the
CD-RAP to the present time. Drinking water criteria will be
used to assess the need for ground water control measures
throughout the aquifer, while discharge options for ground
water that is raroved will be evaluated against the surface
water discharge criteria.
RCRA may be an ARM. for the Site. If on-site treatment is
required for the discharge fran W410, the process will
probably generate "spent carton". This teD1\ refers to
granulated activated carbon contaminated with PAHs. "Spent
carbon to will be returned to tle manufacturer for regeneration
and reuse. If the testing of the spent carton detennines it
to be a hazardous waste as defined by feRA, and if regulated
quantities are generated, then the requirements of RCRA would
be ARARs for the Site. 'n1e Land Ban requirElnents of feRA do
npt apply to the disposal of spent carbon since the carbon
will be regea.erated and reused and no land disposal is
contElrplated .
C. lDng-tem Effectiveness am PeDNmeIX:e
Once the response objective is net, and the further spread of
contamination has been prevented, residual levels of PAH will
remain in the aquifer. Based on the relatively large volune,
10« concentration, and 10« nDbility of the contaminants, this
residual PAH is expected to remain in the aquifer for at least
the 30-yea.r life of the CD-RAP. PlItpiD;J will continue as long
as necessary to prevent the further spread of contamination.
'n1e potential risks posed by residual contamination in the
aquifer after plune management activities are concluded are
very small because of the lack of a human exposure pathway
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-10-
(municipal well SLP3, which draws fran the St. Peter Aquife::-
is upgradient of the contamination plume for drinking water),
and because the low mobility of the PAH compounds reduces
their ability to migrate.
On-site treatment of the discharge fran W410, if needed, will
likely generate granulated activated c~bon contaminated with
PAH, which is called "sp:mt carron." Any spent caroc-n that is
generated will be evaluated for acute toxicity. If the acute
toxicity levels are similar to the Prairie du Chien Aquifer
GAC levels, the spent carbon will be sent back to the
manufacturer to be regenerated and then re used. The carbon
is regenerated by bur;'~ off the PAHs under controlled
conditions; the carron g~nerated fran other plants treating
gradient control water is expected to be similar. Therefc::e,
no significant additional risk fram spent carbon is
anticipated.
The pumping technolo~ for this alternative is a standard,
reliable, and proven technology for lieeting project
objectives. System canp:>nents may require replacement during
the life of this ranedial action, but replacement should be an
easy procedure. The City of St. louis Park has been operating
and rrainta.ini.ng ground v-later pumping systems for over 40
years, thus no problems with the adequacy or reliability of
controls is anticipated.
D.
Reduction of toxicity, mobility, or volurre through treatment
"
The nost ~rtant feature of this alternative is the control
exerted by the p.mping well on the vol\m'e and mobility of
contaminants within the aquifer. During the course of
purtt:>ing, the nore nobile PAHs will be raroved first, leaving
, less nobile PAHs in the aquifer that will be released slowly
over time. As previously indicated, this alternative is
pr.iJnarily intended to cO:itrol the spread of contamination.
Accordingly, 9n-site treatment of pumped water is not a
principal elerrent of this alternative, but will be ~lerented
if so required by the NPDES pewt.
E.
Short-TeDn Effectiveness
The construction and implementation phase of this alternative
does not present worker or catTl1l..1nity exposure, and will not
cause adverse enviroranental ~cts. During the short
construction project a well punp will be installed in the
existing well house. Based on the previous aquifer test, the
fw:ther spread of contamination in the greatest part of the
aquifer will be halted within approximately two days after the
start of pumping. Therefore, there will be a relatively short
time pericx:i in which short-tem effectiveness can be assessed.
The need for additional response actions in portions of the
St. Peter Aquifer that are outside the influence of the
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-E-
pumping well will be ad'~essed based on future ground water
monitoring results. Mor~toring of wells installed in the St.
Peter Aquifer is ongoing.
F.
Lmplementability
There are no outstandinc issues relative to the technical
feasibility of bnplementing this alternative. The techno log}'
for pumping ground water is reliable, and easy to maintain.
There should be little potential for schedule delays, or
conflicts with other remedial actions taken at the site.
Repair work on system CaTlpOnents will be similarly
straightforward. Ground water monitoring, and monitoring the
discharge from the pun~ing wells will provide an adequate
rreans of assessing exposure pathways. Obtaining the necessary
permits is not expected to be difficult. The sarre remedial
actions are currently being practiced elsewhere at the Reilly
Site. PeDTritting authorities soch as the Metropolitan Waste
Control Cc:mnission, Mirmesota Department of Natural Resources,
and Minnehaha Creek Watershed District have a precedent to
follow in dealing with this activity.
Services and materials for this work are all available at
competitive bid prices, and will not limit the
il11plementability of this alternative.
G.
Costs
"
Project costs are minimal at this point based on the amount of
work that has already been done to construct and test the
well, and build the well house. Capi tal costs for equiprent,
installation, engineering, permits, startup, and contingencies
, are estimated at $225,000 ($200,000 of this cost is for the
, Metropolitan Waste Control Carmission service availability
charge). If a treatmant facility is required for a surface
water disposal option, th"'! capital cost of the treatment
facility is estimated at $:50,000. Annual operation and
maintenance (0 & M) costs .,re also minimal for this
alternative because of the nany other gradient control wells
that are currently cared for by the City of St. Louis Park.
o & M, materials, energy, disposal of residues, purchased
services, administrative costs, and other post-construction
costs that may be required to ensure the effectiveness of this
remedial action are estimated at no rore than $60,000 per
year. Major cCJTlp:>nents of the annual 0 & M costs include:
se'Ner charge
electricity
labor
$35,000
$ 2,100
$20,000
If major equipnent problems occur, and replacement is required
at same time during the first 30 years of operation, two to
four weeks should be sufficient for installation and stal-"J~
of equiprent. This time span is short enough that, giver."'.:.he-
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-12-
relatively slow velocity of ground water travel in he aquifer
and the large capture area of well W410, contaminants are not
expected to escape the area controlled by the well.
No cost sensitivity analysis was performed due to the
relatively high certainty of project costs.
H.
Agency Acceptance
Both U.S. EPA and MPO. are in agreenent with the reredy
because it is protective of public health and the eIT:ironment
and satisfies the nine required evaluation criteria. The
remedy is also consistent with the Daoedial action specified
in the CD-RAP.
1.
Community Acceptance
Community acceptance is assessed in the attached
ResFOnsi VE>:1ess Sl.ITJ1'1'1al'y. The Responsiveness Surrmary provides a
thorough review of the public cc:mnents received on the Rl, FS
and Proposed Plan, and the U.S. EPA's responses to the
cc:mnents received.
VIII. SELECI'ED REMEDY
The preferred alternative of using well W410 as a gradient control to
contain contamination in the aquifer has been found to satisfy the 9
evaluation criteria and thus, is the selected alternative. The well
will be ~ at a rate of 65 to 100 gpn, depending on the extent of
contamination in the aquifer as determined by ground water JrOnitoring.
For the first five years following the effective date of this ROD,
ground water sant'les will be collected on a se-niannual basis frcrn the
following wells: SLP3, W24, W33, W122, W129, W133, W408, W409, W410,
W411, W412, and P116. These samples will be analyzed for the
CarcinOgenic PAH and Other PAH listed in Appendix A of the CD-RAP. The
wells to be sampled and the frequency of sampling will be re-evaluated
after the five year period. Water level nea.surements will be taken at
all the above wells, as well as at W14, on a quarterly basis for the
first year, and. semiannually thereafter. If the proposed range of
pumping rates is not sufficient to control the spread of contamination,
additional wells may be required for gradient control.
Well W410 will initially discharge to the ~C wastewater treatment
plant for treatJrent of the contaminated groundwater. Within three to
five years, MPCA anticipates that the water quality of ground water
pumped fram W410 will be improved sufficiently to meet National
Pollutant Discharge Elimination System (NPDES) limits. This would allow
MPCA to route the grow1d water pumped fran W410 to a stom sewer for
eventual discharge to Minnehaha Creek. If necessary, an on-site
treatment facility will be built to ensure that the ground water meets
National Pollutant Discharge Elimination System (NPDES) limits.
The selected remedy is consistent with the CD-RAP, 8.3 which specifies
the installation and operation of one or two gradient control wells to
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IX.
-13-
prevent the further spread of ground water exceeding any of the drinking
water criteria defined in CD-RAP Section 2.2. Because the CD-RAP
requires that the Potentially Responsible Parties control the gradient
in the St. Peter Aquifer and specifies this particular remedial action,
the analysis of this a:~rnative builds on various earlier studies,
referenced in the CD-~, tlJat developed and s~reened alternatives.
STATtJIORY DFI'ERMINATICNS
The selected remedy must satisfy the requira"nents of Section 121 of
CERClA, which are:
. Protect human health and the environment
. Canply with ARARs or justify a waiver
. Be cost effective
. Utilize pernanent solutions and alternative technologies or resource
recovery techrol~ies to the maxbun extent practical
. Satisfy the preference for treatment as a principal eleltS1t or explain
why preference was not satisfied.
Protection of Human Health and the Enviroment
The selected remedy provides overall protection of human health
and the envirorrrent by limiting the spread of contamination within
the aquifer. No human health risks have historically been
associated with PAH contamination in the St. Peter Aquifer.
Municipal well SLP3 is the only drinking water well that draws
water fran the St. Peter Aquifer. '!his well is only used in
periods of peak water clenand and is located upgradient of the
contaminant plume. Well SLPJ has consistently produced ground
water of good quality. The na;t inp:>rtant effect of this remedy
is to provide protection to wx::ontaminated p::>rtions of the St.
Peter Aquifer arrl thus achieo.ring overall protection of the
enviroul1e11t.
",
2. "Ca'f1)liarre with MARs
'!he selected alternative will Beet all applicable, relevant and
approPriate requirElnents (MARs) of federal law or rore stringent
state laws. '!he following discussion provides details of the
MARs that will be met by this I'EltEdial action.
1.
e. Safe Drinking Water Act (SDiA)
As previously discussed in Section VII B of this 10:>, the
Drinking Water Criteria developed for this Site are considered
to be a TEe. '1he rEllE!dial action is required by the CD-RAP to
prevent the spread of contaminated ground water in the aquifer
that exceeds these Drinking Water Criteria.
b. Clean Water Act (c.wA)
Surface water discharge criteria for the Site are set forth in
the NPDES peDnit issued under the c.wA and are shown in Section
VII B of this fO). '1'reatJrent of the discharge fran well W410
will initially occur at the !K:C wastewater treatJrent plant.
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-14-
The discharge from the Site will comply with t}~ pretreatment
requirements of the Clean Water Act (40 CFR Part 403). In
three to five years, the ground water from ~ll W410 may
be discharged to a storm seo...er. The discharge to the storm
sewer must meet the NPDES permit discharge limits. An on-site
treatment facility may be necessary so that the discharge fran
~ll W410 will meet NPDES peDTlit limits.
c.
Resource, Conservation and Recovery Act (RCRA)
RCRA may be an MAR for the Site. If on-site treatment is
required for the discharge fran W410, the process will
probably generate "spent ca.rl::on". This teDTI refers to
granulated activated ca.rl::on contaminated with PAHs. "Spent
carbon" will be returned to the manufacturer for regeneration
and reuse. 1 f the testing of the spent ca.rl::on detennines it
to be a hazardous waste as defined by R:RA, and if regulated
quant i ti es are generated, then the requi.rE:Pents of RCRA would
be ARARs for the Site. The Land Ban requi..ra1ents of RCRA do
not awly to the disposal of spent ca.rl::on since the cal.-oon is
to be regenerated and reused and no land disposal is
contenplated.
3.
Cost Effectiveness
Raneclial costs for the selected rertedy are mirU.IMl at
approximately $250,000 in capital costs. Since the only other
alternative that was considered was the no action alternative, a
rigorous cost effective catparison cannot be made. It is unlikely
however, that any other proposed alternative could be rrore cost
effective. Annual operation and maintenan:e costs will be
awroximately $60,000, which is lower than at other sites because
of the many other wells currently maintained by the city of St.
Louis Park.
4., Utilize Pexmanent Solutions and Alternative Technologies or
'Resource Recovery Technologies to the MaximJm Extent Possible
'n\e selected alternative of contairment by ~ing ~ll W410
represents a peunanent solution. 'n1e PAWs are expected to. renain
in the aquifer for at least the 30 year life of the CD-RAP. .
P\IIping will continue as long as necessary to contain the spread
of c:ootanination in the aquifer above Drinking Water Criteria
levels. P\mping is a standard, reliable and proven technology for
DBetinq ranedial objectives. In three to five years, the
discharge fran well W410 will be routed to the stonn sewer at
which time on-site treat:rrent may be necess~ to JlEet NPDES
discharge limits.
Satisfy the Prefererce for Treatment as a Principal Elenent
'n\e II1JSt inp:>rtant feature of this alternative is the control
exerted by the ~ing well on the volume and m::>bility of
contaminants wi thin the aquifer. During the course of ~ing,
the IIDre m::>bile PAM will be rem:wed first, leaving less robile. PAH
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-15-
in the aquifer that will be released slowly over tim:. As
previously indicated, this alternative is primarily intended to
control the spread of contamination. Accordingly, on-site
treatment of pumped water is not a principal element of this
al ternati ve, but may be implemented if so required by the NPDES
peImi t .
x.
RESPONSIVENESS SUMHARY
The Agencies held a public comment period from May 7, 1990 though
June 8, 1990, for interested parties to comment on the Proposed Plan.
The Agencies also held a Public meeting at 7:30 p.m. on May 16, 1990 at
the City Council Chambers in st. Louis Park, Minnesota to present the
RI.
Several questions were asked d.xing the public meeting.
are sl.IITmarized b2~:)W, along \.:it.h t~ MPCA's responses.
The questions
Question:
Will the cost of this project fall on the taxpayers? Who
pays for it?
MPCA Response:
The City will pay the costs of the project using funds
received fram the Reilly Chemical Corporation. The
company has set aside a $1 million contingency fund for
expenses that were not foreseen during negotiations on
the settlement, and this project does qualify as a
contingency itE!'!l eligible for reirobursement fram the
fund. No expenditures have been made from the fund.
Question:
Is there a possibility that the water ~ fram this well
could be discharged to Y~haha Creek?
MPCA ~sPonse:
Question:
The water will be discharged to the sanitary sewer
systE!'!l for at least the next three to five years. The
water will be analyzed periodically and the MPCA
anticipates eventually being able to take it off the
sewer connection for potential discharge to surface
waters after on-site treatment. This will not happen
until the water's quality is proven and an opportw1i ty
for public review and ccmnent has been provided.
Is the soil on the Site still contaminated and is it still
polluting the aquifers under it?
MPCA Response:
About one million cubic yards of contaminated earth
still reside at the Site, and are affecting mainly the
upper aquifers. That anount of earth "-'OUld be
prohibitively expensive to rarove or treat using present
technologies. Because it is presently impossible to
reJTCVe the source of the contamination, the focus of
-------
Question:
-16-
cleanup is to limit its spread and treat the affected
ground water. Ce'veloping technologies such as
biorenediation m3y allow treatJT1ent of the soil in the
future.
~10 is doing the s~)1ing of the water? Are they testing for
all the chemicals found at the Site?
MPCA Rest:Dnse:
Question:
Rocky Mountain Laboratories of Arvada, Colorado. The
methcd being used is gas chrcrnatographY/m3ss
spectrometry, yielding results in the parts per
trillion. Currently there are no local labs that can
provide this level of anal}'"Sis. The lab meets the U. S.
EPA's contract lab standards, which provide for periodic
revieo,..; of laboratory methodologies. The Consent D:?cree
identified approximately three dozen chemicals to be
tested, which include all the PAris found at the Site.
There were several multi-aquifer wells in the area that might
allow migration of contaminants fram one aquifer to another.
Is the MPCA sure they've fOlUld and sealed than all?
MPCA Rest:Dnse:
Question:
The Health DepartIrent investigated and abandoned many
such wells in the area in the 1970's and 80's. There is
one ~ll whose existence is known, but it has not yet
been found. Its general location is known; h~~ver, it
was drilled in the last century and there's no one
living who can pint:Dint it. Evidence suggests it was a
deep well extending into the Mt. Sim:m-Hinkley aquifer,
so the MPCA is doing its best to find this ~ll.
There wet£' a prc'P;)sal in the past to discharge conta."'1.inated
water fran one of the wells in these aquifers into Lake
Calhoun that was rejected. What is the status of that well?
Is it being used?
MPCA Response ~
The City of St. Louis Park has hired a consultant to
design a granular activated carbon treatment plant to
treat the water fram that well. The ~ll is currently
closed and will not be used until the treatment plant
is ready. When it is, the water will be treated and
made a part of the City's municipal supply, the same as
is currently done with the two wells in Bronx Park at
29th and Jersey. .
-------
-17-
Community Relations Activities Conducted for
the Reilly Tar and Chemical Site, St. Peter Aquifer
Attachment #1 April, 1990
Attachment #2
May 2, 1990
Attachment #3 May 4, 1990
May 16, 1990
Fact sheet mailed out, re:
Peter aquifer.
Prop:)sed Plan, St.
Ne<.-.-s releasemailedout.re :
Prop:>sed PIan
Public comment on
Advertisenent in Star Tribune ne.vspaper
announcing availability of Prop:)sed Plan and date
of public meeting and comment period.
Public meeting held at St. LJuis Park City
Offices.
-------
..
Superfund Proposed Plan/Foct Sheet for
ATIACH11.::~7 ~:
Reilly Tar and Chemical Site
April, 1990
This fact sheet summarizes the
U.S. Environmental Protection
Age:1cy's (EPA) and ~1innesota
Pollution Control Agency's
(MPCA) joint proposed cleanup
plan for pan of the Rcilly Tar
and Chemical site. 'This ~m-
mendation follows a complete
investigation of ground water
cor.umination and a stUdy of
feasible cleanup options.
What is the history of the site?
Berween 1918 and 1 r:T72. Repub-
,lic CreosOte. a subsidiary of
Reilly Tar and O1emical Corp.,
operated a coal-tar distillation
and wood-preserving plant on an
80-~ site in St Louis Parle.
The former site is nqnh of
Highway 7 and west of Louisi-
ana A venue. Oak Park Village
condominiums are located. on the
northern portion of the site.
Durin g those years, wastewater
from the distillarion process was
disposed of in a series of ditches
emprying intO what had been a
swampy area south of the site.
Spills and leaks also contami-
runed the surface soils, and tar-
like materWs were found deep
in a \Ir'aI.er well on-sire.
These activities caused signifi-
cant contamination of the ground-
WaIf'.T in the a!""...J. 0: the Reilly
site v.-ith creosore and other
chemicals affecting human
health. The problems at this site
have been well publicized
throughout the late lr:T7Os and
'80s, and it has been the object
of a high-priori:y Superfund
investigarion and cleanup since
the early' 80s. The site has nor
teen in use since 1 r:T72., and
. contaminated municipal water
wells are no longer used.
.. ..
While the immediate drinkin g-
water emergency has been taken
care of. the ground warer in the
area is still comamin ared and
poses potential problems.
Oeaning up the ground water is
the focus of most of the curren!
effortS at the Reilly sire.
In 1986, the fanner O\lri1e~ of
the Reilly site, along v-lith the
Ciry of St Louis Park. signed a
cleanup agreement, called a
Consent D~~, with th~ EPA
and MPCA. Under this agree-
ment, the parties responsible for
the site were to continue investi-
gating the exrent of the problem
and conduct necessary cleanup
.. . . .. ... . d...
,i.lJ1e'MPcAYianf~. ..ypur ,cornrnents.
. .....
:,t::':'~:~~~i~IO~~~ifk'~ecs plan 'ala pubjK=
'..rrieetiOQ.' to be held May 16; 7:30p.ni; ,in the first.floor communify
,,'roomof theSLlouis PaJ1(CityOtfices,50Q5 Minne1ONPrttJ1e ':: ':"'.' H:, :
' ,:...::.. ". .. ,. H. ... .. . .:...,.:'....inn>POliutionContro.Agency
HPubiclnformation Ofti~ .:'
: 52Q, 'Layfa)'ette . ~ad' ":'. .,,'. .
,.st:PaJL~,:M~ . 5$155"
:~~,:'~~:~;':~:~~i1~ed,.of);~}~~~~.'J~~ii:.~~~Jf~
~~I -'::
-------
.........".. TWO' ':-:-~.-' ..;..., ~-"- '.' .
~, ~ r',~ '. -~.;;.":!'- ,- '.> ". .'
actions, Because of its complex-
ity. the ove:rall Reilly cleanup in-
vestigation has been divided intO
a nwnber of phases called "oper-
able units," each of which has, or
will have, its own aerion plan.
The: plan for one of these units.
the St Peter Aquifer. is now
ready for public comment (The
other ope:rnble writs are in
various stages of cleanup.)
~Vhy is the MPCA dividing the
site into operable units?
~
The contamination at the Reilly
site occurred over many years
and through many avenues. As a
result, chemicals went deep intO
the ground. The sin: is underlain
by five separate aquifers, or
layers of earth and porous rock
containing ground water. These
aquifm are stacked on top of
one another, separated by various
confinin g layers, going down
hundrMs of feet below the
surface. Communip~' in the
Twin Cities western suburban
area get their drinking water
from these aquifers.
The Reilly site has contaminated
most of these aquifers to varying
degrees in the area of the site.
The ground water in each aquifer
"behaves" differently, moving in
somewhat different clirections.
Because cleanup will be different
for each aquifer. they are being
inve.stigated separately. The St.
Peter is the second layer down,
lying berween about 100 and 200
feet below the surfa.ce. The
contamination in this aquifer
needs to be removed., because it
has the potential to spread to
other drinking water supplies
and/or aquifers.
So what's the cleanup plan for
the St Peter aquifer?
EP A and rv1PCA propose to
pump out the contaminated
water from the aquifer and treat
it so that. it no longer poses a
health risk. The 'investigation
showed that a well in this aquifer
pumping an average of 65 to 100
gallons a minute would induce
ground water in the area to move
tOward the well and be drawn
out of the ground.
Eventually this would cmy all
the contmrination in the aquifer
to the well, effectively prevent-
ing it from spreading from the
Reilly site. The wau:r v.ill be
sent through the sanitary sewer
syStem to the Metropolitan
Waste Control Commission's
(MWCC) main treattnent facil-
ity, where the contaminants will .
be removed.
The well has been constrUcted
and teSted. and is ~dy to begin
pumping as soon as the public
has had a chance to comment on
this remedy.
How can you send chemically
contaminated water to a sewer.
plant?
The water from the pW11p-out is
fairly clean. V.,rh.i1e nor pure
enou gh to be used for d:rinkin g
Wa1eI', it is. for example, cleaner
than StOrnl nmoff. The contami-
nants it contains, primarily
polynuclear aromatic hycirocM-
bons (PAHs), are biodegradable
and can be t:re3I.ed by MWCC.
This is only an interim solution,
and it's likely that this WaICl'
may be treated on-site in the'
futUre. .
Why was this plan chosen?
Remedies in Superfund cl~anup~i
are evaluated against a number
of criteria. A5 Stated, this rem-
edy is only pan of the overall
remedy or cleanup for the Reilly
site; it's not the solution to the
whole problem. The plan was
carefully considered in light of
the following criteria:
1. This remedy providCs overall
protection of human health and
the environment by limiting the
further spread of contamination
within the aquifer.
2. Applicable local ~uire-
ments are complied with in thaI
the water will meet state surface.
water criteria when discharged
from the MWCC's treatment
plant.
-------
~
~
"1'
3. The rem~y will provide for
long-term effectiveness and
permanence by ensuring that th
pwnp-<:>ut will continue as lor.g
as necessary to prevent the
further spread of contamination
in the aquife.r.
4. Tne tOxiciry, volume, and
mob~~y of the contaminantS
preSC:1t in the aquifer v.ill be
effec:ively reduced over time by
the ?urnp-out.
..
5. The conStruction and imp'lem- .
entation of this remedy presents
no worker or communiry expo-
s~. nor any adverse environ-
me:-.ul irnp3.ctS.
6. T:-.~ :::chnolcgy fer this
rer..=-:y is proven, cost-effec-
rive, reliable, and easy to main-
tain.
7. The final criteria are state and.
community acceptan~. The
MPCA has agreed, to . this rem-
edy. and now the communi~ has
an opporrunity to review and
COIT'..,'nent on the proposed
re~edy before it becomes final.
In view of the health hazards
posed by the ground water
contamination from this site,
pumping and treating the water
i.s tWly the only practical
alternative.
How long will the pump-out
need to continue?
Water coming from the well v.ill
be tested pericxiically, and the
pump-<:>ut will continue until the
well proouces water that's \Vithin
state guidelines for drinkin g
water. TIlls may take as long as
30 ye.m, and possibly longer.
What about the rest of the
cJeanup (the other operable
units)?
The other partS of the overall
Reilly investigation relate to the
other aquifers involved. and
have their own investigations
and action plans. They are all in
va...;.ous st3ges of completicI:. but
basically, the same type of
pump-and-treat will be per-
formed, vvith minor variations,
for each aquifer:-
These aquifers are critical water
supplies for a sizAble portion of
the Twin Cities metro area. and
there's no question that they
mUSt be cleaned up and pro-
teeted from the further spread of
contamination related to the
Reilly site. Ground water moves
very slowly, and the cleanup i.s
keeping ahead of the problem.
When all the opc:rable units in
this project are complete and
pumping, the ground water
contamination in each aquifer
resulting from the Reilly site
should be well under contrOl.
What happens next?
With the release of this fact
sheet, the MPCA announ;:cs a
30-day public comment period
on this alre:rn.ative, to end June 1.
A public meeting is scheduled
fer May 16th (see the box on the
firn page of this fact sheet). Fol-
lowing the public comment
perioo. the EP A and MPCA wiil
begin the pum~ut of the SL
- Peter aquifer, vvith any addirior.al
modifications resulting from the
public's commentS.
The response of the tWO agencies
to commentS received will be
available for re\iew in a respon-
siveness summary at the St.
Louis Park Community Lib~--:...
along \Vith the agency's Record
of Decision, which documentS
the reasons for the EPA's and
MPCA's choice of remedy.
Any more questions?
Persons vvith questions are
invited to call Ralph Pribble at
the MPCA's Public Information
Office, 296-7792, or roll-fr-ve 1-
800-652-9747 (be sure to ask for
the ~tPCA).
-------
""III
News Release
Minnesota Pollution Control Agency
520 Lafayette Road, St. Paul, Minnesota 55155
~
Printed on Re
-------
The aquifers under the Reilly site are stacked atOp one another. extending several hundred fee:
below ground Past operations at the Reilly site have contaminated all five aquifers to varying
degrees 'With creosote and other chemicals affecting human health. Because of the variaoons in
the aquifers. they are being investigated and cleaned up as sepa..-.ne p::...'1S of the overall cleanup
The proposed cleanup plan was evaluated for its abiliry to prot.e(:t human healLl1; comp!y \I,i:r, e:l-
vironmental regularions; prevent the spread of the contamination; and reduce the to:ojcity. mob:~-
ifY. imct voll.lme- (If th.'" r0~'~mi!'~~;1..S. The' E?A" a.nd ?v1PCA also CO!1si~~d L~e p!::..'~'s lcn,;-te:-:r.
effectiveness. its cost effectiveness, and its teduucaJ feasibiliry.
the public's comments on the proposed plan before finalizing iL
The agencies will aJso conside;
Copies of the investigation report and the feasibiliry srudy of this remedy are avaj1ab1e at the 51.
Louis Park Community Library, 32~ Library Lane, SL Louis Park, for review by area residems
d~r:~g the co~m~~t ~rioi L'"l!:re~~d ~si~~u: are 2!£c i~'.~!~d to co~me!"l! c!"! !h~ prop0~~d
cleanup plan during the public meeting or during the public comment period. ending June 1.
Comments may be addressed to:
Ralph Pribble
Minnesota Pollution Conrrol Agency
520 Lafayette Road
St Paul, MN 55155
(612) 296-7792
###
-------
.,
The Minnesota Pollution
Control Agency (MPCA)
and tile
U.S. Environmental
Protection Ag.ency (EPA,'
invite public comment
on a proposed remedy
for the Reilly rar and Chemical site,
Sl Louis P.~ Minn.
The MPCA and EPA are S""'~<9 publiC commer'll
during the oenod from May , 1!"'~ug.~ June 1. 1990.
on a proposed remedy (cl88nup I'./&nl lor one of ltIe
Operable UntlS 01 ltIe Superfund cleanup altne s"e
01 operibons 01 ,"e lormer Reilly Tar ind Chemical
Company in 51. Lou.s Park, Minn. The pi oPOSed
plan dealS WIlli COnllmlnil'on in tne 51. Peter aQui.
fer resulting Irom Illose operations. The clelnup 01
tnis IQUller compnses one 01 1118 operable unitS in
!tie overall cleanup 01 Illis Sill. Otner operable
units are ,n vanous slages of inveSI'glhon Ind
cteanup.
The MPCA and EPA propose 10 pump oultne con.
1a~!K ground waler in tile 51. Peter ac:uller
I:'1nel:1l !:'Ie F\alHy srte lna dlscnlrge ilillrougn Ine
saMary 5Iwlr Sysllm to tne Metropolitln Wasle
Control CommiSSion's (MWCC1 ma,n Ir881menl la.
Clirty lor trllimenl. A COPy 01 III'S propo5ld reme-
dy. along w"11 OIlier documents relat,ng 10 Ille sill.
is available tor puDlic rev..w 81 tile 51. Louis Park
Community lIbrlry, 3240 library una, St. louIs
Park.
This proposal lias been evaluated for its ability to'
~ IIumar. r.e.ann; comply willi env"on~nlll
regulations. preve"-' !~'8 sptead 01 1118 conr.mina.
ticn; and reduce the 'tOJuc.aty. mc~ulty. an:: vOl'..;~e
of tntI contam'nants. The MPCA illS 11$0 consoO-
Ired 1tI8 8ff8Chveness. cost Itfectjveness. Ind
tlChnic:a1 flaslbliity. Aftar tne puDlic commenl pe".
00. tII8 MPCA will 1150 consider 1tI8 plan'S accepl-
ability 10 tne publiC.
Interlsted parties are .nvitacl to commenl on III'S
prOPOsal e'1II8r 81 a public m..,.,,; 10 be IIeld May
1111':.7:30 p.m. in"" first-lloor communIty room 01
11'18 Sl Louis Park City Offices. 5005 M,nnetonkl
BMI., SlLouis Park, or ,n writing 10: .
Rllpll Pribbl.
MPCA Public Information Office
520 ufl,lne Road
Sl Plul, MN 55155
(612) 296.7792
The propoltcl remedy is ope" for public comment
. ItIrougnJllnt1, 1990. '
..
-,
".t"o
C"
,.
, .
-
'"
..
c.
n:
.~,
,-
o.
..
0,
. ,
ATIA::-i:1.E:';7 # 3
s 1M T"'~2,
r- /J-i. /'7;(\
. .: 1'0
.... --,
-------
A"!T ACH1'1ENT it 4
@
1\letropolitan \"aste Control Commission
~e3rs Park Centre. 230 East Fifth Street. $1. P:1ul. ~innesot.1 55101
612 222-8423
December 8, 1989
~~~~~~[Q)
JUL 3 O. 90
City of St. Louis Park
5005 Minnetonka Boulevard
St. Louis Park, MN 55416
jll.::>CA. GroU!1d Water
t- ~:::'~~ ':h::ste Div. r:rrr n; q. I.rlll, P:'R:':
Ii f IJ , I V E D
DEC 1 3 1989
RE:
Industrial Discharge Permit (Special Discharges) Number 2045
For Site located at Oxford Street (east of Edgewood ~venue)
St. Louis Park, MN 55416
Attn:
James Grube
TRANSMITTED HEREWITH is the Industrial Discharge Permit eSpecial Discharges)
for the above referenced site. This Permit has been issued by the
Metropolitan Waste Control Commission for the period specified, and it
supersedes any temporary or draft permit or approval which may exist. The
discharge of landfill leachate, contaminated groundwater or special
indust=ial waste into the Metropolitan Disposal System is hereby allowed,
subject to any and all provisions of the Waste Discharge Rules for the
Metropolitan Disposal System, and ~~is Permit.
THE PERMIT contains Discharge Limitations, Monitoring and Reporting
Requirements, Special Conditions reqarding connected and nonconnected sites,
General Permit Conditions, and Specific Permit Conditions. Any failure to
submit the required Special Discharge Reports is a violation of this Permit.
The Permit'Number shall be included on all correspondence regarding this
Permit. The Spill Location Code shall be included when reporting a spill or
a slug discharge.
THE PERMITTEE is re~nded that renewal of this Permit is not automatic.
Permittee mu.t apply for renewal at least 90 days prior to the Permit
expiration date. If questions arise, contact Lynn Holly at 772-7286.
The
Sincerely,
~/I-~
Leo B. Hermes, P.E.
Industrial Waste Manaqer
MWCC Industrial Waste Division
LHH:pf
2045final
-------
Page
1
of
9
Permit No.
2045
Spill Location Code
MP-~W-O 1-5L .
METROPOLITAN WASTE CONTROL COMMISSION
(MWCC)
INDUSTRIAL DISCHARGE PERMIT
SPECIAL DrSCgARGES
Pu~suant to the provisions of Minnesota Statutes Chapter 473 as
amended, the Waste Discharge Rules for the Metropolitan Disposal
System (Minnesota Rules S~ 5~OO.1600 - 5900.7500), and the MWCC
Leachate and Contaminated GroUfldwater Program, permission is hereby
granted to
City of St. Louis Park
5005 Minnetonka Boulevard
St. Louis Park, MN
55416
for the discharge of
contaminated qroundwater:
W410, W422
into the
Metropolitan Disposal System (MDS) at
Oxford Street
east of Edqewood Avenue, St. Louis Park
This Industria~ Discharge Permit is granted in accordance with the
application tiled on
August 31
, 19!i-, and Permit fees of
$
180.00
received.
Discharge Limitations; Monitoring and Reporting Requirements; Special
Conditions regarding connected and nonconnected sites: and Permit
Conditions are contained in following sections of this Permit.
Effective Date:
December 8
, 19 89
Expiration Date: W4l0-December 31, 1992.
W422-January 31, 1991.
Issued by the Metropolitan Waste Control Commission
,
Donald R. Madore
Director of Quality Control
1"2.~
ate
Chief Administrator
or duly authorized representative
-------
Pag~
2
of
9
Permit No.
2045
S9ill Location Code
~?-NW-01-3:
A.
Di5c~ar~e ~imitatio~5
1.
Local
Limi':.ati~:15:
Parameter
MWC: Local
Li:r.i:3.:i::-:
Cadmium (Cd)
2.0 mg/l
Chromi~m - total (C=)
3.0 mg/l
CO~ger (Cu)
6.0 mg/l
Cyanide -
t:>tal
(C~ J-
4.0 mg/1
1.0 mg/1
Lead (Pb)
Merc'..1ry (ag)
0.1 mg/1
6.0 mg/l
Nickel (Ni)
Zinc (Zn)
8.0 m;/l
maximum
10.0 pH
u:;i:s
pH -
p3 -
mi n i~'~:r.
5.0 pH
u~i~;
MWCC local limitations for metals and CN are the maximum far
any operating day.
pH li~ltations are instantaneous val~es.
2 .
Additional Limitations:
The following maximum dail; limits apply to leachate and co~-
taminated groundwater discharges:
Conceritration of anyone toxic organic parameter
3 rr.;/ l.
Combined total toxic crganics pa~ameter concentrations
10 rr.;/l
Total Hydro:arbons (for petroleum-related discharges)
100 mg/l
Additional Special Limits:
Param~ter
Individual PAH
3 mc/I
- ~
Total PAH
10 mg/l
-------
B.
Pag~
3
of
9
P~rmit No.
2045
S~ill
Lo~atior: C~d~
~? - ~ii-: - 0 :. - S":.
.- METROPOLITAN WASTE CONTROL CQM."115SION
3 .
Prohibited Was~~ Dis~har~es:
Prohibit~d
Discja:;~s are described in Sec~ion S98C.45C~
';
-------
Page
4
0:
9
Permit: No.
2("\ .:::
.... .. J
Spill Location Code
~P-N~-i)l-S:'
METRC'?OL:TA~
~ASTE
CONTROL CO~~ISSION
following para~e~:rs:
cH, TSS, COD, PAH, ?he~~l:
3 .
Re~o=~ing Re~~i:e=e~~s
a)
Schedule:
The Permi~tee is required to submit Special Discharge
Reports to the W~CC four times per year according to t~e
following sc~ed~le:
Reportin~ Period
Reoort Due Date
January 1 - ~a=ch 31
April 1 - June 30
July 1 - Septem~er 30
October 1 - ~ecember 31
.~pril 30
July 30
OCtober 30
January 30
Reports shall be submitted each quarter until this
pe=:Tti~
" has been terminated, whether or not a discharge has
occurred during a given quar~er.
b)
Report Contents:
~ completed report consists of an MWCC Special Discharge
Report form and a copy of the laboratory data sheets for
all samples collected for this discharge during the
reporting period.
The total discharge volume for the
reporting period shall be reported, as well. as the
-------
Page
5
of
9
Permit No.
2045
Spill Loca~ion Cede
~P-~W-0:'-3':
METROPOL:TA~ WASTE CONTROL CO~~ISSION
cumulative total vol~~e discharged under this ?e:rnit.
Other per~ine~~ infor~ation shall also be i~c~uded, s~~~
as operational problems and cha~ges, etc.
The siq:;a':.~:e
of the responsible party or a designated a~thorized
representative shall appear at the bottom of the form.
C.
Soecial Cc~di~i~ns for Qi5~ha:qe Sites Not Connected to the
Sani tary Se~'e=
1.
Discharge Location
Permitted discharges for
sites
not connected to the sanitarv
. .
sewer must be transported by an MWCC Permitted Liquid Waste
Hauler to the Third and Commercial Disposal Si~e in St. Pa~:'.
2.
Load Charqe
~ransported discharges will be subject to a Load Charge whi=~
includes a volume charqe and a streng~h char;e (based on
analytical results).
The volume component is based on the
volume rate that the MWCC charges each co~~unity serve~.
strength component is derived from the same equation used t~
T:-:-=
calc~late.Strength Charges for industrial users that are
connected to the MDS, and is based on volume, a Chemical
Oxygen Demand concentration in excess of 500 milligrams per
liter emg/l) and a Total Suspended Solids concentration in
excess of 250 mg/l.
,.'
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Page
6
of
9
Permit No.
2045
Spill Location Code
MP-NW-Ol-~
METROPOLITAN WASTE CONTROL COMMISSION
D.
Soecial Conditions for Discharge Sites Connected to the Sanitary
Sewer
E.
1.
Connection Approval
Connections made to local sewers or Commission interceptors
shall require approval from the a~propriate authority prior
to connection.
Eilling for sewer use shall also be arrange~
with the community.
2.
Volume Measurement
The Permittee shall install and ~4intain an appropriate
discharge metering device.
3 .
Service Availability Charge (SAC)
Permitted sites that are connected to the sanitary sewe~ will
be subject to SAC if the discharge exceeds three years dura-
tion, effective February, 1988.
Therefore, S~C payment for
W422 January 31, 1991
W410 December 31, 1992.
th~s site will be required on or before
General Permit Conditions
1.
All discharges into the MDS shall be in accordance with ap~lic-
able provisions of the Waste Discharge Rules for the MDS, the
MWCC Leachate and Contaminated Groundwater Program, and this
Permit.
2.
The Permittee shall not knowingly make any false statement,
representation or certification in any record or report
required to be submitted to the MWCC.
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Page
7
of
9
Permit No.
2045
Spill Location Code
MP-NW-Ol-SL
METROPOLITAN WASTE CONTROL COMMISSION
3 .
This Permit shall not release the Permittee from any lia-
bility, duty or penalty imposed by Minnesota or Federal
statutes or regulations, or any local ordinances or regulations.
4.
The Permittee shall take all reasonable precautions to mini-
mize all accidental dis=harges including slugs, s9ills and
bypasses. In ~he even~ of any accidental discharges, spills
or bypasses whose quantity and nature might reasonably be
judged to constitute a ~azard to the Commission's ~ersonnel
and treatment facilities or the environment, the Permittee
shall IMMEDIATELY notify the Industrial Waste Division of the
MWCC a~ 772-7109 (office hours) or 681-4511 (non-office hour!
a~~ report the site location, the spill location code, and
other pertinent informa~ion.
5.
The Permittee shall report any change in the proposed
dls<;harge plan, including changes in pretreatment system
design or rate of discharge.
The Permittee shall also notify
the MWCC within 48 hours if the system is temporarily or per-
man.n~ly discontinued.
6.
The Permittee shall pay applicable Strength Charges or Load
Charges assessed by the Commission.
7.
The Permittee shall allow MWCC personnel to enter upon the
Permittee's premises to inspect the system and discharge point
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Page
8
of
9
Permit No.
2045
Spill Location Code
MP-NW-Ol-~L
METROPOLITAN WASTE CONTROL COMMISSION
or sample the discharge ir order to verify the reports
received and determine co~~liance with the Waste Discharge
Rules for the MDS and thi= Permit in accordance with ~~ ~
5900.3100.
"
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F .
Page
9
_2-
of
----
Permit No. --lQi2_-
Spill Location Code
MP-NW-Q}-
-----'-:"----
METROPOLITAN WAS7E CONTROL COMMISSION
~£~£ifi£-f~~i!_f~~~i!i~~
1.
Representative samples may be collected once per reporting
period during a 'normal discharge day in lieu of monthly
sampling.
2.
PAH Limitations are applicable at individual well discharges.
3.
Service Availability Charge requirements must be satisfied
if the Permittee intends to discharge beyond the expiration
date of this Permit.
4.
One sample per quarte~ shall be analyzed for pH, Chemical
Oxygen Demand (COD) and Total Suspended Solids (TSS). A
Permittee may reduce their reporting frequency of COD and TSS
to once per year if the following conditions are met:
After an Industrial Discharge Permit issuance, four con-
secutive routine self-monitoring reports must exhibit a
TSS of 125 mg/l or less and a COD of 250 mg/l or less
(50' of the Strength Charge limits).
The Permittee must have no history of Strength Charge
this system.
m
The Permittee must formally apply for this reduced
reporting requirement through a letter illustrating the
above points.
The Industrial Waste Division reserves the right to revoke
.th~s authorization for reduced reporting requirements.
5.
The laboratory reports for !ll wastewater monitoring conducted
during' each reporting period (at the point of discharge to the
sanitary sewer) shall be submitted with the Special Discharge
Report for that period. Reports must be submitted each
quarter until t~e permit is terminated.
Sample collection and analytical methods shall meet EPA
protocol (Code of Federal Regulations, Part 136).
6 .
This permit supersedes any MWCC approvals previously issued
for this site.
7.
This discharge approval is not exclusive. The approval does
not release the Permittee from conditions set by the Minnesota
Pollution Control Agency, Minnesota Department of Health,
Minnesota Department of Natural Resources, and the City of
St. Louis Park.
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f"\J. .../"\_."'1...'0.;....,.
--
'.-,
Page 1 of 31
Per~it No: HN 00298:5
A~~ORIZA7ION TO DISC~~GE AND TO CONSTRUCT ~ASTE~ATER TREATHE~IT FAC:~ITI~S
UNDER TEE NATIONAL POLLUT~NT DISCHARGE ELIMINATION SYSTEM
AND STATE DISPOSAL SYSTEM PERMIT PROGRAM
In compliance vith the provisions of the Clean Vater Act, as amended, (33 U.S.C.
1251 et seq; hereinafter the "Act"), Minnesota Statutes Chapters 115 a.r.d 116, as
amended, and Minnesota Rules Chapter 7001
THE ~£IROPOLIT}.~ VASTE CONTROL COMMISSION AND THE
METROPOLii:r.l~ COUNCIL (BLUlNAFTER "JOIN1' PERMITTEE")
are authori%ed by the Minnesota Pollution Control Agency (MPCA), to constru~t
vastevater treatment facilities and/or to discharge from the Metropolitan
~aste~ater Treatment Facility (Metro Plant), located in the E~ of the SE~ of
Se~tion 9, T 28 N, R 22 V, Ramsey County and from the bypass points listed
herein to receiving vater named the Mississippi River, in accordance vith .
effluent limitations, monitoring requirements and other conditions set forth in
PAR:S I, II and III hereof.
"
The Metropolitan Vaste Control Commission (hereinafter "Commission") and the
!'!etropolitan Council (hereinafter "Council") shall be jointly and severally
liable for compliance vith tne terms and conditions of this permit except the
Metropolitan council shall be liable only to the extent of its statuto~; or
regulatory authority over the activities necessary for compliance with this
permit.
This permit is a reissuance of an existing permit which has an
of midnight, June 30, 1987. This reissued permit shall become
date of issuance by the Agency Commissioner and vi11 supersede
permit upon issuanc.e.
expiration date
effective on the
the existing
This permit and the authorization to discharge shall expire at midnight, May 31,
1995. The Joint Permittee is not authorized to discharge after the above date
of expiration. In order to receive authorization to discharge beyond the above
date of expiration, the Joint Permittee shall submit such information and forms
as are required by the Agency no later than 180 days prior to the above date of
:::::.tiO:'::::-::~ ::9:innesot& Rules P.rt ~~~
Direc tor
Division of Vater Quality
"
For:
Gerald L. Villet
Commissioner
Minnesota Pollution Control Agency
-------
Page 2 cf::
Pe~;t No:
~':i OOZge::
E,
~::_:."!::-: L~!:AI~=~IS
D~:~~g the period beginning on the ef:ec:ive d~ce or t~is Pe~it ~ne l~s:~~g until ~~y 31,
:995, t~e ;oint ?e~1t:ee is ~u~ori%ed to dis~,~:ge ::0111 ou::ali nu=be: 010,
S~ch d~sc~arge shall be licited by the Joir.t ?e~i::ee ~s specified below, (Note: A dis~'~:ge
flov 0 f .31Z. ege vas used for calcula t:.::.g can li::i cations as ~ lIIon ~ly ave:a~, r: c:e
~ississippi Rive: flov is less than 5,000 c~:ic feet per second (c:s) as. a lIIont:.ly average a:
Robert St~eet, m~ss licitations vere calc~latee ~s~~g ~ discha:ge flow 0: 25: :ge,)
~:::~e~: ~a:ac:eristics
Con:inuous Discha:~e Li:i:at:~~s
Calendar ~ont~ Ave:a~e
~
5-~ay CarbonaceouS Biocbeoical
Oxygen De:ar:d (C30D 5)
l~ IIIg/l (16,617 kg/day)
Applicable du:~g t:e :cn:h 0:
June i; lIIon~,ly average =ive:
flow is >',000 cis.
Applicable dU~~i ~e cc~th 0:
J~~e i; lIIont:ly average ::ve~
now u ~,OOO cis.
110. eg/1 (13,:93 kg/day)
10 =K/l (11,869 kg/day)
Appl1cab1e mQ July
Septe=ber if contbly
river flov is >5,000
t:.~~ug!1
average
cis.
10 =;/1 (9,488 kg/cay)
Applicable fr:= July t~~ough
Septe=ber if :or.~,ly average
river flow is ~,OOO cis.
- '
2Z. mg/l (18,Z.86 kg/day)
85~ Re=oval
Applicable frolll October
cnrcugb I".ay
:otal Suspended Solids (ISS)
.30 mc/l (.35,608 kg/day)
85'\ nmoval
Fecal Coliform Grcup Or~isms
200 organis=s/lOO =1 (geoce~ic =aan) AppliC&ble frc= ~~ 1 -
October 31
".
13 l1li/1 (U,3JZ. q/day)
Applicable dur~~g tbe month 0:
Hay if monthly average river
flow is >5,000 cis.
Applicable ~.ng tbe =ont~ or
May 1f monthly average river
flow is SS,OOO cis.
1.3 l1li/1 (1.5,1030 ki/day)
A::on~a-Sitrosen
8.0 l1li/1 (7,590 ka/day)
Applicable dur'.nC :he mont~ of
June if monely averace r1.ver
flow is >5,000 c:s.
Applicable dur1DC the .onc~ of
JUDe if manchly averace river
flow is SS t 000 ds.
8.0 =e/l (9,495 ki/day)
5.0 ../1 (S,935 ki/day)
Applicable from July chroucn
Sepcember if 80nchly average
river flow is >5,000 ~fs.
.,
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~:::~e~: ~a~aC:e~:5::C5
p=~: : of 21
Permi: No: M~ 002981S
C~le~c.~ ~e~~ Ave~at~
No:es
5:.:c:: d~sc:Ja.rge shall be l~io:ed by o:."le Jo:.."1O: Pe:-::iuee n specified below. (Note: A d~sc!:U'ge flow 0:
~o g:'eace~ ti\.an 339 CI;d 'In used fo~ calc~:acir.g Class l1.::io:ac:.ons as a week.ly Ive:'age. I! t:e
~~ssiss~:;Jpi ~ver flow is less t.C.an 5,000 cubic feee pc:' second (cfs) IS a :Donthly average (or \/eekly
avenge IS appropriao:e), at Rober: 5l:eeo:, IIIiISS li.::io:ations we~ calculated using a disc:arge flow 0:
:".0 g:-eacer U:..iIn 251 ::2!!;c.)
:-~ay Ca=~o:".aceous Bioche=ical
Oxyge~ De=and (C3C~5)
:otal Sus~e~ded Sol:~s
~issolved ~!ge~
A:::onia N1:=clen
21 =g/l (26,909 kg/day)
Applicable dU:'~g ::Je C!on~ 0:
June.
Applicable 1£ weekly average
river flov in June is
~,OOO cf~.
Appl1ca~le fro= July through
Septe=ber.
Applicable July o::rough
5ept~ber 1£ =on~ly ave:'~ge
river flow is ~,OOO cfs.
Applicable from Oc:ober
through May.
l: =Sfl (19,92~ kg/day)
~ 1113/: (19,::: kg/day)
1.5 =&/1 (1~,:~1 kg/day)
~o cg/l (51,2Si kg/day)
4S =ill (57,S6~ k&/~ay)
7.0 ::g/l
~eekly average co~cent:'a:~on. *'
Applicable f=o= J~e 1 -
5ept~~er 30 whe~ :'equired
under PA.IU: !,C.J
1.3 1113/1 (lS,~30 q/day)
Applicable duri.::g the =ont~ of
Hay.
Applicable if =ont:ly average
Tiver flow i: ~ is ~,OOO c:s.
13 111/1 (1.2,33lo ka/day}
1.2 11;/1 (U,500 k;/c1ay)
Applicable du~-=g che con:: 0:
J W'le .
Applicable 1: mont:ly average
river flev in Jur.e is ~,OOO cfs.
1.2 =;/1 (9,~95 kg/day)
7.5 =sll (9,611 ka/c1ay)
Applicable frolll July cnrolJii:1
Selltuber.
Applicable July throush
September if =oc~ly average
river flev is ~,OOO c:s.
7.5 =sll (10,7101. q/day)
1.3.5 =s/l (17,299 k;/c1ay)
Applicable
Octcber.
Applicable
river flev
durinl thl IIIO:t~ of
9.0 =1/1 (8,539 ka/day)
if 8Cllthly average
111 Oce. is ~, JOO c~s.
31.5 =sll (~,365 kg/c1ay)
AlIp l1cab 1 e
November.
Applicable
rtver flow
c1uriAl the con:h of
21 =1/1 (19,9210 kg/c1ay)
if =onthly Iverage
in /fov. i~ ~ 000 c~s.
rw For aver~ging periods of less tnan leVln days, Che weekly ~verage
. . - - .. "" Q ., '.".,.. , :: ~ . 0, d a'!. !. v va l'.le! .
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PAKi I
pase i of 21
Pe ri71it No:
MN 0029215
C.
SPECIAL REOUIREMENiS
1.
Syoass/Overflow Authorization
.'
As approved by the Corrrnissioner, in conrormance with app1icajie
Agency guidelines for system reliability, and in accordance w;t~
PART II, A.2. of this permit. the Corrrnission is authorized to
discnarge from emergency bypass points, outfall serial numcers
020, 030, 040, 060, 070 and 080.
The Commission shall, in accordance with PART II, A.I. of t'1is
permit. report in the remarks section or the Monthly Operat~on
Repor:, each eme~gency bypass event, the corresponding oU:~:lll
number, its duration, t:ie estimated volume, and estima:ed
concentrations for CBOD;, TSS, total phosphorus and ammonia based
on sampling of locations which are representative of the bypass.
Total Residual Chlorine
2.
If the daily total residual chlorine sample exceeds 0.1 mg/l, the
Commission shall immediately investigate the cause, take
appropriate remedial action and report the action and results on
the monthly discharge monitoring report. If the Mississippi
River elevation at Robert Street exceeds 697.5 feet. to protect
the integrity of the facility, the dechlorination facilities may
be removed from service. During these periods, the total
residual chlorine effluent limitation in PART I, B. and the f~rst
sentence in PART It C.2. shai1 not apply. The occurrence of such
an event sha 11 be reported to the Agency COlm1i ss i one!" as requ: red
by" PART II. A.l. and described in the monthly discharge
monitoring report.
Dissolved Oxyqen
~ .
3.
The effluent shall comply with the effluent limitation for
dissolved oxygen identified in PART 1, 8.1 when daily average
dissolved oxygen concentrations below discharge 010 are less than
5.5 1119/1 for two consecutive sample-days or when daily average
dissolved oxygen concentrations above discharge 010 are less than
6.0 mg/l for two consecutive sample-days. Dissolved oxygen
measurements in the river shall be evaluated within 12 hours
after each day's monitoring to determine when aeration of the
effluent will be required. When continuous river monitors are
used to determine compliance with this condition, measurements at
UM 826.6 and UM 831 shall be used to evaluate downstream
dissolved oxygen concentrations .and measurements at 'UM 836.8
shall be used to evaluate upstream dissolved oxygen
concentrations. This requirement shall only apply when da; 1y
average river flows' of 7,000 cubic feet per second or less oc~ur
for two consecutive days as measured by the U.S.G.S. Gauglng
Station at St. Paul.
-------
P.:o,?i I
p:~e 9 of 31
Permit No:
MN 002981:
is,i~adequate and specifies the basis for ~~e inadequacy ;~
wrlt,ng. If th.e A~encl Commi~s~,c:!er finds that the plan ;$
inadequate, the Ccrrrnission shan, ",ithin lS days of
receiving written notificatior1 of the plan's inadequac:I,
submit to the Agency Ccrrrnissioner a pian tt,ct has be:!"1
revised to correct the inadeGuacies. Within 30 days of
receivin; written ~9proval from the Agency Co~iss;one;, the
COrnill;ssion snall COffioence testing.
-
Procedural, requirements for toxicity testing shall be in
conformance with the following manuals and listed
exceptions:
i. Tests shall be conducted in aceo;:ance with proce~ures
outlined in E?A-5aO/4-aS-Q~3 ~Methcds for Measurina the
Acute Toxicity of Effluents to Aquat~c Cirsa:1isms"
(Acute Manual) and EPA-600/4-85-014 "Short-Term Methods
for Estimating the Chronic Toxicity of Effluents and
Receiving Waters to Freshwater Organisms" (Chronic
Manual) and any revisions to the manuals.
v.
Test oraanisms shall include the fathead minncw
(Pime!:)nafes ~rome1as), and Ceriodaohnia du~ia far
cnron,c testing. Acute tests sha 11 employ' "the fathead
minnow, Ceriodaonnia dubia, and Daohnia ma~:'\2.
Fathead minnows used in acute testing snail-oe--a
minimum 15 days of age post-hatch. .
Acute s.erial dilution testing of the effluent shall
consist 0' a control (dilution water) and four
treatment levels (100, 50, 25, and 12 percent
effluent). An abbr!viated chronic test shall consist
'of a control, 100 percent effluent, and effi'Jen~
diluted to the Instream Waste Concentration (HiC of
24 percent. Winter acute testS may be conduc:.::d at
temperatures as low as 100e (See b. below) provided
statistically significant test results can be obtained.
All samole collection of the effluent shall be by ~'ow
proportioned 24 hour composites with test solu~ions
renewed daily from each fresh composite. Testin; of
the effluent sh~ll b!gin within 36 hours of the
completion of sample collection.
Any other ci rcumstances not covered by these Man;.a 1 s.
and 1 isted exceptions or that require deviation from
that which ;s specified in the Manuals and listed
exceptions shall first be approved by the commissioner.
Toxicitv Test FreQuencies and Re~ort Submittals
, i .
iii.
"
iv.
b.
Abbrevi ated chroni c tests sha 11 be conducted 3 times per
year for 3 years during the months of May, July, and
October. Thereafter, annual chronic tests (Augus~ :!1iy)
~--..;,...-~,...:
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P.c..RT I
Page 11 of 31
Permit No: MN 0029815
The Corrm;ssion shall make reasonable progress toward comeliance
with the LTWQBE~ during the term of this permit by completing Part
I"C.7 and Note (7) to Part I,D.4. of this permit.
7.
Mercurv, PCS and Pesticide Investioation Plan
a.
The Corranission shall investigate potential sources of
mercury, PCBs and the pesticides Chlordane, Heptachlor,
Endrin, Dieldrin and Alpha-SHC within the sewage colle~t'!on
system in accordance with the following schedule:
i .
Submit a report which 7ncludes the May
resu!ts of a seven-day dry weather mercury,
PC3s/pest;c;Q~S survey; a one to two day
wet we~ther mer:ury, pcas/pesticides survey;
and monitoring program of three Minneapolis
interceptors. The wet weather survey shall
attempt to assess the effects of first flush.
31, lS~l
Submit a report which includes the
conclusions obtained from monitoring
nine additional interceptors for
mercury, PCBs/pesticides. ,.
iii. Submit a report identifying point
sources (if found) and the monitoring
required of industrial users.
December 31, 1991
i i .
December 31, 1992
"-
'.
Submit a complete evaluation and
Remedial Action Plan if applicable.
v. .Implement Remedial Action Plan as
approved by the Agency Commissioner.
September 30, 1993
i v.
",
December 31, 1993
b.
The Commission shall co11 ect sampl es of suspended sediment
from traps in the effluent channel and analyze the samples
for mercury, PCB's and pesticides (Chlordane, Heptachlor,
Endrin, Dieldrin and Alpha-SHC). Four consecutive 3-month
samples shall be taken in the first two years of the permit.
The resul ts shall be reported to the Agency Conmissioner
within 90 days of the completion of testing.
The Conmission shall conduct one 30-day in-situ
bioaccumJation test of carp and fatheads with Metro effluent
for mercury. PCBs and pesticides (Chlordane, Heptachlor,
Endrin, Dieldrin and Alpha - SHC). The test shall be
conducted within the first 2 years of the p~nnit. . T~e .
results shall be reported to the Agency Commiss1oner wlthln
90 days of the completion of tes~ing.
c.
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PAR,;" !
Page 13 of 3:
Per.nit no: ".1:/ OC29815
ii.
for the 2nd quarter of 1950) are requi red for phosphorus re!iiova 1
or in the event the river study indicates to the Agency that a
phosphorus 1 imi t other than 1 mg/l (month 1 y average on a
year-round basis) is needed to meet applicable water quality
s "andards, the Agency, duri ng the peri od January 1, 1993, to
May 31, 1993, shall place on public notice a draft per;nit
modification or reissuance to consider the phosphorus limitation
and/or the final compliance deadline set forth beJow and, in
response to a timely he~ring request by the joint per;n;ttees or
the State of Wisconsin, the Commissioner shall recomme~d that the
Agency Board order a contested case hearing to consider the
phosphorus limit, the capital expenditures necessary for
compliance with the phosphorus limit, and the final compliance
de~dline. An interim phosphorus limitation may also be
established pursuant to this paragraph.
In conjunction with Part I .C.B.c. i.. the joint permittees :::ay
apply for a variance from the provisions of Minn. Rules. Pcrt
iOSO.0211. Subpart 1 relating to phosphorus removal. The request
for a variance shall be made in accordance with Minn. Rules. Part
iOOO.0700 and other applicable rules of the agency.
Unless a different phosphorus limitation or a schedule of
compliance is established according to the paragraphs above, a
phosphorus limitation of 1 milligram per liter as a monthly
average on a year round basis shall be applicable for the
discharge from outfall-Ol0 in accordance with paragraphs'iv. or v.
below. If during the pUblic notice process conducted pursuant to
Part I.C.S.c.i., above, a contested case hearing is requested and
granted, the phosphorus limitation and the final compliance
deadl ine shall not become effective until the conclusion of the
hearing process and a final decision is made by the agency.. The
agency and the U.S. Envi ronmenta} Pro~ection Agency acJcnowl edge
that the anti-backsliding provisions of Section 402(0) of the
Federal Clean Water Act and the regulations promulgated thereunder
will not be applied to a revision of the phosphorus limitation
made in accordance with the provisions of this paragraph.
In the event the treatment plant study indicates capita 1
expenditures less than 510 million (adjusted to an ENR index for
the second quarter of 1990) are required for phosphorus removal.
design contracts to achieve the limitation established above shall
be awarded by October 31, 1993, and a notice to proceed with
construction shall be issued by December 31, 1994 50 that
comp 1 i anc! wi th the 1 imi ta ti.on can be ach i eved by December 31.
1995 unless a'different final compliance date is established
during reissuance or modification of this permit.
In the event the treatment plant study indicates ca~ita 1
expenditures greater than $10 million (adjusted to an ENR 1ndex
for the second quarter of 1990) are requi red for phosphorus
removal, design contracts to achieve the limitation establis~ed
above sha 11 be awarded by December 31, 1993 and construct' on
contracts shall be awarded by May 31. 1995, so that compliance
with the limitation can be achieved according to a schedule
established during reissuance or modification of this permi~~ .
By December 31, 1994, submi t progress report on acn 1 e'.J1 ng
..._--~ ~ ~...-~ "'~.I., -"'-0 '.""'::1' ::a';':'"a,..- , ~r-~" .;,.-.,- 1jhO~!jhr"r'~<:.
i i i.
iv.
v.
vi.
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F.e-.RT I
Pace 11: c': ~;
Pe;';it~ NO~ ~MII 002S21:
. -..
1 )
2 )
3 )
4)
5)
The exact place. data. and time of sampling;
the dates the analyses were performed;
the person who performed the analyses;
the analytical techniques, procedures or methods uSed;
and
the results of such analyses.
e.
Additional Monitorinc bv Commission
If the Commission ~onitors any designated pollutant or
parameter mDre frequent1y than is required herein, the results of
such monitoring shall be included in the calculation and reporting
of values submit~ed on the Discnarge Monitoring Report.
If the Ccmu.ission performs any special monitoring or studies or
routine monitoring not designated herein on the ;nfluen~,
effluent, sludge, or on the receiving water, the results of such
monitoring or studies shall be provided to the Agency Co~issioner
upon request.
f.
Recordinc and Re~ords Retention
2.
All sampling and analytical records required by this permit shall
be retained by the Commission for a minimum of three (3) years.
The Commission shall also retain all original recordings from any
continuous monitoring instrumentation, and any calibration and
maintenance records, for a minimum of three (3) years. These
retention periods shai1 be automatically extended during the
course of any legal or acministrative proceedings or when so
"requested by the Regional Administrator, the Agency, or the
Agency Commissioner.
Monitorina Plan
The Commission shall submit a monitoring plan or monitoring plan
amendments to the Agency Commissioner for approval within ninety (90)
days after the date or issuance of this pl!rtnit. The monitoring plan
shall deal with all phases of the Commission's effluent and receiving
water monitoring activities required herein. Hew monitoring plans or
amendments to previous monitoring plans shall be submitted if changes
are to be made or if additional or different monitoring is required by
this permit. The monitoring plan shall include the items described in
Minnesota Rules 7001.1090 Subp. 1.
. Upon review of the monitoring plan the Agency Commissioner may require
changes or additions to that portion of the Conmission' s monitoring
program, including the quality assurance program, required by the
permi t.
~ --.
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PA,RT I
Page 17 or 31
Permit No: MN 0029815
4. Monitorino Recuiremen:s - Class A ~as:ewate~ Treatment Facility -
Major Olsc~aroe~
Cetermi na ti on Frecuency Same I e Tvee ~
.
Influent flow Ca i I y Continuous
Effluent fecal colifo~ Daily Grab ( 2)
Effluent dissolved oxygen Da il y Grab (1)
Receivina stream dissolved oxygen (6)
Chlorine-residual Ca i 1 y Grab ( 3 )
Chlorine used Da ily (3)
Infl uent pH Da i1 y Continuous
Effluent pI-! Da ily Grab
Influent C30DS Da i 1 y 24 hour composite
Effluent CBOD Da i 1 Y 24 hour composite
: CBOD~ remcv~l Da ily
Influent total suspended solids Da i 1 y 24 hour composite
Effluent total suspended solids Da i 1 y 24 hour composite
: Total suspended solids removal Da il y
Sulfur dioxide used Da il y (4)
Influent ammonia-nitrogen Da i ly 24 hour composite
- Efflue~t ammonia-nitrogen Da i 1 y 24 hour composite
Influent total cadmium 3 X Weekly 24 hour composite
Effluent total cadmium 3 X Weekly 24 hour composite
Influent total copper 3 X We~kly 24 hour composite
Effluent total copper 3 X Weekly 24 hour composite
Influent total cyanide 3 X. Weekly 24 hour composite
Effluent total cyanide 3 X Weekly 24 hour composite
Influent total mercury 3 X Weekly 24 hour composite (7)
Effluent total mercury 3 X Weekly 24 hour composite (7 )
Influent total chromium Wee k I y 24 hour composite
Effl uent-, tota I chromium Weekly 24 hour composite
Influent total';ead Weekly 24 hour composite
Effluent total lead Weekly 24 hour composite
Influent total nickel Weekly 24 hour composite
Effluent total nickel Weekly 24 hour composite
Influent total zinc Weekly 24 hour composite
Effluent total zinc Weekly 24 hour composite (7)
Influent PCBs aroclors Monthly 24 hour composite
Effluent PCBs aroclors Monthly 24 hour composite (7)
Influent total phenols Monthly Grab
Effluent total phenols Month I y Grab
Influent total arsenic Quarterly Grab (5)
Effluent total arsenic Quarterly Grab (5)
Influent total iron Quarter 1 y 24 hour composite
Effluent total iron Quarterly 24 hour composite
Influent total phosphorus Daily 24 hour compasite
Effluent total phosphorus Da i 1 y 24 hour composite
Influent dissolved phosphorus Daily 24 hour composite
Effluent dissolved phosphorus Daily 24 hour composite
Effluent Kjeldahl nitrogen Weekly 24 hour composite
Effluent nitrite-nitrogen Week1y 24 hour composite
Effluent nitrate-nitrogen Weekly 24 hour composite
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E.
PAR T I
Page 19 of 31
Permit No: MN 002~815
-
D~~INITIONS
1.
"Agency" means the Minnesota Pollution Control Agency, as constituted
pursuant to Minnesota Stat~test Section 115.02, S~cd. 1.
2.
"Agency Commissioneru r.:e~ns the Commissioner of the Minnesota
Pollution Control Agency as described in Minnesota Statutes, Se~tion
116.03. as amended.
3.
"Regi ana 1 Admini strator" means the U. S. Environmental Protection
Agency (E?A) Regional Administrator for the region in which Minnesota
is 1 oca ted (now Regi on V).
4.
"ActU means the Clean Water Act, as amended. 33 U.S.C. 1251, et seq.
c:
w.
"Composite" sample, for monitoring requirements, is defined as (a) a
series of grab samples c:Jl1cc:ed at least once per hour at equally
spaced time intervals and proportioned according to flow; or (b) grab
samples of equal volume collected at 'equally spaced intervals of
wastewa:er vaiume and collected not less than once per hour.
6.
"Calendar Month Averaae" other than for fecal coliform arouc
organisms. is defined ai the arithmetic mean of the samples coll~cte~
in a period of one calendar month. The calendar month average for
fecal coliform group organisms. is defined as the geometric mean of
samples collected in a period of one calendar month.
"Ca 1 endar Week Average" continuous di scharge 1 imi tations, other than
for fecal coliform group organisms, is defined as the arithmetic mean
. of the samples collected in a period of one calendar week.
".
7.
8.
"85 Pe~c:ent Remova1.u For the calendar month average, the effluent
conce~trat;Qns shall not exce!Q the stated value or 15 percent of the
arithmetic mean of the values for influent samples collected at
approximately the same time during the same period (mos': restrictive
values).
s.
"Acute Toxicity Serial Dilution Test" is a static renewal test
conducted on an exponentially diluted series of effluent (a control
and 100, 50 t 25 and 12 percent effl uents). Its purpose ~ s t~
calculate the percent of effluent that causes 50 percent morta11ty OT
the aquatic organisms tested in 96 hours for vertebrates and 48 hou~S
for invertebrates. Mortality greater than or equal to 50 pe~c~nt 1n
100 percent effluent constitutes a positive test for acute tOX1c1ty.
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P~se 21 of 21
Permit No: M~ 0029215
PART II
A.
MANAGEMENT REOUIREMENTS
1.
Non-Comoliance and Byoass Notification
If, for any reason, the Commission exce2ds any effluent limitation
specified in the permit, bypasses, or causes a diversion of wastewater
or unauthorized discharge in violation of this permit, the Co~ission
shall notify the Agency Commissioner as follows:
a.
TeleQhone Communication
Report immediately to the Regulatory Com~liance Section, Division
of Water. Quality (612) 296-8100 any bypass ..."ich may cause a
nuisance or health hazard and all unauthorized discharges,
accidental or otherwise, of oil, toxic pollutants, or other
hazardous wastes. The Commission shall immediately recover as
rapidly and thoroughly as possible such discharged substance(s)
and take such other action as may be reasonabl e to minimize or
abate pollution of the waters of the State. This must be
followed by a written explanation on the discharge monitoring
report.
b.
Pri or Aoprova 1
Bypassing which would result in the discharge of raw or
inadequately treated effluent is prohibited during routine
mai ntenance procedures. 1ft for any reason, a major trea tmen t
'ul1it must be bypassed for routine maintenance, and this bypass
will result in a degradation of the effluent, the Agency
Commiss"ioner (Attn: Operations/Training Unit, (612) Z96-i296)
must be notified and grant approval prior to removing this unit
fram service. In the case of emergency maintenance, the Agency
COIIIDissioner shall be informed of the circumstances surroun"ding
the need for emergency maintenance and the action taken.
Written Report
c.
Report on the Discharge Monitoring Report, any violation of daily
minimum, maximum, calendar week average, or calendar month
average effluent limitation and any bypass that did not present a
nuisance or health hazard.
ReQuired Information
Written notification required above shall contain the following
information:
(1) A description of the discharge, approximate volume, and
cause of non-compliance or bypass.
d.
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PART II
Page 23 of 3:
Permit No: MN 0029815
-
shall. be report~d to ~h~ ~genc~ Cor.rnissioner. (Attn: Regulatory
Comp11ance Sectlon, DlvlS10n OT Water Quality). Modification to
the permit ~a~ then. be m~de to refl ect any necessary change in
pennlt condltlons. lncludlng any necessary effluent limitations
for any pollutant not identified and limited herein.
d.
In no case are any new connections, increased flows. or
significant changes in influent quality permitted that will cause
violation of the effluent limitations specified herein.
5.
Sewer Extensions
In accordance with Minnesota Statutes Section 115.07 Subd. 3,
appl ication must be made, plans and specifications submitted, and a
permit obtained for any addition to or extension of a sanitary sewer
prior to the commencement of construction.
6.
Facilities Ooeration and Oualitv Control
All waste col1ection, control. trea.tment, and disposal facilities
shall be operated in a manner consistent with the following: -.
. a.
Maintenance of the treatment facility that results in degradation
of effluent quality and/or wastewater sludge shall be scheduled
as much as possible during non-critical water quality periods and
shall be carried out in a manner approved by the Agency
Coamissioner.
b.
'rhe' Agency Conmissioner may require the Conmission to submit a
maintenance plan to eliminate degradation of the effluent and/or
wastewater sludge. The Coami ss i on shall operate the di sposa 1
system in accordance with this plan as approved by the Agency
CQlllllissioner.
,
c.
The Commission shall provide an adequate operating staff which is
duly qualified under ~N Rules Chapter 9400 and if applicable as
detennined by the Agency Cormtissioner pursuant to 7001.01~O,
subp. 3.F., to carry out the operation, maintenance and test,ng
functions requirea to insure compl iance with the conditions of
this permit.
The Commission shall at all times maintain in good working order
and operate as efficiently as possible all facilities or systems
of control ins'talled or used to achieve compliance with the tenns
and conditions of this permit. .
d.
e.
Necessary in-plant control tes:s shall be conducted at a
frequency adequate. to ensure continuous efficient operation of
the treatment facility. '
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PART I!
pase 25 of 31
Penni~ No: M1i 0029815
" -.
B.
RESPONSI8 IUTIES
1.
Prohibited Wastes
Under no circumstances shall the Corr.mission allow the introduction of
wastes prohibited by regu]atibns promulgated pursuant to Section 307
of the Act or regulations adopted by the Agency into the sewe!"
collection system including, but not limited to the following:
a.
b.
c.
2.
Those which create a fire or explosion hazard in the disposal
sys, te."I1
Which will
syste."I1,
cause corrosive structural
damage to the disposal
Solids or viscous substances in amounts which" cause obstructions
to the flow in sewers or ; nterference wi th the proper ope!"a ti on
of the treatment works,
d.
Wastewaters at a flow rate and/or pollutant discharge rate which
;s excessive over relatively short time periods so as to."cause a
loss of treatment efficiency,
New wastes or increased volumes or quantities of wastes from
contributing industries in such volumes or quantities as to
overload the treatment facility or cause a. loss of treatment
efficiency.
e.
Coolina Water
a.
Recirculation of non-contact cool ing water, by contributors to
the collection system, shall be encouraged in order to conserve
suriace and ground water suppl ies and to reduce the hydraul ic
load on the collection and treatment system of municipal
wastewater treatment facilities receiving these discharges.
Consistent with Federal construction grant regulations and the
intent of the Act, existing discharges of non-contact cooling
waters to municipal sanitary sewer'systems shall be eliminated,
where such elimination is cost effective, where such discharges
adversely impact the municipal treatment facilities, or where an
i nfi 1 tration/inflow ana lysis and sewer system evaluation survey
indicates the need for such removal, provided such discharges ~re
in compliance with all applicable Agency effluent qual,ty
standards, or which, through reasonable measures, can be brought
into such compliance.
b.
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PART II
Page 2i of n
Permi~ No: MN 002=315
a.
To e!1te~ upo~ the Corrrnission's premises where a disposal syste!il
or other pOint sou,rce or portion thereof is located for the
purpose of. obtaining information. examination of records
conducting surveys or investigations; .
b.
To examine ~nd copy any books. papers. records or memorandum
pertaining to the installation. maintenance or operation of the
discharge. incl.uding but not limited to. monitoring data of the
disposal system or point source or records required to be kept
under the terms and c~nditions of this permit.
To inspect any monitoring equipment or monitoring procedures
required in this perm~t; and
c.
d.
To sample any di.scharge of pollutants.
i .
Civil and Criminal liability
Nothing in this permit shall be construed to relieve the Joint
Pennit'te! from civil or criminal penalties...or preclude the institution
of any legal proce!dings for noncompliance with applicable State or
Federal pollution control laws or for noncompliance with the terms and
conditions of this permit except that the Council shall be liable for
noncompliance with tne terms and conditions of this permit only to the
extent of the Council's statutory authority over the activities
necessary for cempliance with this Permit.
Oil an~'Hazardous Substance Liabilitv
. -
8.
This permit shall not preclude the institution of any legal action or
relieve the Joint Permittee from any responsibilities. liabilities. or
penalties to which the Joint Permittee is or may be subject to under
Section 311 of the Act and Minnesota Statutes, Chapters 115 and 116 as
amended. Each Joint Permittee shall be liable only to the extent of
its statutory and (in the case of the Cormtission) regulatory
authority.
Liability Exemotion
9.
This pennit autherizes the Joint Permitte~ to perfonn the ac.tiviti~s
described herein under the conditions set forth. In issulng thlS
penni t, the state/agency assumes no responsibi 1 ity for any damage to
persons, property or the envir.onment caused by the ~ctivities of the
Joint Pennittee in the conduct of its actions. including those
activities authorized. directed or undertaken pursuant to the pennit. .
To the ex~entthe state/agency may have any liability for the
activities of its employees, that liability is explicitly limited -;:---
that provided in the Torts Claims Act. Minnesota Statute 9 3.736.
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rice 29 -c: 21
Permit No. XN C'Z-
PART III
PRI7REATMSNT REQUIREMENTS
- the authority of Section 2G7(b) and '(c) and 402(b)(6) of the Clean Water
ind implementing regulations (40 CFR Part 4C2), the Commission's
-sat.T,ent program was approved on December 22, 1SS2. The Commission shall
i.Tent and operate the pretreatment program according to the legal
jrities and procedures contained therein, the General Pretreatment
iations (40 CFR Part AQ3), and any subsequent federal or state laws or
lations which may apply. The Pretreatment Requirements contained in this
it shall apply to tJie Commission's systemwide pretreatment program, until
time as tfrey are replaced partially or totally by P re treatment Requirements
ained in any future permit issued by the Agency to the Commission.
APPROVED FRETSEATMENT PROGRAM CONDITION;
The Commission is hereby required to:
1. Apply and enforce against violations of Prohibited Discharge Standards
spscifiea in 40 CFR 403.5(a) and (b), local limitations established
pursuant to 40 CFR 403.5(c) and (d), Categorical Pretreatment
Standards promulgated as described in 40 CFR 403.6, and the
Commission's Waste Discharge Rules. In the case of numerical
discharge standaras, the Commission shall require compliance with the
. most stringent standard, either federal or local. In all cases,
appropriate remedies for non-compliance with pretreatment standards
and requirements shall be obtained.
2. Issue and administer Industrial Discharge Permits to all affected
industrial users in accordance with criteria and procedures contained
in the approved pretreatment program. The permits shall contain
compliance schedules, as necessary, to require the industrial user to
achieve compliance with applicable pretreatment standards and
requirements and any provisions of the Commission's Waste Discharge
Rules. In addition, permitted industrial users shall be required to
submit any reports specified by the Waste Discharge Rules or
applicable federal pretreatment regulations.
3. Carry out Inspection, surveillance and monitoring procedures which
will determine, independent of information supplied by the industrial
user, the compliance status of the industrial user with respect to
pretreatment standards and requirements.
4. Locate, identify and maintain records on all industrial users of the
Metropolitan D.ispos'al System. Such records shall indicate the nature
and/or volume of wastewater discharged and shall be updated, as
necessary.
5. Provide adequate funds.and resources for pretreatment program
activities. Any decrease in funding or activity levels shall be
reported to the Agency.
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