United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R05-90/134
September 1990
&EPA
Superfund
Record of Decision
Kummer Sanitary Landfill, MN
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50272-101
REPORT DOCUMENTATION 1. REPORT NO.
PAGE EPA/ROD/R05-SO/134
t. Till* and Subtitle
SUPERFUND RECORD OF DECISION
Kummer Sanitary Landfill, MN
Third Remedial Action - Final
7. Author(s)
9. Performing Organization Name and Address
12. Sponsoring Organization Name and Addresa
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
2. 3. Recipient's Accession No.
S. Report Date
09/29/90
6.
8. Performing Organization Repl No.
10. Proiecl/Task/Work Unit No.
11. ContracMC) or Grant(C) No.
(C)
(G)
13. Type of Report & Period Covered
800/000
14.
IS. Supplementary Notes
16. Abstract (Limit: 200 words)
The 35-acre Kummer Sanitary Landfill site is an inactive mixed municipal waste landfill
in Northern Township, Beltrami County, Minnesota, approximately one mile west of Lake
Bemidji. A large residential area lies approximately 1,000 feet east of the site, and
there is a hospital directly southwest. The privately owned landfill was operated from
1971 until 1985; however, business records for the site are virtually nonexistent.
Operations at the landfill caused the State to take a number of administrative and
enforcement actions. Following the discovery of ground water contamination in Northern
Township in 1984, the State issued a public health advisory concerning the well water
and provided a temporary water supply. Two previous Records of Decision (RODs) in 1985
and 1988 documented the provision of an alternative water supply for the Northern
municipal water system as Operable Unit 1 (OU1 , and a source control Operable Unit
(OU2) , which included a cover system to control the source of contamination (OU3) . This
final ROD addresses ground water contamination. The primary contaminants of concern
affecting the ground water are VOCs including benzene, PCE, TCE, and vinyl chloride.
(See Attached Page)
17. Document Analysis s. Descriptors
Record of Decision - Kummer Sanitary Landfill
Third Remedial Action - Final
Contaminated Media : gw
Key Contaminants: VOCs (benzene, PCE, TCE)
b, Identifiers/Open-Ended Terms
c. COSATI Field/Group
18. Availability Statement
, MN
19. Security Class (This Report) 21. No. of Pages
None 80
20. Security Class (This Page) 22. Price
None
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R05-90/134
Kummer Sanitary Landfill, MN
Third Remedial Action - Final
Abstract (Continued)
The selected remedial action for this site includes ground water pumping and treatment
using advanced oxidation processes (e.g., ozone, hydrogen peroxide, or ultraviolet
light), and lime soda softening, as necessary, to precipitate alkalinity and other
inorganic compounds, followed by disposal of the precipitate sludge, polishing the
effluent stream with granulated activated carbon, and discharging treated ground water
to an onsite infiltration pond; and ground water monitoring. Treatability studies for
bioremediation as a more cost-effective remedy are planned; however, the ROD will be
amended if the treatment is changed to biotreatment. The estimated present worth cost
for'this remedial action is $1,800,000-S6,200,000, which includes an annual O&M cost of
$240,000-$510,000 for 30 years.
PERFORMANCE STANDARDS OR GOALS: Contaminants of concern in the ground water will be
reduced to meet current and proposed Maximum Contaminant Levels (MCLs) including PCE 5
ug/1 (proposed MCL) , TCE 5 ug/1 (MCL) , and benzene 5 ug/'l (MCL) ; thereby reducing
cumulative residual carcinogenic risk due to ingestion to 10~°.
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DECLARATION FOR THE RECORD OF DECISION
Site Name and Location
Kummer Sanitary Landfill
Northern Township, Beltrami County, Minnesota
Statement of Basis and Purpose
This decision document presents the selected remedial action for
the Kummer Sanitary Landfill, Northern Township, Minnesota, which
was chosen in accordance with the Comprehensive Environmental
Response, Compensation and Liability Act of 1980, as amended by
the Superfund Amendments and Reauthorization Act of 1986 and, to
the extent practicable, the National Contingency Plan.
This decision is based on the contents of the administrative
record for the Kummer Sanitary Landfill site. The attached index
identifies the items that comprise the administrative record upon
which the selection of this remedial action is based.
Assessment of the Site
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action in
this Record of Decision, may present current or potential risks
to public health and welfare and to the environment.
Description of the Selected Remedy
This operable unit is the final action of three operable units
for the site. The first operable unit at this site involved
installation of a municipal drinking water system. The second
operable unit involved a final cover for the landfill. The third
operable unit involves the contaminated ground water. The
selected remedy consists of the following components:
- Extraction of contaminated ground water
- Treatment of contaminated ground water by advanced
oxidation processes
- Discharge of treated ground water using an
infiltration pond
Statutory Determinations
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment technology, to the
maximum extent practicable, and satisfies the statutory
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preference for remedies that employ treatment that reduces
toxicity, mobility or volume as a principal element.
However, the size of the landfill precludes a remedy in which
possible contaminants in the landfill could be excavated and
treated effectively. Thus, this remedy may result in hazardous
substances remaining on-site above health-based levels. A review
will therefore be conducted within five years of commencement of
the remedial action to ensure that the remedy continues to
provide adequate protection of human health and the environment.
State Concurrence
The Minnesota Pollution Control Agency (MPCA) played a major role
in the Remedial Investigation/Feasibility Study (RI/FS) process
as the lead agency and concurs on the selected remedy. The MPCA
has indicated that research in bioremediation of contamination
similar to that found at Kummer is underway and may, in the
future, provide a reasonable alternative or an additional
component of remediation to that which is selected in this
document. The MPCA believes that a timely and appropriate
bioremediation study is warranted for the Kummer Sanitary
Landfill Site.
MPCA believes that Alternative III - ground water extraction and
treatment via a plume barrier system for aquifer restoration -
presents the best balance among the nine evaluation criteria.
Valdas V. 'Adamkus ~/ODate
Regional Administrator^''
U.S. Environmental Protection Agency, Region V
Gerald L. Willed
Commissioner
Minnesota Pollution Control Agency
Date
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RECORD OF DECISION SUMMARY
RUMMER SANITARY LANDFILL
OPERABLE UNIT 3
I. SITE NAME, LOCATION AND DESCRIPTION
The Kummer Sanitary Landfill is located in Northern Township,
Beltrami County, Minnesota, approximately one mile west of Lake
Bemidji. The site is-located along the north side of Anne
Street, N.W., and midway between U.S. 71 and County State-Aid
Highway 15. The northern corporate limits of the City of Bemidji
are one-half mile south of the site (Figure !.)•
Northern Township has a population of 4,095 (1986 data) and is
generally sparsely populated. Most of the township residents
live in the southeastern section of the township near the City of
Bemidji and along the western shore of Lake Bemidji. To the
north and west of the site the land is sparsely settled with
isolated residences. The closest residential building is the
Kummer residence located on-site in the extreme southeast corner
of the property. A large residential area lies approximately
1,000 feet further to the east and a hospital is located
directly southwest of the landfill.
The property is over 40 acres in size, with the actual landfill
occupying approximately 35 acres. The landfill has relatively
steep outslopes and a gentle sloping to flat upper surface. The
present landfill cover is very permeable, consisting of material
excavated from sand and gravel deposits from the extreme northern
portion of the site.
The terrain in the immediate vicinity of the site is very gently
rolling. The site is bounded on the east and west by pasture,
and on the north by woodlands and a bog. To the south, Anne
Street provides a boundary between the landfill and wooded area
containing a gravel pit. Surface elevations at the site range
from about 1,360 to 1,380 feet above mean sea level (MSL). Local
surface drainage is generally northward. Approximately one-half
mile to the north, a modified stream channel or ditch carries
runoff to Lake Bemidji, but runoff from the site infiltrates into
the soil before reaching this ditch.
The region is characterized by flat to gently rolling terrain to
the north and gently rolling terrain to the south. Surface
elevations range from approximately 1,050 to 1,550 feet above
MSL. The area contains numerous wetlands and lakes.
The Kummer Sanitary Landfill is located within the Mississippi
River Headwaters Watershed. The ground water reservoir contains
the largest quantity of water available within the area. Ground
water discharge provides at least part of the base flow of
streams and uniform lake stages.
The landfill site is underlain by glacial outwash deposits of
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sand and gravel mixed with some silt and clay. The sands of the
glacial outwash deposits continue approximately 100 feet below
the average site elevation. Well logs from on-site monitoring
wells and residential wells located within two or three miles of
the site indicate the top of a discontinuous clay layer at a
depth of 36 to 45 feet.
Ground water in the glacial outwash sands flows generally to the
east, where it eventually discharges into Lake Bemidji. Water
from Lake Bemidji is used for fisheries, recreation, industrial
consumption, agricultural purposes and by wildlife. The average
linear velocity is .075 feet per day to 7.2 feet per day,
calculated from an estimated hydraulic conductivity of 10 to 120
feet per day for the outwash sands of the aquifer. The hydraulic
gradient of the water table ranges from 0.0024 feet/feet to .0030
feet/feet.
Ground water use in the Bemidji area is limited to the
unconsolidated deposits above bedrock. The City of Bemidji's
primary water supply wells are located one and one-quarter miles
west and hydrologically upgradient of the site and are pumpe
from a depth of about 160 feet. An aquifer test analysis
completed by Barr Engineering in 1989 concluded that pumping
Bemidji's well field would neither reverse the gradients at nor
pull in contamination from the landfill. The depth of
contamination at the landfill is limited to the upper 30 to 50
feet of the aquifer.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Kummer Sanitary Landfill was opened in 1971 with solid waste
permit number 31 from the Minnesota Pollution Control Agency
(MPCA). Until 1983, the landfill accepted material described
only as "mixed municipal waste".1 The waste was deposited in the
landfill using a trench and fill technique, and early trenches
were located along the southern, western and northern borders.
Cover material was excavated from borrow areas within the
landfill property, and these borrow areas later became active
landfill disposal sites. The landfill area occupied a major
portion of the property by 1984. A demolition debris disposal
area near the eastern edge of the site was opened in 1974, and is
known to contain fly ash and sawdust.
During the pre-RI investigation, ground water samples were
collected from the landfill monitoring wells and residential
wells by MPCA staff. Twenty-five volatile organic compounds
(VOCs) were found, including 1,1,2,2-tetrachloroethene, benzene
1 / The Minnesota Waste Management Act of 1980 includes
certain industrial wastes in this definition.
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1,2-dichloroethane and 1,1,2-trichloroethene (Table 1).
Enforcement History
During the operating life of the landfill, poor operations at the
site caused the MPCA to take a number of administrative and
enforcement actions. -
On March 6, 1979, a Notice of Noncompliance was issued to Jon
Kuiruner for failing to comply with MPCA Solid Waste Rule 6 (SW-
6).2 A Notice of Violation was then issued to Jon Kummer on May
15, 1979, for his failure to comply with Rule SW-6. Jon Kummer
failed to comply with the requirements of corrective action set
out by both these notices.
On December 18, 1979, Jon and Charles Kummer entered into a
Stipulation Agreement with MPCA in order to bring the landfill
into compliance with Minnesota rules and regulations. However,
the MPCA later found that conditions in the Stipulation Agreement
were being violated, and that there were continued violations of
MPCA Rule SW-6.
On April 19, 1983, the State commenced legal action against Jon
and Charles Kummer for alleged violations of Minnesota statutes,
MPCA solid waste and water quality rules, and the December 18,
1979 Stipulation Agreement. The lawsuit was dismissed with
prejudice but without costs in April, 1988.
Under the Minnesota Environmental Response and Liability Act
(MERLA), a Request for Response Action (RFRA) was issued by MPCA
on June 26, 1984. This document requested Charles, Ruth and Jon
Kummer to undertake a Remedial Investigation/Feasibility Study
(RI/FS) at the landfill, as well as to produce plans for remedial
action, closure/continued operation and long-term ground water
monitoring. Charles and Ruth Kummer then indicated that they
were not financially able to conduct the work required by the
RFRA, and would voluntarily close the landfill. Therefore on
August 28, 1984, a Determination of Inadequate Response was
issued -for failure to conduct the RI/FS. At this time,
authorization was also given to negotiate and enter into a
cooperative agreement with the United States Environmental
Protection Agency (U.S. EPA) and to negotiate and enter into
2/ Minnesota Solid Waste Rule 6 (1973) provided rules and
regulations for the maintenance and operation of sanitary
landfills. The rule requires, among other things, that deposited
wastes be covered daily with at least 6 inches of cover material,
that windblown debris be collected daily, that surface water
drainage be diverted away from the operating area and that
the deposited material not cause pollution of ground water.
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contracts to expend State and/or Federal superfund monies to
conduct response actions at the site.
A temporary restraining order was issued by Beltrami County on
April 4, 1985, because an inspection showed that the permittee
had reopened the landfill. The MPCA then issued an
Administrative Order on June 25, 1985 which closed the landfill
and revoked the permit.
Section 122(a) of the Superfund Amendments and Reauthorization
Act of 1986 (SARA) gives the President the authority to enter
into agreements with Potentially Responsible Parties (PRPs) to
perform response actions if he determines the actions will be
done properly. If the President determines ^hat it is
inappropriate to enter into an agreement or to initiate
negotiations, the PRPs shall be notified of this decision and the
reasons behind it. Charles and Ruth Rummer, the owners and
operators of the landfill, were sent a letter dated September 28,
1988, notifying them of the decision not to enter into
negotiations with them, consistent with this requirement of
Section 122(a).
On September 29, 1984, the U.S. EPA and MPCA executed a
Cooperative Agreement for implementing a RI/FS for the Kummer
Landfill. In October 1984, the site was proposed for the
National Priorities List (NPL). In June 1986 the site's
inclusion on the NPL was finalized by the U.S. EPA.
Following the discovery of ground water contamination, a
Determination of Emergency was issued by the MPCA on July 17,
1984. This permitted the expenditure of State Superfund money
for a temporary water supply for affected residents. The
Minnesota Department of Health (MDH) and MPCA delineated a three
and one-half block area east of the landfill as a well advisory
area. On August 28, 1984, the MPCA authorized the expenditure of
State Superfund money for a focused FS on a water system for the
well advisory area. Eighty-one property owners received letters
from MDH on August 29, 1984, which notified them that they should
discontinue the use of their private wells for drinking and
cooking purposes.
On June 12, 1985, a Record of Decision (ROD) was signed which
selected an alternative water supply as the remedial action. The
selected remedy provided for an extension of the existing public
water supply from the City of Bemidji. Because the additional
area between the well advisory area and Lake Bemidji was
downgradient of the landfill and potential for contamination of
wells in that area was thought to be very high, the entire area
east of the landfill to the lake was included in the water
supply system. Construction of the water system began in June
1987, and was completed in the summer of 1990. A total of 193
connections to individual homes, businesses, and a mobile hone
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park were completed in this operable unit (Operable Unit 1).
Due to the complexity of the site, the RI investigation was
completed in phases. The Final RI Report was approved in May
1990. The Source Control Operable Unit (Operable Unit 2) FS was
received in September 1988. On September 30, 1988, a ROD was
signed which selected -a cover system for the landfill as the
remedial action for Operable Unit 2. The selected remedy
included a low permeability cap, site deed restrictions, fencing
and long-term operation and- maintenance to provide inspections
and repairs to the cap.
As business records for the site are virtually nonexistent, the
PRPs were identified primarily through responses to Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA)
Section 104(e) information requests, and responses to the MPCA
requests for information, MPCA disclosure files, and MPCA site
inspection files. Pursuant to its authority under Section 104(a)
of CERCLA, the U.S. EPA issued General Notice letters to 10 PRPs.
The Ground Water Operable Unit (Operable Unit 3) FS was received
in July 1990, and is the subject of this ROD.
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Superfund activities at the Rummer Sanitary Landfill site
have been followed closely by local community and press. To
date, there have been public meetings, fact sheets, update
letters and press releases regarding the activities at the site.
There is an active mailing list of local citizens interested in
the activities at the site. A chronology of past community
relations activities at the site is listed in the Responsiveness
Summary as an attachment to this ROD.
A public information repository has been established in the
Northern Township Town Hall. The administrative record for the
site has been placed in the repository. When the RI/FS for this
Ground Water operable unit was completed a proposed plan was
prepared stating MPCA's and U.S. EPA's recommendation for
remedial action at the site. Notice of the availability of the
RI/FS and proposed plan was published in the Bemidji Pioneer on
July 29, 1990, initiating a thirty day public comment period.
Notice of the public meeting held on August 9, 1990, was
included. Additionally, a fact sheet and a separate letter
providing notification of the public meeting were sent to
interested parties.
A public meeting was held on August 9, 1990, where the MPCA
presented the alternatives to a group of interested citizens.
The attached Responsiveness Summary (Appendix A) addresses
specific comments raised at the August 9 public meeting and
during the public comment period. The official public comment
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period ended on September 5, 1990, following the granting of an
extension of time for submittal of comments.
IV. SCOPE AND ROLE OF OPERABLE UNIT
Because of the complexity of work at the Rummer Sanitary
Landfill, the activities at the site have been divided into three
operable units, which are:
Operable Unit 1. Northern Township Municipal Water System
Operable Unit 2. Source control of contaminants emanating
from the landfill
Operable Unit 3. Management of the contaminated ground
water
Operable Unit 1, which is operating, provided for an extension of
the City of Bemidji municipal water supply system into the
affected area, thereby providing a safe drinking water source to
affected residents.
The landfill cover system planned for Operable Unit 2 is
currently in the remedial design phase. Actual construction on
the cover is planned to begin in the spring of 1991.
The principal threat of Operable Unit 3 is the contaminated
ground water beneath and down gradient of the Rummer Sanitary
Landfill. The contaminated ground water contains VOCs, including
vinyl chloride, a known human carcinogen, which threatens human
health because of possible ingestion of contaminated water, as
well as possible dermal contact and inhalation during showering
and bathing. The center of the plume straddles the eastern
boundary of the landfill. As indicated in Figure 2, the critical
portion of the present plume does not extend past Irvine Avenue.
This operable unit represents the final remedy for the site and
in combination with the two previous operable units is intended
to address the entire site with regards to the principal threats
to human health and the environment posed by the site as
indicated in the risk assessment for the site. The findings of
the risk assessment are included in the RI Report and are
summarized in a later section of this document.
V. SITE CHARACTERIZATION
The problem of primary importance is the contamination of ground
water with VOCs by leachate from the Rummer Sanitary Landfill.
The Rummer Sanitary Landfill is the only known source of
contamination of ground water in the area. The compounds of
concern and the range of concentrations detected in ground water
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at the site are listed below.
COMPOUND OF CONCERN RANGE DETECTED
Tetrachloroethene 1.0-12 ug/1
Trichloroethene 1.0-6.8 ug/1
Trans-l,2-dichloroethene 1.3-35 ug/1
Vinyl chloride 5.9-94 ug/1
Benzene 1.0-6.0 ug/1
Contaminants observed during investigative activities of the RI
were solely found dissolved in ground water samples. With the
exception of benzene, all these compounds may be related as part
of the degradative transformation of tetrachloroethene to vinyl
chloride through both chemical and biological processes. These
contaminants were found at locations both outside and within the
boundaries of the landfill. Due to the limited amount of
subsurface work conducted in the landfill, it is not possible to
determine with certainty the actual physical state(s) of waste
materials which may have caused contamination of the ground
water. Identifiable cuttings of the waste mass consisted of
typical household waste such as plastic, paper, wood and carpet
scraps, mattress springs and automotive parts. The observations
are based upon landfill trenching completed at the site in May
1990 and described in the FS.
The ground water contamination is most likely the result of
precipitation infiltrating through the permeable landfill cover
and coming in contact with the waste. Specific contaminants may
also result from the degradation of waste products.
The compounds of concern can be classified as to carcinogenicity.
A "Group A compound" means that sufficient information exists to
correlate it as a human carcinogen. "Group B2 compounds" are
classified as probable human carcinogens because sufficient
epidemiological evidence does not exist, but there is sufficient
evidence from animal studies to support the classification of
"probable" human carcinogen. "Group D compounds" are not
classifiable as to human carcinogenicity. The classes of the
compounds of concern are listed below.
1,1,2,2-tetrachlorothene Group B2
Trichloroethene Group B2
Trans-l,2-dichlorothene Group D
Vinyl chloride Group A
Benzene Group A
The plume is defined using the extent of detectable vinyl
chloride. The lateral extent of the vinyl chloride plume is
shown in Figure 2. The ground water contamination extends to a
depth of 50 feet; the vertical extent of vinyl chloride, however,
is limited to the B zone (which is approximately 42 feet deep) in
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8
the area of concern (see Figure 2).
Migration of VOCs through surface water is unlikely to occur
because of their volatility. As a matter of fact, the surface
water pathway was found to be unlikely for migration of any VOCs
attributable to the Kummer Landfill since surface water was not
present on the site during remedial investigations. Wetlands to
the north of the site are not downgradient of the waste-filled
area of the landfill and, therefore, should not be impacted by
contaminants migrating from the site.
Risk has been calculated for the above-mentioned compounds of
concern, and three pathways for incurring risk were evaluated.
These pathways were: (1) ingestion of ground water, (2)
inhalation during showering and (3) contact with ground water
during bathing. Risk is based on the concentrations found in the
center of the plume located at the eastern boundary of the
landfill. Risk exposure through inhalation and contact with
ground water contaminated with contaminants of concern was
calculated to be three in one thousand.
Ecological exposure was not considered significant because ground
water was the primary pathway identified. Exposure to waste at
the landfill was not considered because exposed waste is not
present for direct contact to occur. In addition, the soils at
the landfill have low organic carbon content, and the compounds
of concern will not readily absorb them.
The concentrations of certain inorganic compounds are
significantly higher in downgradient monitoring wells along the
eastern boundary of the landfill than in the upgradient
monitoring wells. The inorganic compounds of concern are
aluminum, arsenic, barium, iron, manganese, nickel, and nitrate.
Only barium concentrations are greater than the Maximum
Concentration Levels (MCL) set under RCRA. The inorganic
compounds are relatively immobile, and as such pose no
significant threat to human health and the environment. The
extent of the concentrations of inorganic contaminants exceeding
drinking water standards appear to be confined to the area
encompassed by the Kummer Landfill.
VI. SUMMARY OF SITE RISKS
A baseline risk assessment of the Kummer Sanitary landfill is
detailed in Chapter 8 of the RI Final Report. The only media
found to be of concern at the site was ground water. Three
ground water monitoring programs were completed, and eight rounds
of data were collected. The results revealed that VOCs are being
introduced into the shallow ground water by the landfill.
However, ground water monitoring has shown that the plume does
not extend to Lake Bemidji.
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The area affected by the ground water contamination is between
the landfill and Lake Bemidji, an area of approximately one mile
by one-third mile. The current population of this area is 960
persons with a projected population of 2,240.
The ground water is the pathway of concern, and human exposure
may occur from ingestion of the ground water for drinking and
cooking, skin contact during bathing, and inhalation exposure to
contaminants volatilizing from the water during bathing. Table 4
summarizes the exposure data for the three pathways examined at
the site.
The risk levels (probabilities of an individual developing
cancer) are summed to predict the combined impact of chronic
exposure to a mixture of the compounds of concern. The values
are detailed in Table 5. As discussed in the RI Report, the
estimated cancer risks from individual chemicals range from 7E-10
to 3E-03. The summed risk is relatively high, three in one
thousand, because of the high concentration of vinyl chloride
detected in the ground water (94 ug/1 found in well 12B) and its
carcinogenic potency. The risk level is conservative because it
is based on people ingesting ground water from the center of the
plume. However to date the highest concentrations of
contamination have not reached the residential wells. The non-
cancer impact varies from 1E-4 to 1E-7.
Deer, rabbits, raccoons, skunks and small rodents which may
utilize the landfill and adjacent wetland area for feeding are at
minimal risk, as well as various bird species. These animals
would most likely become contaminated through contact with
vegetation growing on the landfill or fill materials and then
pass through the food chain. However, the compounds of concern
are highly volatile both in the water and in soils with low
organic contant such as the sand at the landfill. Therefore, the
risk of uptake of contaminants by vegetation growing on the
landfill's surface is considered low.
The other pathway of exposure would be through Lake Bemidj i.
This pathway is considered low risk because of its distance from
the landfill, the volatile nature of the contaminants of concern,
and the low bioaccumulation potential of these compounds.
VII. DESCRIPTION OF ALTERNATIVES
Three alternatives were developed to meet the remedial action
goal of controlling migration of contaminated ground water from
the Kummer Sanitary Landfill Site to minimize the potential risk
to public health from future consumption of contaminated ground
water. The first alternative to be described involves no further
action at the site besides that which will be performed for
Operable Units 1 and 2. Alternatives II and III involve pumping
and treating contaminated ground water. Alternative II would
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10
provide for discharge of treated water to Lake Bemidji, whereas
Alternative III would discharge treated water to an on-site
infiltration pond.
Alternative I - No Further Action
The no further action-alternative consists of allowing
contaminated ground water to eventually discharge to Lake
Bemidji. Off-site monitoring wells no longer required for long-
term monitoring of the plume may be removed, and ground water
quality will be monitored annually for 30 years. Some new
monitoring wells may also be installed near Lake Bemidji which
will be monitored for surface water quality parameters.
The aquifer is considered to be a Class II aquifer, having
potential as a source of drinking water. The area of cleanup
considered under this alternative includes the plume from the
landfill east to Lake Bemidji, as Surface Water Quality Criteria
(SWQC) must be met upon discharge to the lake. Using numerical
computer ground water modelling, if the hydrodynamic processes in
the aquifer are left to run their course, the present contaminant
plume will reach Lake Bemidji in approximately 34 years with
concentrations of contaminants at levels below surface water
quality standards. This discharge of contaminants would
constitute a non-point source discharge into surface waters and,
therefore, SWQC would have to be met. Any increase in
contamination above the surface water quality criteria (SWQC)
would require the implementation of other alternatives to bring
the ground water into compliance. It appears that more than 80
years will elapse before the plume dissipates to the point where
the aquifer can be utilized again as a potable water supply.
Applicable or relevant and appropriate requirements (ARARs) are
SWQC for the surface water and MCLs for the ground water (Table
4). The discharge of the plume to Lake Bemidji must meet the
SWQC. The center of the plume does not comply with the MCLs and
this alternative is inconsistent with the U.S. EPA ground water
protection strategy. The discharge to Lake Bemidji appears to
comply with SWQC.
Total Cost of Alternative I: $300,000 (in present net worth)
Alternative II - Active Dovngradient Hydraulic Controls and
Surface Water Discharge
Ground water will be collected in a series of pumping wells
located within the present plume of VOC contamination. An on-
site treatment facility will be constructed with removal of
inorganic compounds by lime-soda softening and filtration which
produces a sludge, and removal of organic compounds by an
advanced oxidation processes (AOP) and granulated activated
carbon for polishing of the effluent stream. Plans are to
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11
landfill the inorganics treatment sludge off-site. Treated
ground water is discharged to Lake Bemidji via a dedicated line
and a below-water discharge structure.
The area of cleanup considered under this alternative includes
the plume defined in Figure 2. The ground water modelling
indicates that sixty percent of the plume can be recovered in 3.5
years and it will take 10 years before the plume will comply with
MCLs. The point source discharge to Lake Bemidji is regulated by
SWQC under NPDES permit requirements. A portion of the plume
will escape the pumping wells and reach Lake Bemidji after 36
years at concentrations below SWQC.
The cleanup criteria in the pumping area will be drinking water
MCLs because they are the most stringent criteria in the area of
concern. However, the alternative as presented considers the
average VOC concentration to drive the ground water treatment.
Treatment operations may continue from 4 to 30 years, depending
on long-term effectiveness of the cover system in blocking future
contaminant migration to the ground water under the landfill.
The extraction of ground water with high concentrations of metals
may also involve managing a hazardous waste sludge. Modelling
has shown that it may take 10 years before the plume would comply
with MCLs. The portion of the plume that is not captured by the
pumping wells would reach Lake Bemidji in 36 years at a total VOC
concentration of approximately 2 ppb. This amount complies with
SWQC, and with the MCLs. The pumped water must also comply with
SWQC under the NPDES permit.
In a general sense, the risk associated with this alternative is
lower than that of Alternative I because of implementation of
active ground water treatment. Through treatment of the
contaminated ground water, the risk range associated with this
alternative will be reduced from 3E-3 to 1E-6. However, because
of the low transmissivity of the aquifer immediately downgradient
of the east boundary of the landfill, not all of the plume can be
captured. This indicates that a drilling advisory must be
implemented in order to ensure that licensed well drillers are
aware of the presence of a contaminated aquifer and wells are not
developed in the contaminated aquifer.
The ARARs, relevant and appropriate for this alternative, include
MCLs and SWQC (Table 4). The concentration of contaminants in
the treated ground water will comply with MCLs. Based on ground
water modelling, the concentration of the plume when it
discharges into Lake Bemidji will comply with SWQC. The sludge
may require management as a hazardous waste and appropriate
Resource Conservation and Recovery Act (RCRA) rules may apply for
land disposal. A notification of pumping must be issued to the
Minnesota Department of Natural Resources (MDNR).
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12
Total Cost of Alternative II: $6,000,000 (in net present worth
dollars)
Alternative III - Active Downgradient Hydraulic Controls and On-
site Infiltration Pond Discharge
Ground water will be collected in a series of pumping wells
located within the present plume of VOC contamination. An on-
site treatment facility will be constructed for removal of
organic compounds by AOP. Inorganics treatment (lime-soda
softening) may be provided if barium concentrations exceed
drinking water quality guidelines, the pumping out of ground
water with high concentrations of inorganic contaminants may also
involve managing a hazardous waste sludge. A notification of
pumping must be issued to the MDNR. Treated ground water is
placed in an on-site pond for recharge to the aquifer.
The area of cleanup considered under this alternative includes
the plume defined in Figure 2. The ground water modelling
indicates that sixty percent of the plume can be recovered in 3.5
years and it will take 10 years before the plume will comply with
MCLs. Because the treated ground water is then discharged into
an on-site infiltration pond, no NPDES permit is required. SWQC
are applicable to that portion of the plume which escapes the
pumping wells and is discharged as a nonpoint source into Lake
Bemidji. The portion of the plume which escapes the pumping
wells will reach Lake Bemidji after approximately 36 years at
concentrations below SWQC. The pumped ground water will be
treated to comply with MCLs prior to discharge to the
infiltration pond.
Treatment operations may continue from 4 to 30 years, depending
on long-term effectiveness of the cover system (Operable Unit 2)
in blocking future contaminant migration into ground water
beneath the landfill.
The ARARs, appropriate and relevant for this alternative, include
MCLs and SWQC (Table 4). The concentration of treated ground
water will comply with the MCLs. Based on the results of ground
water modelling, the concentration of the portion of the plume,
which will escape the extraction system, will comply with SWQC
when it discharges into Lake Bemidji. The sludge produced from
treatment of inorganics may require management as a hazardous
waste and appropriate RCRA rules may apply for disposal (40CFR
Part 268).
Total Cost of Alternative: $6,200,000 (in present net worth
dollars) "
VIII. SUMMARY OF THE COMPARATIVE ANALYSIS
The nine criteria used for evaluating the remedial alternatives
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13
listed above include: overall protection of human health and the
environment; compliance with ARARs; long-term effectiveness;
reduction of toxicity, mobility, and volume; short-term
effectiveness; implementability; cost; State of Minnesota and
Community acceptance. The advantages and disadvantages of each
alternative were compared to identify the alternative providing
the best balance among the nine criteria.
1. Overall Protection of Human Health and the Environment
Alternatives II and III considered for the Rummer Sanitary
Landfill ground water remediation are protective of human health
and the environment by eliminating, reducing or controlling risks
through combinations of treatment and engineering controls.
Alternative I (No Further Action) does not provide for protection
of human health and the environment. Although this alternative
would include institutional controls, these controls are non-
enforceable and only encourage residents to refrain from using
contaminated ground water. At the present time almost fifty
people are still using private wells which extract ground water
from the contaminated aquifer.
Alternatives II and III both reduce the risks associated with
ground water contamination by pumping and treating contaminated
ground water. A ground water monitoring program will also be
implemented to evaluate the effectiveness of the ground water
remediation activities.
2. ARARs Compliance
SARA requires that remedial actions meet legally applicable or
relevant and appropriate requirements (ARARs) of other
environmental laws. A "legally applicable" requirement is one
which would legally apply to the response action if that action
were not taken pursuant to Sections 104, 106 and 122 of CERCLA.
A "relevant and appropriate" requirement is designed to apply to
problems sufficiently similar that their application is
appropriate.
Alternative I will not meet MCLs before 80 years and does not
comply with GWPA or 7060 (see Section X(2)). Since Alternative I
is not protective of human health and the environment and does
not comply with ARARs it is not eligible for selection and shall
not be discussed further in this document.
Alternatives II and III for the Kummer Site meet or exceed ARARs
as discussed in Section X(B). Alternative II and III are
expected to meet MCLs within 10 years of treatment. ,
3. Long Term Effectiveness and Permanence
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14
Both Alternatives II and III utilize the same ground water pump
and treatment component. By eliminating the contaminants present
in the ground water, each of the alternatives achieves a certain
degree of long-term effectiveness and permanence.
4. Reduction of Toxicity, Nobility, or Volume through Treatment
Since both Alternatives II and III use the same treatment
technology for organic contaminant destruction they equally
reduce the toxicity, mobility and volume of organic contamination
in the ground water.
5. Short Term Effectiveness
Both Alternatives considered have similar impacts on short-term
effectiveness resulting from a ground water treatment system
being utilized.
It is anticipated that Alternative II or III would require one
construction season to complete. During well development and
near ground water treatment facilities workers could be exposed
to VOC emissions. Air monitoring will be required to assure
levels are within applicable National Ambient Air Quality
Standards.
6. Implementability
While both alternatives considered are implementable, Alternative
III is technically and administratively easier to implement than
Alternative II, based on design, complexity, land
purchasing/leasing and permitting requirements.
Alternative II, which includes point discharge to a surface water
body, will be required to meet NPDES permitting requirements
which may be more stringent for treatment of the inorganics in
the ground water than for Alternative III which would discharge
to an on site infiltration pond which would not be subject to
NPDES permitting requirements. Additionally, for Alternative II
it may be difficult even obtain a NPDES permit because some
metals in the Mississippi already exceed standards set for its
protection.
7. Cost
The estimated capital, annual maintenance and monitoring, and
present worth value costs are evaluated by this criterion.
Present worth costs are calculated using a 10 percent discount
rate over the expected period of operation.
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15
Alternative I Alternative II Alternative III
Construction Cost $73,000 $1,300,000 $1.0-1,400,000
Present worth Cost $300,000 $3.0-6,000,000 $1.8-6,200,000
Annual O&M Cost $24,000 $510,000 $240,000-510,000
8. State Acceptance .
The Minnesota Pollution Control Agency (MPCA) played a major role
in the RI/FS process as the lead agency, and concurs on the
selected remedy. MPCA also recognizes their 10% cost share and
O&M responsibilities. The MPCA has indicated that research in
bioremediation of contamination similar to that found at Kummer
is underway and may, in the future, provide a reasonable
alternative to that which is proposed in this document and merits
further studies. The MPCA has submitted an application to the
U.S. EPA Superfund Innovative Technology Evaluation Program
(SITE) to have a bioremediation treatability study performed at
Kummer. The Office of Research and Development within the U.S.
EPA contemplates future participation in evaluation of
bioremediation for the Kummer Sanitary Landfill.
MPCA believes that Alternative 3 - ground water extraction and
treatment via a plume barrier system for aquifer restoration -
presents the best balance among the nine evaluation criteria.
9. Community Acceptance
The public generally accepted the ground water extraction and
treatment remedy selected in this Record of Decision, but
expressed some concerns regarding the treatment process. See the
attached Responsiveness Summary for a detailed discussion of
comments received.
IX. The Selected Remedy
The selected remedy in Alternative III, active downgradient
hydraulic controls and infiltration pond discharge.
1. Ground water extraction
The goal of this remedial action is aquifer restoration to a
drinking water aquifer. Based on information obtained during the
remedial investigation and on careful analysis of all remedial
alternatives, U.S. EPA and MPCA believe that the selected remedy
will achieve this goal. It may become apparent, during
implementation or operation of the ground water extraction
system, that contaminant levels have ceased to decline and are .
remaining constant at levels higher than the remediation goal.
In such a case, the system performance standards and/or the
remedy may be reevaluated.
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16
The selected remedy will include ground water extraction for an
estimated period of 30 years, during which the system's
performance will be carefully monitored on a regular basis and
adjusted as warranted by the performance data collected during
operation. The operating system may include:
a) discontinuing operation of extraction wells in areas
where cleanup goals have been attained;
b) alternating pumping at wells to eliminate stagnation
points; and
c) pulse pumping to allow aquifer equilibration and
encourage absorbed contaminants to partition into
ground water.
Ground water extraction within the VOC plume is selected as the
active downgradient hydraulic control technology most applicable
to the Kuituner site. The intent of this alternative is to extract
the VOC plume and intercept the flow of any additional
contaminated ground water leaving the landfill. Pumped ground
water will require treatment to remove the contaminants. The
effluent will have to be managed.
The ground water "sink" will be formed by installation and
operation a series of about five extraction wells near the
eastern perimeter of the landfill. Conceptual design of the
withdrawal network is based on numerical computer ground water
modelling. Figure 3 depicts potential well locations, the
location of treatment system, and the recharge system.
Wells will be up to 60 feet deep and equipped with screens along
the 10 to 60 foot interval. Most wells will extract water from
the A (15 to 28 foot depths) and B (23 to 47 foot depths) zones,
shown to be contaminated in vicinities of wells MW-12, MW-2 and
MW-3. Wells located at the southern end of the array will
extract water from the A, B and C zones in the general vicinity
of MW-1, the only monitoring well showing contamination at the c
depth. These wells will be screened from 53 to 104 feet.
2. Ground Water Treatment
Advanced Oxidation Process (AOP) is the chosen treatment for the
contaminated ground water. AOPs are chemical treatment
technologies which involve the addition of one or more of the
following to contaminated ground water: ozone, hydrogen peroxide
and ultraviolet light. They are most effective in treating
unsaturated organic straight-chain and ringed compounds. Lime-
soda softening as a pretreatment is desirable to remove
alkalinity and other inorganic compounds, which increase ozone
dosages and treatment costs. Treatment for organics takes place
in 3. fiber-reinforced plastic or a stainless steel reaction
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17
vessel. Contaminated water and hydrogen peroxide are fed through
the vessel, and ozone is continuously supplied. The vessel is
vented through an ozone destruct unit for low temperature thermal
treatment of the exhaust air. An ozone dosage 5 to 30 mg/1 will
likely be required to oxidize VOCs. The hydrogen peroxide to
ozone ratio (by weight) selected for conceptual design is 0.5.
Effluent polishing by activated carbon is also included in the
conceptual design of AOP for the following reasons:
1. Incomplete oxidation can result in organic intermediates
which also may be toxic. Carbon will likely remove organic
compounds which result from incomplete oxidation.
2. The types of wastes present in the landfill are unknown.
Carbon contactors provide a low-cost contingency for
treatment of a possibly variable suite of organic compounds
which may not be destroyed by AOP.
The ground water may have to be treated to remove the inorganics
depending on chemical composition of the ground water and the
distribution of inorganic compounds at the initiation of pumping.
Lime-soda softening is a chemical treatment process involving
converting bicarbonate alkalinity to carbonate alkalinity, and
then removing divalent ions as precipitates of carbonate and/or
hydroxides. During the process the pH is raised to above 10,
causing the precipitation of arsenic, nickel and barium. Other
ionic compounds may also be removed by adsorption to the
carbonate and/or hydroxide precipitates. The disadvantage of
softening is that sludge is produced, which is the result of
precipitation of divalent cations to compounds such as calcium
carbonate. This sludge must therefore be handled and disposed
of, increasing the cost. The system may also require
sophisticated controls, as the pH ranges are narrow for optimal
removal of arsenic, nickel and barium. Arsenic removal is
complicated further by several possible valence states.
3. Ground Water Discharge
On-site discharge is planned to an infiltration pond. The design
of the infiltration pond is based on permeability data for the
unsaturated zone and hydraulic conductivity data. Additional
field tests including infiltration capacity will be required
during preliminary engineering. Existing data indicate the
strata are extremely permeable so that pond size is minimal. The
exact location will be determined during remedial design for
maximizing performance of the pumping network. Depth is set at
10 feet to allow for continued operation during extended sub-
freezing temperatures characteristic of the Bemidji winters.
Based on average annual conditions, detention time in the pond is
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18
expected to be less than one hour. Pond design is based on a
water balance calculation which includes: discharge rate of
water into the pond, evapotranspiration, runoff, infiltration,
percolation and interlayer drainage.
4. Ground Water Monitoring
During the time of remedial design and remedial action the ground
water will continue to be monitored on a regular basis. Two
additional monitoring wells will be installed near Lake Bemidji
to monitor advancement of the portion of the plume which escapes
the extraction well system. These wells will be monitored using
Surface Water Quality Criteria for Lake Bemidji. Sampling of
ground water from monitoring wells near Lake Bemidji will be done
on an annual basis, or as determined by the MPCA Water Quality
Division staff. The surface water sampling parameters will
include total phosphorous, ortho phosphorous, total Kjeldahl
nitrogen, total alkalinity, chloride, pH, temperature and
ammonia. In addition, VOCs and priority pollutant metals will be
tracked twice a year.
5. Remediation Goals
The ground water shall be extracted and treated until MCLs for
all contaminants are obtained. When these standards are met the
cumulative residual carcinogenic risk due to ground water
ingestion is estimated to be 1E-6.
Although all VOCs will trigger cleanup levels, the primary focus
will be on vinyl chloride because its high concentration and its
carcinogenic potency (see the Final RI report).
6. Costs
Costs for the three components of the remedy are shown in Tables
5, 6, 7 and 8.
X. STATUTORY DETERMINATION
The implementation of Alternative III at the Kununer Sanitary
Landfill site satisfies the requirements of Section 121(a to e)
of CERCLA as detailed below.
1. Protection of Human Health and the Environment
Implementation of the selected alternative will reduce and
control potential risks to human health and the environment posed
by exposure to contaminated ground water. Extraction and
treatment of contaminated ground water to meet State and Federal
standards will reduce the potential excess cancer risk to 1E-6.
The selected remedy also protects the environment by reducing the
potential risks posed by the site chemicals discharging to Lake
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19
Bemidj i.
2. Attainment of Applicable or Relevant and Appropriate
Requirements.
Section 121(d) of SARA requires that remedial actions meet
legally applicable or relevant and appropriate requirements
(ARARs) of other environmental laws. These laws may include:
the Resource Conservation and Recovery Act (RCRA), the Clean
Water Act (CWA), the Clean Air Act (CAA), the Safe Drinking Water
Act (SDWA), and any state law which has more stringent
requirements than the corresponding Federal law. "Legally
applicable" requirements are those cleanup standards, standards
of control, and other substantive environmental protection
requirements, criteria or limitations promulgated under Federal
or State law that specifically address a hazardous substance,
pollutant, contaminant, remedial action, location, or other
circumstances at a CERCLA site. "Relevant and appropriate"
requirements are those requirements that, while not legally
applicable to the remedial action, address problems or situations
sufficiently similar to those encountered at the site that their
use is well suited to the remedial action.
Non-promulgated advisories or guidance documents issued by
federal or state governments do not have the status of ARARs;
however, where no applicable or relevant and appropriate
requirements exist, or for some reason may not be sufficiently
protective, non-promulgated advisories or guidance documents may
be considered in determining the necessary level of clean up for
protection of human health and the environment.
The selected alternative calls for the extraction of ground water
to a facility on-site for treatment and eventual discharge into
an infiltration pond. The following is a description of the
ARARs for the selected remedy and an explanation of how this
remedial action meets these requirements.
The Safe Drinking Water Act of 1974 (SDWA), as most recently
amended in 1986, requires the establishment of standards to
protect human health from contaminants in drinking water.
Maximum Contaminant Levels (MCLs) for specific contaminants have
been promulgated under the SDWA. [CERCLA §121(d)(2)(A)(i)
requires on-site CERCLA remedies to attain MCLs where they are
applicable or relevant and appropriate.] Additionally SDWA
maximum contaminant level goals (MCLGs), which are non-
enforceable health-based goals, have been set at levels at which
no known or anticipated adverse effects on the health of persons
occur and which will allow an adequate margin of safety. CERCLA
§121(d)(2)(A) requires on-site remedies to attain MCLGs where
relevant and appropriate under the circumstances of the release.
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20
MCLs and MCLGs are not applicable at the site because the aquifer
does not serve a public drinking water system. Because
approximately 49 residents drink from this aquifer through
private wells, however, MCLs and MCLGs are relevant and
appropriate. Non-zero MCLGs and, where the MCLG equals zero,
the corresponding MCL will be met by implementation of the
selected remedy.
One possible situation where more stringent standards than MCLs
may be appropriate for ground water used as drinking water is
where multiple contaminants in the ground water present
extraordinary risk, so that the single, chemical-specific
requirements may not adequately protect human health or the
environment. A risk of 1E-6 serves as the point of departure for
cumulative risk due to carcinogens that represent an excess
upperbound lifetime cancer risk to an individual of 1E-4 to 1E-6.
See Preamble to National Contingency Plan (NCP), 55 Fed. Reg. at
8713. It is believed that the cumulative risk due to the
contaminants present at the site will not, upon completion of
remediation, exceed this risk range.
Minnesota Rules Chapter 7035.2815, Subpart 4 similarly provide
ground water protection standards at solid waste treatment,
storage and disposal facilities. These standards, called
intervention limits (ILs), are not applicable because the
landfill was filled prior to the effective date of the ILs.
While ILs are relevant because they pertain to landfills, they
are not appropriate because they were set at such levels as only
those landfills designed in accordance with recent regulations
and technology can meet.
The Minnesota department of health has established health based
criteria for contaminants in drinking water referred to as
Recommended Allowable Limits (RALs). These RALs are not ARARs
because they are not promulgated. Rather, they are criteria to
be considered and are based on a cumulative risk of 1E-5.
The 1989 Ground Water Protection Act (GWPA) (Minn. Stat. 103H)
was promulgated in 1989. Implementation of the act is being
carried out by different state agencies which are currently in
rulemaking. The GWPA strives for nondegradation of ground water
or, in instances where degradation has occurred, no further
degradation. The GWPA is not applicable because cleanup
standards have not been promulgated, but is considered.
Minnesota Rule 7060 (7060) discusses nondegradation of
underground water. It is not applicable because no enforceable
standards are currently promulgated, but is considered.
Regarding surface waters, the Federal Clean Water Act (CWA), 33
U.S.C. Sections 1251, et seq., as amended, requires USEPA to
establish water quality criteria (WQC) for bodies of water based
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21
on effects of pollutants on human health and aquatic life and on
the potential or designated uses of the waters. Federal WQC are
non-enforceable guidelines used by States to set water quality
standards for surface waters, as required under Section 303 of
the CWA. WQC may be relevant and appropriate to cleanup of
surface and ground water at CERCLA sites. See CERCLA Section
121(d)(2)(B)(i). Since a.minor portion of the contaminated plume
will eventually reach Lake Bemidji, the Federal Ambient WQC are
relevant and appropriate. The National Wild and Scenic Rivers
Act (PL 90-542, USC 1271) applies to the Upper Mississippi
Headwaters Watershed. However, Lake Bemidji is exempt from the
Act.
CERCLA remedial actions involving surface bodies of water must
also ensure that applicable state water quality standards are
met. Minnesota has existing and proposed surface water quality
standards for Lake Bemidji and the Mississippi River. See MN
Rules, Chapter 7050. The existing water quality standards are
applicable. Because the proposed standards have not yet been
promulgated, they are not ARARs. Because these standards are
proposed specifically for the particular waters which may be
affected by the selected remedy, however, they have been
considered. The portion of the plume expected to reach Lake
Bemidji will not cause either the proposed or the existing water
quality standards for Lake Bemidji and the Mississippi River to
be exceeded.
(Unlike the selected remedy which calls for discharge of the
treated ground water into an infiltration pond, an alternative is
the discharge of the treated ground water into Lake Bemidji via a
dedicated discharge line. In this case, Alternative II, the
direct discharge into Lake Bemidji would require a National
Pollutant Discharge Elimination System (NPDES) permit because the
action would constitute an off-site discharge from a point
source (the discharge line) into surface water. See Section 402
of the CWA and 40 CFR Parts 122, 123 and 125. Effluent
limitations are specified in NPDES permits based on the
application of best available technology economically achievable,
or more stringent limits as necessary to achieve applicable toxic
pollutant effluent standards promulgated at 40 CFR 129, Subpart A
or to maintain applicable state water quality standards.
Additionally, the Federal Ambient WQC would have to be met. Had
this alternative been selected, these requirements would have
been satisfied.)
Air quality must also be protected in carrying out remedial
actions. Pursuant to Section 109 of the Clean Air Act (CAA),
National Ambient Air Quality Standards (NAAQS) have been
promulgated at 40 CFR Part 50. The selected remedy will not
exceed any NAAQS or emission limitations or standards under the
CAA.
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22
In addition to chemical-specific requirements, action-specific
requirements must be met. The treatment facility and
infiltration pond will be designed in accordance with Minnesota
solid and hazardous waste regulations, MN Rules, Chapters 7035
and 7045. Minnesota Statute 115.063, the State Potable Water
Protection Policy is not an ARAR because it imposes no
substantive requirements, but it will be considered because it
provides guidance as to areas in which solid/hazardous waste
facilities should be prohibited.
If the inorganic sludge that is created during the treatment
process tests RCRA "characteristic", then 40 CFR Part 268 is
applicable and the disposal of the sludge will be conducted
accordingly.
The selected remedy will satisfy all ARARs and will be protective
of human health and the environment.
3. Cost Effectiveness
An analysis of cost effectiveness of the alternative selected
indicates that the remedy chosen is not the most cost effective.
Alternative I is the least costly alternative considered, but
Alternative I does not satisfy all ARARs and is not protective.
Between Alternatives II and III, Alternatives III is the most
cost effective and also satisfies the appropriate ARARs and is
protective.
4. Utilization of Permanent Solutions
The U.S. EPA and MPCA believe that the selected remedy represents
the maximum extent to which permanent solutions and treatment
technologies can be utilized in a cost-effective manner for the
final remedy at the Kummer Sanitary Landfill Site. Of the
alternatives that are protective of human health and the
environment and comply with ARARs, U.S. EPA and MPCA have
determined that the selected remedy provides the best balance of
tradeoffs in terms of long-term effectiveness and permanence,
reduction in toxicity, mobility or volume achieved through
considering the statutory preference for treatment as a principal
element and considering the State and community acceptance.
Organic contaminants of concern will be destroyed by the AOP
process, intermediate compounds present in the effluent after AOP
treatment will be removed with GAG. Contaminants captured by the
GAC are destroyed during regeneration of spent carbon at elevated
temperatures. Although residual material (sludge) will result
from treatment of ground water for inorganic constituents, the '
material that remains can be contained with a high degree of
certainty over the long term by proper placement in an
appropriate landfill.
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23
5. Preference for Treatment
This satisfies the statutory preference for treatment as a
principal element of the remedy through extraction and treatment
of the contaminated ground water plume by AOP to achieve State
and Federal standards.
XI. ADDITIONAL STUDIES
Section 311 of CERCLA, 42 U.S.C. Section 9660 provides that USEPA
shall conduct "research, evaluation, testing, development, and
demonstration of alternative or innovative treatment technologies
which may be utilized in response actions to achieve more
permanent protection of human health and welfare and the
environment." These tasks are carried out through a program
within the Office of Research and Development (ORD).
Bioremediation is an innovative technology which involves
utilizing the indigenous microflora in the degradation of
contaminants in the ground water. Subsurface and sediment
samples are collected from the field, and indigenous
microorganisms capable of degrading the compounds of concern are
isolated and characterized. Treatability testing is then done in
the laboratory in a bench-scale reactor, and the nutrient
requirements of the microflora and gas stream composition
(percent methane in air) are determined. A pilot scale
bioreactor is then set up in the field, using the information
gathered during the laboratory investigations. The research to
date suggests that bioremediation is a technology that warrants
further study as it may prove to be a preferable alternative,
given site-specific characteristics, to those alternatives
currently available for the treatment of ground water.
If it is demonstrated that implementation of bioremediation would
be as protective of human health and the environment as the
treatment method selected in this ROD, and if the cost of
replacing the AOP treatment system or modifying the AOP treatment
system to include a biological treatment component were
desirable, then this ROD may be amended, if necessary, to reflect
such findings.
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THE C ZONE 18 ALSO INCLUDED AT *LfLL LOCATION 1
VINYL CHLORIDE. DCE. AND PCE WERE ALSO DETECTED IN SAMPLING
ROUND 8 AT WELL LOCATION 18 B
KUMMCN LANOF1U. GROUND WATEM FEASIBILITY STUDY
BOUNDARIES
nouw* t
-------
Zy— COlieCTiOM M C * D f. M
. /
250 0 250 5OO HSO IOOO
CM
CRAI-HIC SOUl IN fCtl
IU//01SC H » n C E T0/l«l(t (CUIO.II
\woomT
I PIRNIE
KUMUER LAHOFII.L OROUND WATER fS
ACTIVE DOWNORADIENT HYDRAULIC CONTROLS PLAN
FICUHE J
JUl' 19*0
-------
TABLE 1
KUMMER SANITARY LANDFILL, MINNESOTA
VOLATILES FOUND IN GROUND WATER PRIOR TO 1986
Lowest
Highest
Methylene Chloride
1, 1-Dichloroethane
1-2-Dichloroethylene (total)
1 , 1 ,2-Trichloroethane
Trichlorofluoromethane
1,1-Dichloroethylene
l-2,Dichloropropane
Vinyl Chloride.
Chloromethane
Dichlorofluoromethane
Bromome thane
1,2-Dichloroethane
1,1,1-Trichloroethylene
Oi chl orodi fl uoromethane
Acetone
Ethyl Ether
Benzene
Toluene
Total Xylenes
Tetrahydrofuran
Ethyl Benzene
1,1,2 , 2-Tetrachl oroethyl ene
Chloroform
Chloroethane
1,1,2,2,-Tetrachlorethane
1,2-Dibromomethane
Bromodichloromethane
1,2-Dibromoethane
Trichloroethylene
Methyl Isobutyl Ketone
1,1 -Di chl oro-1 -Propane
1.0
O.1
O.t
0.2
0.2
0.2
0.2
*
*
*
*
0.1
0.2
*
16.0
0.1
0.3
0.5
0.6
0.5
0.5
2.0
0.2
*
2.0
0.4
0.2
0.4
0.2
5.0
0.2
46.0
5.4
27.0
2.7
5.6
1.7
1.7
• *
*
*
*
4.2
8.8
*
100.0
60.0
3.1
6.8
8.2
130.0
8.0
16.0
2.4
*
4.6
0.7
0.7
0.7
2.8
6.0
1.8
All values in micrograms/1iter.
* If no Lowest-Highest value is given, the volatile organic compound was
detected as a peak below the detection level.
-------
TABLE 2
SUMMARY Of' EXPOSURE DATA
Chronic
Intake (CDI)
Carcinogenic
Dai ly
(mg/kg/day)
Noncarcinogcnic
Popul at inn
Res idents
Exposure Pathway
Ingestion of groundwater
that has migrated from
the site to downgradient
local wells
Skin absorption of chemicals
from ground water during
ba th i ng
Inhalation of chemicals
that have volatilized from
ground water during use
Chemical (il
Benzene
t-1 ,2-Oichloroethylene
Tetrachloroethylene
Trichloroethylene
Vinyl Chloride
Benzene
t-1 ,2-Dichloroethylene
Tetrachloroethylene
Trichloroethylene
Vinyl Chloride
Benzene
t-l,2-Dichloroethylene
Tetrachloroethylene
Trichloroethylene
Vinyl Chloride
Effects
7.35E-05
4.29E-04
1.47E-04
8.33E-05
1.15E-03
2.56E-08
I.49E-07
5.I2E-08
2.90E-08
4.01E-07
2.94E-05
1.69E-04
5.88E-05
3.31E-05
4.63E-04
Effects
I.71E-04
1 .OOE-03
3.43E-04
1.94E-04
2.69E-03
5.97E-08
3.48E-07
1.19E-07
6.77E-08
9.35E-07
6.86E-05
3.94E-04
1 .37E-04
7.71E-05
1 .08E-03
Notes:
M) Maximum concentrations detected in ground water were used
in this analysis (see Table 8-1 for values), in order to
provide a conservative exposure estimate.
-------
lABLh J
G\NCER, RISK ESTIMATES
Chemical
r-posurc Polhuoy: Ingest
:?cnlcnc
: • 1 , 2-C icM oro •
tihyl c-nc
I tt r ochl or octhyl cnc
1 .- icM oroc Idyl cnc
viiv/l CMoridc
•'.tl'.'.'\ "olh.'.iy S' in ;'
•j*-nt cnc
. • t . ?-Di(Moro-
t;hy I cnt
i t I r ocli I cr uclrtyt cnc
If KM Or OC :hyl Cnc
.'.rwl CMoridC
J*pOjUfc Pot'woy: Inhato
aenicnc
I • I . 2-OicMoro-
c:riyl C.ic
1 C 1 rnthl dose odni m s t cr cd in drinking water ( i assumed absorption fraction of 1.0.
-------
TABLE 4
KUHER SANITARY LANDFILL, MINNESOTA
COMPARISON OF ARARs AHD OTHER CRITERIA
TO BE CONSIDERED FOR ORGANIC CONTAMINANTS
Units
TBC
Pathway
Ground Water
Surface Water
Air
Notes:
NA
SWQC
TBC
MCLs
HALS
10"5,10~6
CA Risk
NPDES
AWOC
TLV
NAAOS
40CFR-268
PWOS
MCLG
PMCL
*
GUPA
Lontaminani
Range Detected Cleanup Level
1,1,2,2-tetrachloroethylene (PCE) 1.0-12 5
1,1,2-trichloroethylene (TCE) 1.0-6.8 5
trans-1,2-dichloroethylene (tDCE) 1.3-35 100
vinyl chloride 5.9-94 2
benzene 1.0-6.0 5
*
1,1,2,2-tetrachloroethylene (PCE) NA 9
1,1,2-trichloroethylene (TCE) NA 123
trans-1,2-dichloroethylene (tDCE) NA 449
vinyl chlorine NA 3.3
benzene NA 38
NAAQS
1, 1,2,2- tetrchloroethylene (PCE) NA
1,1,2-tri,chloroethylene (TCE) NA
trans-1,2-dichloroethylene (tDCE) NA
vinyl chloride NA
benzene , NA
= Not Available
MCL PMCL MCLG Ug/L
5* 0
5 0
100* 100
2 0
5 0
NPDES-Chronic SWQC Ug/L
9
123
449
3.3
38
Ug/m3
RALs ILs
6.6 1.7
14 7 Q
31 f .0
70 17
0.15 0 .037
7 3
AWQC
0.8
2.7
NA
2.0
0.66
ID'5
8
•) 7
i<
NA
•yn
C\J
6.
PUOS
8.9
120
50
7.6
38
:A .
Cancer R sk
U TLV 10"b O"6
3350 4.
2700 1.
NA NA
100 0.
300 0.
1
5
l
28 i
27 i
.41
.15
A
.02
.02
= MPCA Surface Water Quality standards for Lake Bemidjl and the Mississippi River (Minnesota Rule 7050).
* Other criteria to be considered
' Safe Drinking Water Act Maximum Contaminant Levels.
• Minnesota Department of Health Recommended Allowable Limits (1988).
» Minnesota Rules mixed municipal solid waste landfill ground water performance
= Concentration correspondence to a lifetime incremental cancer risk of 10 or
quality criteria for water 1986).
= National Pollutant Discharge Elimination System (also Minnesota Rules Chapter
* USEPA Ambient Water Quality Criteria-drinking water and fish consumption (10"
= Threshold Limit Value work-shift time- weighted average.
=> National Ambient Air Quality Standard
intervention limits (7035.2815
10 (ground water number from
Subpart 4).
EPA 440/5-86-001,
USEPA
7001 and Minnesota Statutes Chapter 115 and 116).
increment cancer risk).
* Land ban on disposal of untreated and certain liquid wastes in land-based waste management units may be appl
discussion of ARARs In Section XB).
«= Proposed Water Quality Standards for Lake Bemidji and the Mississippi River.
= Maximum Contaminant Limit Goals
* Proposed Maximum Contaminant Levels
N
V
(cable for inorganic sludge
* NPDES Permit required only for Alternate II. NPDES requirements under Minnesota law are equal to the SWOC.
= Minnesota Ground Water Protection Act, Minnesota Statue 103H is a TBC.
-------
TABLE 5
GROUND WATER COLLECTION CAPITAL COST
Ground water collection
well construction & testing S'O.OOO
well pump equipment ^10.000
Ground water collection pipeline $36,000
Miscellaneous
remove monitoring wells S50,000
Land Acquisition(1' S40,000
SUBTOTAL CAPITAL COSTS $206,000
CONTINGENCY Q 25% $51,500
ENGINEERING 0 20* $41,200
TOTAL CAPITAL COST $300,000
GROUND WATER COLLECTION OPERATING AND MAINTENANCE COST
Annual Cost Item
Maintenance Materials & Labor
15% of Equipment Capital Cost $1,500
Auxiliary Materials and Labor
Electricity<2) for Ground $2,500
water pumping
Purchased Services
Water Well Analysis(3' $15,000
Insurance, Taxes & Licenses $15,000
5% of Capital Cost
SUBTOTAL ANNUAL OiM COST $34.000
CONTINGENCY 0 251 OF ANNUAL O&M COST $8,500
TOTAL ANNUAL O4M COST $43,000
PRESENT WORTH OF O&M COST'") $410,000
PRESENT WORTH COST $710.OOP
(1) Based on $2,000/acre
(2) Based on S0.08/kwhr.
(3) Based on annual ground water sampling for HSL volatiles,
metals, convential parameters.
-------
TABLE 6
r.U««ER UHOFILL. MIKNl'SuU
SOffENIHG/AOP/ACHVATED CAR80K IREAIMENI
CAPITAL COST ESTIMATE
.'CAPITAL CUSfS IKORGAHICS R[«OV4L
,'lne
; Metering Feed Puip
I Rapid Mi: tanks
; Mechanical Miier
,'Solids Handling Equipient
; Clarifier l Internals
; Centrifuge
,'C02 pH Adjustient Srstei
I Sparger
; pH Probe
,'Polr.ier feed Srstei
! Mixing Tank
; Metering feed PUIP
.'filtration Srstei
I Multi-Media Pressure Sand filter
,' Backwash Tank
,'Puips
,' Pressure filter (2
! filter Backwash (I
; Sludge PUIP (2)
,' Centrifuge filtrate (1)
I filter Backwash Tank (1)
iPiping t Valves I 10Z
JElectrical 4 Instruientation ! 101
FOUL COST
SbO.OOO
$50,000
:j7s,ooo
510,000
$10,000
58,000
JS.OOO
$8,000
{4,000
18,000
{2,000
5?,000
J23.000
{25,000
Cdr> Huebnpr
Gary Huebr.er.KAHCON
fen Lindgren.Bird Machine Coipanr
Jeff Hughes, Bob J. Johnson ( Asscc.
iSUBTOMl COKSTRUCTIOK COS!
,'COHTIHGENCY t 201
!COHrRACrO(! OVERHEAD & PROFIT ( 101
!ENGINEERING t 151
•TOTAL CAPITAL COST
{278,000
{55,600
{27,800
{41,700
{400,000
ICAPITAL COSTSrORGANlCS REMOVAL
Generator Srstei
! Air Drrers/filters
I Oiffuser
! Power Supply
! 0;one leak Monitor
! Packed Coluin 0;one Oecoiposer
! Start-up and Training
.'Hrdrogen Peroiide Systei
! Hrdro9en Peroiide Storage Tank
.' Metering feed PUIP
.' Oiffuser
!0/one Contactor
,'CartfOn Contactor
.'Initial Carbon (20,000 Ib)
.'Piping t Valves t 101
.'Electrical I Instruientation > 10:
.'Site«orl
'foundat ion
'Building
Total Cost
Source
{90,000
Jerry 6rut»er. Griffin Technics,Inc.
{10,000
510,000
{50,000
{10,000
516,000
(16,000
5?,000
510.000
$90,000
Pulsafeeder
SUBTOTAL COHSIRUCriOK COS1
;'COKTIHGEKCT ! 201
COKIKACTOR OVERHEAD ( PROFII ( (01
[K6INEERIHG ( 151
!OUL CAPITil COS1
5505,000
561,000
550,500
$
-------
TABliE 7
CUMMER UHOfllL. MINNESOTA
SOnCNING/AOP/ACMVAIED CAREOH fREAIMEMl
otM cosr ESTIMATE
;or:ni!is( CYSTS iNORCi1--.'':' -f-ovii
!Po«er
lLabor
[Maintenance Materials t 51
Iliie
[Carbon Dionde
[Polymer
iSolids Disposal
I Monitor ing
,'Insurance, fares, S Licenses < 51
,'SU8 TOTAL ANNUAL Oi« COST
1COHIIN6ENCY t 251
,' TOTAL AKHUAL OtM
JPRESENI KORTH Ot« (J)
t
!OPERAIIN6 COSfS:ORGANICS REMOVAL
(
1
I Poner
! Labor
maintenance Materials t 51
iLiquid Phase 6AC (0.10 lb/1000 gal)
jKrorogen Peroiide
i
iMonitoring
[Insurance, [ares, I Licenses ! 51
i
! SUB TOTAL AHNUAL Ol« COSI
ICOHTIKGEHCY ( 2SI
i TOTAL AHHUAL 04H
! PRESENT WORTH 04« (l)
1
UVh'S
(WHR
HOURS
L6S
L8S
IBS
CT
UNITS
im
HOURS
L8S
L8S
OUiNI! IT
2000
220,000
7,000
1.000
400
OUANTITr
2.000
6,000
16,000
UKII cost
$0.08
$25
$0.05
$0.40
$2.50
$200
IS
UNIT COST
{0.08
J2S
tl.OO
JO. 50
LS
: iiMti cosr
$10,000
$50,000
$11.500
$11,000
$2,800
.. $3,000
$80,000
$30,000
$20,000
{218,000
$55.000
(270,000
$2,500,000
TOTAL COST
$13.000
550,000
$8,000
(6,000
(8,000
$30,000
(22,000
(157,000
(34,000
(170,000
(1,600,000
HOTES: m Present north cost based on 30 year project life and 101 discount rate.
Coluins lay nol add due to rounding.
-------
TABLE 8
GROUND WATER DISCHARGE COST
Capital Cost . $230,000
Excavation
Erosion control
Pumping
Annual O&M Cost $29,000
_«•»«•
-------
APPENDIX A
RESPONSIVENESS SUMMARY
-------
RESPONSIVENESS SUMMARY
RUMMER SANITARY LANDFILL
OPERABLE UNIT 3
I. RESPONSIVENESS SUMMARY OVERVIEW
In accordance with CERCLA Section 117, the United
States Environmental Protection Agency (U.S. EPA) and
the Minnesota Pollution Control Agency (MPCA) recently
held a public comment period from July 24, 1990 to
September 5, 1990, for interested parties to comment on
U.S EPA's and MPCA's Proposed Plan and Feasibility
Study for addressing the ground water contamination
problems at the Rummer Sanitary Landfill. At a public
meeting held on August 9, 1990, MPCA and U.S. EPA
presented their Proposed Plan for the Kummer Sanitary
Landfill site.
Based on the findings of the environmental
investigation, the MPCA and U.S. EPA have selected a
remedy for ground water contamination related to the
Kummer Landfill Site involving a ground water pump and
treat system with discharge to an on-site infiltration
pond. The selected alternative includes an advanced
oxidation process for treatment of organic
contaminants. An additional study will be completed to
determine if in the future bioremediation may be a more
feasible treatment process.
The purpose of this responsiveness summary is to
document U.S. EPA's and MPCA's response to comments,
criticisms and new data received during the public
comment period. All of the comments summarized in this
document were considered prior to U.S. EPA and MPCA's
final decision.
II. BACKGROUND AND COMMUNITY INVOLVEMENT
Under a cooperative agreement with U.S. EPA, the MPCA
has conducted a community relations program for the
remedial investigation and feasibility study. This is
the final of the three operable units in this
investigation to reach the Proposed Plan stage, so the
public in the area has by now seen a number of news
stories and been invited to several public meetings in
connection with the site over the last few years.
At the conclusion of the remedial investigation for
this operable unit, a fact sheet on the findings was
distributed to local media, interested parties, and the
information repository. A news release announcing the
findings was also sent to local media. During this
-------
time, the location of the information repository was
changed from the library at Bemidji State University to
Northern Township Town Hall, in response to complaints
about the hours of access and availability of
documents at the former location. This change was
announced by news release and a letter mailed to
interested parties.
Two months after the completion of the remedial
investigation, the Feasibility Study/Proposed Plan was
completed. A 30 day public comment period and public
meeting were announced through a newspaper
advertisement in the Bemidji Pioneer newspaper, and
also by new releases to local media. A fact sheet on
the Proposed Plan was again distributed to local media,
interested parties, and the Information Repository.
Additionally, a letter was mailed to interested parties
to make sure they were aware of the meeting date and
location. Copies of the Proposed Plan were made
available at the information repository. The public
meeting was held August 9, 1990 in Northern Township.
1. General comments
Several commentators questioned how the movement of the
groundwater and the chemicals in the ground water were monitored.
Response. Ground water in the area of the landfill flows
generally eastward, and discharges into Lake
Bemidji. This is determined by using monitor
wells. The elevations of the wells above sea level
are surveyed. Then the depth to water is measured
for each well, and the elevation of the water
table is determined for that location. Generally,
ground water flows from higher to lower
elevations; the water table elevation at the
Kummer site is higher on the west side than the
east, so ground water flows from west to east.
Movement and concentrations of chemical
constituents in the ground water are monitored by
collecting ground water samples from monitoring
wells. These samples are collected using
stringent quality assurance/quality control
procedures, and then sent to a laboratory for
analysis. Analytical data is reviewed to determine
changes in concentrations of chemicals in
individual wells that may have occurred since the
last sampling event.
Several commentators asked what precautions were taken to assure
the treatment method is destroying all the harmful compounds in
-------
the ground water.
Response. Regular monitoring and sampling of the treated
ground water will be an integral part of the
remedial action. If at any time it is
demonstrated that the treatment process is
ineffective, prompt corrective action will be
taken to assure effluent will meet cleanup
standards.
Ground water modelling has indicated a portion of
the contaminant plume will not be captured by the
extraction well system and will eventually
discharge to Lake Bemidji. The modelling has
indicated, however, that this discharge will be
well below Surface Water Quality Criteria.
The US EPA commented that one table included in the Feasibility
Study Report contained incorrect data. In Table 2-2, the maximum
contaminant level (MCLs) of 5 ug/1 for 1,1,2,2-
tetrachloroethylene and 100 ug/1 for trans-1,2-dichloroethylene
should be shown as proposed MCLs and Safe Drinking Water Act MCLs
are relevant and appropriate and, therefore, should be eliminated
from the list of "other criteria to be considered" and identified
as an ARAR. While Proposed MCLs are only to be considered they
have been selected as the cleanup level for 1,1,2,-
tetrachloroethylene and trans-1,2,-dichloroethylene as the most
appropriate standards because the water is used for drinking
water and if cleaned up to this level, it will not pose a
substantial present or potential hazard to human health and the
environment; rather, this level is protective of human health and
the environment.
Response. The corrected table is part of this responsiveness
summary and Table 4 of the ROD.
2. Treatment alternatives
Several commentators had questions regarding specifics of the
proposed additional study on bioremediation, such as what it will
cost, how long will it take, and how does bioremediation work.
Response. Bioremediation is considered an innovative
technology. At the present time there are no cost
estimates on how much bioremediation would cost at
the Kummer Site. It is anticipated that to fully
study the cost-effectiveness and protectiveness of
bioremediation treatment at the Kummer Site may
take two to three years.
Bioremediation makes use of naturally occurring
microorganisms that use the contaminants of
concern a food source. However, in their natural
state they usually aren't present in sufficient
-------
number to have much of an impact. So, in
bioremediation, nutrients and oxygen are added to
help the microorganisms multiply. Bioremediation
is discussed in more detail in the Feasibility
Study and the ROD.
Two commentators stated that chemical treatment was not
appropriate at the Kummer Site because 1) one of the main
contaminants (vinyl chloride) can not be removed with granulated
activated carbon (GAC); 2) chemical treatment is less cost
effective than bioremediation; and 3) chemical treatment creates
a sludge, which only transfers the problem and does not solve it.
Response. Advanced Oxidation Process is the main treatment
and is effective for the removal of vinyl
chloride. The GAC will be additional treatment
used to "polish" effluent from the treatment plant
prior to discharge to the infiltration pond.
Because bioremediation is considered an innovative
technology, there are no cost estimates available.
Two or three years will probably be needed to
fully study bioremediation at the site.
Sludge that will be produced during treatment will
be from treatment of inorganic constituents while
the Advanced Oxidation Process or bioremediation
treatment will only destroy the organic
constituents. Inorganic treatment may be needed
regardless of the organic treatment process.
One commentator inquired whether the bioremediation studies would
be an additional charge to Potentially Responsible Parties
(PRPs).
Response. Currently, the Agencies are investigating funding
for the bioremediation treatability studies
through the U.S. EPA Office of Research and
Development. If a PRP agrees to implement the
selected remedy for this operable unit they will
be given the opportunity to participate in the
study.
One Commentator recommended not to let the bioremediation study,
proposed as an additional study, delay the start up of remedial
action.
Response. The bioremediation study will not interfere with
the implementation of the selected remedy. After
a negotiation period with any potentially
responsible parties, design of the remedy will
commence. If the proposed additional study
demonstrates that implementation of bioremediation
is favorable, then the ROD may be amended to
-------
reflect such findings.
One commentator asked how can we be assured that the northern
part of the contaminant plume won't move farther north.
Response. The predicted plume migration is based on a ground
water model that took into account the properties
of the soil and ground water flow for each well in
the northern part of the plume. The model also
incorporated the properties of the chemicals of
concern and how they interact with the soils to
determine how they would move in the ground water.
Three commentators recommended Alternative I as the preferred
remedy because of previous actions undertaken at, or planned for
the site (i.e., the installation of the water distribution system
and the planned capping of the landfill) .
Response. Alternative I is not protective of human health
and the environment and does not satisfy ARARs.
The Safe Drinking Water Act Maximum Contaminant
Levels must be complied with because residents are
currently drinking water from the contaminated
aquifer. Selection of Alternative I is
inconsistent with CERCLA and the NCP.
Three commentators asked how much water will be pumped out. They
also expressed concern about any negative affects the selected
remedy would have on private water wells, natural springs and
wetlands in the area.
Response. Using numerical computer ground water modelling it
is estimated that five ground water extraction
wells will be needed with a total discharge
ranging between 8,000 and 16,800 gallons per day.
An aquifer test completed during the remedial
investigation showed each extraction well would
not have an influence beyond a 150 foot radius of
influence for each well. In other words, the area
of influence by the wells would not extend even
eastward to Irvine Avenue. No natural springs
exist in this area, and most private wells have
been abandoned in this area. Additionally, the
modelling did not indicate any wetlands would be
adversely affected.
One commentator asked how long will it be necessary to pump the
ground water to before it is cleaned up.
Response. Cleanup of the ground water may take anywhere from
four to thirty years dependent on the
effectiveness of the Landfill cover which was the
remedy selected for Operable Unit 2. Once
-------
monitoring has demonstrated that the ground water
has reached cleanup levels, additional monitoring
will still be done at least once every five years,
as required by CERCLA, since waste will be left in
place under the landfill cap.
One commentator pointed out that if the infiltration pond is
placed close to the landfill, the possibility exists that a
"short circuit" of the extraction well system would occur,
resulting in treated water being re-pumped and the contaminated
water getting away.
Response. The placement of the infiltration pond has not
been defined. The on-site location shown at the
public meeting and in the FS was for conceptual
purposes only and was not intended to represent
the actual placement. Placement will be
determined after further study of soils and pump
capacities so that infiltration will not interfere
with capture of contaminants.
One commentator asked how capping of the landfill will prevent
further degradation of the ground water.
Response. Presently, rain and snowmelt percolate through the
landfill and carry contaminants down into the
ground water. A permanent cap would halt most of
this process. Further, the water table under the
landfill is slightly elevated because the surface
of the landfill itself is higher than the
surrounding area. With the cap in place, the water
table elevation should become lower and this would
effectively remove waste in the landfill from
direct contact with the ground water.
One commentator asked if there will be monitoring wells in the
landfill.
Response. Currently there is one monitoring well in the
landfill itself (well 16A). This well has shown
that the center of the contaminant plume is at the
east edge of the landfill. There are numerous
monitoring wells around the landfill and in the
path of the plume, and the MPCA will continue to
sample some of these wells on a regular basis
throughout the period of remedial action.
Several commentators asked what are the potential negative
effects of Alternative III and whether a possibility exists that
hazardous waste may be produced at the site.
Response. Alternative III provides overall protection for
human health and the environment because
contaminated ground water is removed and treated
-------
to drinking water quality standards. Organic
contaminants of concern will be destroyed by AOP
and inorganic compounds will be removed by
chemical treatment. There is a possibility that
there may be some hazardous waste generated during
the inorganic treatment process which produces a
sludge, but this will depend on the concentration
of the compounds in the plume and the volume of
the contaminated ground water. This sludge will be
disposed of in accordance with waste disposal
regulations.
One commentator asked if the job is done when all the components
in the plume meet the standards of potable water.
Response. It is desirable to clean all components in the
plume to meet drinking water quality standards.
It may require ten years to meet those standards.
One commentator noted that barium was the only inorganic compound
that exceeded the acceptable levels and asked what will be done
with barium sludge if they are generated.
Response. Barium will be removed by the chemical treatment
process by means of pH elevation and
precipitation. Any sludge that is produced at
this site will be disposed of at an appropriate
landfill.
One commentator asked why the Rummer site was being singled out
for cleanup when there are other dumps in the area that are not
being cleaned up.
Response. In 1982 and 1983 MPCA sampled groundwater from on-
site monitoring wells and found nineteen volatile
compounds (VOC's). The VOC's were found in the
down-gradient wells while the up-gradient wells
were uncontaminated, indicating groundwater
contamination as a result of the landfill
operation. Based on this information the site was
included on the Superfund National Priorities List
in May 1986. MPCA has an ongoing monitoring
program that looks for potential sites that may
pose a risk to the environment and human health.
One commentator pointed out that it was stated the chlorinated
compounds would be broken down into carbon dioxide and water by
the treatment process, but it was not indicated what happened to
the chlorine molecules.
Response. After destruction of the chlorinated compounds the
chlorine molecules will occur as free ions in the
water, well below drinking water standards and
therefore will pose no significant threat.
-------
TABLE 1
Summary
September 5, 1990
August 9, 1990
July 31, 1990
July 29, 1990
July 24, 1990
May 15, 1990
May 25, 1989
May 23, 1989
December 8, 1988
of Community Relations Activities
Operable Unit 3
Public Comment Period closes
Public meeting regarding FS/Proposed Plan
Reminder letter to interested residents
regarding upcoming meeting
Publication of newspaper ad regarding public
comment period and public meeting on
FS/Proposed Plan
Fact sheet and news release regarding
FS/Proposed Plan (mailed to local media and
interested parties)
Fact sheet and news release regarding
results of RI (mailed to local media and
interested parties)
Letter to Northern Township clerk regarding
update on overall investigations
News release regarding start of Ground Water
RI (mailed to local media and interested
parties)
Letter to Northern Township clerk regarding
on overall investigation
March, 1986
Community Relations Plan for Kummer
Landfill site
-------
APPENDIX B
ADMINISTRATIVE RECORD INDEX
-------
1J< !«. I
I/O 1780
less/ma PICK
1 00/00/00
2 oo/to/oo
mm
mutt suimt
man, mnson
tint
Letter responding to
request fcr iafcrtatita
IQtBOR
D.DeScflane
Letter couenting/on . U.frictler
plan and specificities!
far rater distribution
sfstei
mmw
S.Riser
Docmir tm
Correspondence
Correspondeaee
7 00/00/00 Respoase to re?o«st for P.Iorjren.ittoriKf
4 81/12/08 Letttr retSolid Haste S.Hejer
Disposal lacilitj, 51-31
MM
C. loner
Corrtspoodeoce
Cflrrsspoadeacf
84/01/17
84/05/31
teiponse to re?o<5t for O.Io«
ioforiitioo
Letttr to poteatiallf L.faom?
responsible partf, trios-
revest for info.
Letter to poteotiallf L.fiorri?
respoasiiie partf, traos-
request for info.
7 84/flS/Jf-
7 84/J5/31
7 84/95/31
Letter to potentiaiJf L.foorri;
reipoosible pirtf, tnos-
ilttiuj refoeit for info.
Letter to poteotialJf L.faomy
respoosiile pirtf, trios-
littioff refaett for info.
letter to poteatiillf L.foorri;
reipoaiioie pirtf, trios-
•ittlflf refocit for info.
MCI
I.Peterson
Lint It
Beiidji mi
Sttidji State
ffairersitf
O.Crepem/lrctic
foterpr.
Correspoadeaee
Correspoadeoce
Correspondence
Correspoadeoee
Correspoadeaee
Correspoadeoee
7 84/05/31 Letter to potential^ L.foorri;
respoosiole partf, trans-
lating revest for info.
7 84/05/31 Letter to poteatiallf i.fnorrif
respoasiole partf, traas-
littins revest for lofo.
D.De5enane
OJofOover
Correspoadeaee
Correspoadeaee
7 84/05'31 Letter to poteatiallf L.fiorri?
D.lficns
Correspondence
-------
:ai/nm PUSS
nni
responsible partf, trans-
littia? request for info.
muismrm MCORD um
mm siiimr uiomi
mim, fiffrsori
JIOT0JI
mmir rm
/ 34/05/3]
7 84/05/31
7 84/05/31
7 84/05/31
7 84/05/31
7 84/05/31
letter to pateotiaiif L.fborriq
rtipoosiblt partf, traas-
littio; re?aest for info.
letter to potential.^
respossiiJe partf, traos-
revest for iofo.
Letter to poteotiallr L.fAorri;
respoosifile partf, trans-
littia; re?aeit for :afo.
letter to potential!? L.fiorfiff
responsible partr, traoj-
re?aest for lafo.
Letter to potential]? L.roorri?
responsible partf, traos-
littio; request for info.
Letter to potential!? L.foorri;
responsible partf, trans-
tittin; request for info.
Letter respoadiay to
letter dtd 5/31/84 and
request for infonation
.Peterson
f.ifaas/ffaas Printing Correspoadeace
S.5tereos, Coca-Cola Correspondence
G.Srensoa
Correspondence
tfa^aetic Peripherals Correspondence
III Sottlin;
O.fitre
Correspondence
Correspondence
Correspondence
2 H/9S/9S
7 84/0*711
84/0f/13
84/0f/15
84/OJ/18
Response to revest for IMS Printing
jnfonatioa
letter to potentiallf JJ.Lnpin
respoulole partf, trans-
revest for info.
0.litre
r.flondelinyer
Response to revest for e.5terens/Coca-Cola Co. S. litre
infonation
Response to revest for ff. lei/lei Bottliag Co. 0. litre
infonatiofl
Letter in reoard to f.faectejeudji State
conrersation rito recipi- ffnirersitf
ent concerning disposal
of vaste 6f author
Correspondence
Correspondence
Correspondence
Correspondence
Correspondence
-------
i;.
icti/nm ftsss DATS
mono itou
mm sjiirm HID/ILL
BWDJI, mitsori
TITU
wnn
rm
Docwm
H/OS/22 farioai letters to
Jeiidji
residents, re; resoles at
residential tell stifles
resirfents Correspondence
H/06/29
S4/OS/2J
Response to revest
for iiforiation
Letter responding, to
infonatjoo request
f.Dornorer
J.Petterson
ietter responrfifl? to R.raiser
request for iaforiatioo
fl.liJcre
D.litre
Correspondence
Correspondence
Correspondence
M/07/IS
H/07/U
H/07/18
Letter responding to C.5»enson
re?oest for inforntion
Letter respoadin? to f.DondeJinyer
request for inforntion
Letter infoniny
recipient
of fteteriination of
re?ardio? toe ase of
;roand
rater; ateacaieot
R.Iapio
IfCi
fail Stari
Correspondence
Correspondence
Correspondence
44/07/18
Copf of Letter sent to
5Jtari
S.Lapin
farioos Letters to
Minnesota
reiideotf, infoninj tnei
tilt parties it S
reiittteti
ia Itnhtn foroioip aare
oeeo adrised if II Oept.
of
ffealtn to discontinue ase
of tneir prirate rells as
a
rater supply
f.falitorsti
lafor Donjlas
Peterson
Correspondence
Marions II residents Correspondence
84/07/3(1
Letter reJe^aest for S.flassep
Seiidji
Correspondence
-------
•:t Ha.
to
csi/mis nets DATS
1 84/07/31
J 84/08/02
j 84/08/02
5 84/08/02
1 84/08/05
umiismrm HCORS
mm saiirm mot ILL
BSSIOJI.
rim
Intonation - recipient
hid not responded as of
date of tnis letter
Letter re-.response -to
request for intonation,
asking for additional
intonation
Letter stating tnat
recipient nerer responded
to intonation request
Letter retRequest for
Intonation
Letter reitarner Hfg.
Coipanf
(response to request tor
intonation)
letter re.-larner Hfg.
Coipanf -responding to
request for infonatioa
HUTBOR
fl.iapin
R.iissej
T. Butler
G.Panallo
KSCItlStT
R.laiser
S.Creeeau
O.lichs
mi/L.thoriiq
mi/l.Tborrig
DOCWIT Till
Correspondence
Correspondence
Correspondence
Correspondence
Correspondence
Dociums
84/08/27 Letter re:Request tor
Info.
fi.falser
S.Iopifl
Correspondence
9 84/12/06 Letter to G.Reese,Hero R.lupin
*"' Ski atg.,transtitting
5/31/84. request for into.
ant toilet-up letter
dtt.t/2/94 stating no
response ns receired
4 84/12/21 Letter to potentiilif S.Lnpin
responsible ptrtj, tnns-
ilttiag cifoeit tor into.
f 84/12/21 Letter to potentiallf 1.Lupin
responsible partf, trans-
sitting request tor into.
5 84/22/21 letter to potential!? R.Lupin
responsible party, trans-
titling request for into.
S.Reese
Correspondence
Ottertail Poter Co. Correspoodeoce
S.Berf/Coester B
-------
icssmm M«S om
6 at/12/21
SI/12/21
7 84/12/21
7 84/12/21
7 84/12/21 '
7 84/12/21
7 84/12/21
84/12/21
ABKIIlSTWin RSCORD IIDSI
mm siiimr momi
BUIBJI, KI1HSOTL
rim
responsible partf, trans-
littin? rtqatst far info.
Letter to potsntiallf R.
responsible partf, trans-
littjno revest for info.-
potentiallf X,
partf, trans-
re?nest for info.
Letter to potentiallf R.
responsible partf, trans-
refoest for info.
Letter to potentiallf fl,
responsible partf, trans-
littjn?. revest for info.
Letter to potentiallf 8,
responsible partf, trans-
littiny revest for info.
Letter to potentiallf K,
responsible partf, trans-
re?oest for info.
Letter to potentiallf R,
responsible partf, trans-
littioff rejaest for info.
Letter to potentiallf i.
responsible partf,trans-
littin; revest for info.
Lopin
Lapin
Lapia
Lapin
Lop:n
Lapin
Lapin
Lapia
uanut
Mcnm rm
Co.
J.Ooran
B.Lovtn
Pipeline Correspondec:e
Correspondence
Correspondence
Btudji Sign
Correspondence
Seiidji felders Correspondence
5npplf
0. filters
Correspondence
DOB foe's Sanitation Correspondence
Src.
f.Status
Correspondence
DOCIQKSU
7 84/12/21 Letter to potentiallf R.Lnpin
responsible partf, tnns-
littiag revest for info.
7 84/12/21 Letter to poteotlallf S.Lopio
responsible pirtf, trans-
littin? revest for info.
Jooionesoo's Inc. Correspondence
faliner ffoies Correspondence
7 84/12/21 Letter to potentiallf R.Lopio
responsible partf, traas-
littina re?aest for info.
fortn Central Door Correspondence
84/12/21 Lst:er to potentialif fi.Lopin
lartfi Central
Correspondence
-------
iff; Ho.
:css/mu PISSS am
7 84/12/21
7 84/12/21
7 84/12/21
7 84/12/21
mitismrm RSCORS
mm suimi LUOIILL
unison
TIILI MTM
responsible party, trans-
littiflj request for into.
Lstter to patentiaiif R. Lupin
responsible partf, 'trans*-
r(?o«5t for iafo.
Letter to potsntialJf Ji. Lapis
r«spoasi4J< partf, traas-
r^aest for iofo.
Letter to potentially K. Lupin
responsible partf, trans-
request for info.
Letter to fotentiallr fi. Lupin
Responsible tartj, tra&s-
titting reqaest for into.
sscinnr
DOCUUIT TIPS
Paaelbaari Correspondence
Co.
fit's
R.Loctner
Shop
Carrespoadeflce
Correspondence
Spaoldiofl Xotors Correspondence
oocmm
7 Si/12/21 Letter to potential!? J.Lnpin
responsioie partf, trans-
littin? re?nese for info.
7 34/11/21 Letter to potential? J.Lopin
responsioie partf, trans-
ilttin? revest for info.
8 34/12/21 Letter to potentiaiir LLap in
responsioie partf, trans-
^ tittin? revest for info.
ffnited Bid?. Centers Correspondence
?.rittin;er
S.Lfian
Correspondence
Correspondence
84/12/21 Letter transiittinj copf f.Lopin
of
revest for infonation
and
foiiot-op iitter statin?
toae recipient nerer
resptotfed to refneit
84/12/21 Letter rtifablic leetinj; f.jloosnar
lortiern forosoip
S.IaJef/irror Correspondence
tnntinq
J.Lapin
Correspondence
84/12/24 Response rt- rt^eaf Jferton Larsen
for inforial.fyir*.-v
84/12/28 Letter re:l.fo»nsnip S.fliner
Ground Vater
Ltderald
Correspondence
Correspondence
-------
:.- *:. '
3 >..-30
csi/mits PHIS BITS
1 84/12/21
I 85/01/07
2 85/01/09-
I 85/01/09
18 85/01/15
Aotuismtm mm rim
tOMMES SUtmi U101ILL
BSHIOJI, mmson
tins
(response to letter
frit recipient dtd
12/21/84)
Response to request tar
intonation
Response to request tor
iotortitioo
Letter responding to
request tor into.
Response to Request tor
Intonation
Letter reslleetings of
l/10/85;Centnl rater
Supply
feasibility
Stndr.Iortbern
Tornship. Attiebtents
MTBOR
RtCIPISH
Eetidji telters Jopplf SPCA
•Inc. •
D.Schnell/Sorth Central R.Lupin
Dotr Co.
k.Donn/Donn Coipinj R.Lapio
P.Linlier/ODC, Inc.
t.Rousnir
R.Lupin
mi
Correspondence
Correspondence
Correspondence
Correspondence
Correspondence
85/01/16
85/01/ia
85/01/18
85/01/18
85/01/18
Letter confining LLindihl
eitention granted tor
response to into, request
Letter responding to S.Slein
request tor intonation
Letter responding to f.Iltio
request
for into.
IStitn,Carpenter,Sentnoof
i
Ilein Lu Qttien, on
Malt
otletidji Sign Co.)
Jeipoaif to reqvtit for I.ri
-------
JfO. J
PISIS nn
rim
RtcoRo imi • mun n
mm suimt LUOIILL
BUIDJI, IIIHSON
Rtcimir
oocmir im
MCJUHBSR
10 !0/08/22 Coueat ofl Proposed
Plia
Sebbiri. A., P.S.
Birr Sagiaienag Co.
fribble, KPCI
Corr«spond«ac«
1 90/Oi/iO Coueat oa Proposed
Plao
ff. f.S.,Pi. J.
Professor of Jurir-
Correspondence
J 90/09/95
Coueoc ofi Proposed
Plan
SceiJ, 5., P.i.
of ieiidji
Soroeff, IfPCI
Correspoodeace
SO/09/05 Coiieoc oo Proposed
Plao
iTolsJci, C., Leoaard,
Street aod Deioard
PriOflJe,
Correspondence
90/09/05 Coiient OB Proposed
Plan
Jacfoes, *., P.J.
Daies 4 Jfoore
Priioie, L,HtCi Correspondence
80 Jff/08/22
Paoiie leetjo;
On fS/PP for
Sroond facer
Contaunacion
Minnesota Pollution fauer landfill fraascnpts
Control Iqtacj, Saperfand
mn
2 90/ti/2S
Jfeio re.- 5orface
facer Poajjtf
Standards for Late
Bnidji Hatter
Laadfiii)
SoderoecJt, I.,
linoesota PoJJatioa
Control ijencr
, A.
Jeioraodai
Saperfand Proyrai
Propsied PJio
Crowd Ticer ffuic
Jeports/SCadies
180
leport IS
for Srosad facer
Operatic ffait
faner Saoicarr
Landfill
(Talcoi Piroie
inrironiental
Engineers Scientists
aod Piaooers
Minnesota Poliation Jeporcs/Scodies
-------
iff »:.
:.0'./so
'.ess/ma ftGis nn
MCOW IIDfl
mm suimr LMDIILL
i, sinsson
rim
Pat'i
Sodf Snap is oovillin? to
respond ontil fortner
docuientation is prorided
wcjpinr
DOCUUJS
1 85/01/18
2 85/01/18
3 85/01/21
flespoos* ca r
-------
css/mm ness BITS
rini
8KOSD 11011
mm
, mnson
HCIPIUt
Docwiir rm
2 85/02/07
letter to revest for
infonation
Sits
Correspondence
2 85/02/07
2 85/02/07
85/02/07
1 $5/02/10
1 85/02/J8
2 S5/02/22
Letter re:Jei?aest for
Icforiatioa froi
Sign Coipaof
Letter re^eifnest for
lofonatioo froi Pat '5
Sftop
Sits
B.Liodjef Sin
l.fJine
Correspondence
Letter re.-l!e?oest for S.Siis/Special isst.
lofonatioi froi Cfiester Itt.GeoeraJ
fiery Sotors
Response to revest for Pine Ridye Serrice
iofonatioo
Letter expressing sopport r/orsetti
of grant application lade
of f.fornsnip for a mer
distribotion srstei
Letter froi Seiidj:
resident,
re?ardin? a possible
solution
to tne rater
contaiinatioo
problei
f.Conraf
l.fline.attoroef Correspondence
I.Hine
1PCI
8.Lupin
Correspondence
Correspondence
Correspondence
J.Stranaelaad Correspondence
j 85/02/25 Letter transiittina i 8.Scott Lopin
snuarf table of rolatiie
oryinic afdrocarbon
dit* froi IPCl'i residen-
tial saiplin?
Correspondence
2 85/03/14 Letter responding to fat's Bodf Snop
re?oest for infonation
4 85/03/18 Response to infonation N.flein
regoest
j 85/03/21 Letter responding to
regoest for infonation
tm
8.Lupin
S.Lupin
Correspondence
Correspondence
Correspondence
-------
•?• He. 10
01/30
css/ram nets om
rim
umnsnuin MCOM now
mm suimr LUOIILL
BSHIDJI. unison
ascmsit
socnur rw
oociumt
2 85/03/21
Letter notifying
recipient
of proposed soperfond
project
Ltastj
Correspoodjflce
1 8S/W26
Letter
recipient
of proposed superfand
project
Letter responding to f.
request for infonatioa
R.Werold
Correspoadeoce
Correspondence
4 55/03/28 Response to request for l.fieia, ittornef ffPCi Correspondence
infortacion
^.flein, attorney on
benaJf of Cnester fierj
Motors/
j 35/03/29 Letter recardin? fortnern tfPCi J-StaoseJand . Correspondence
fornsnip Sroond later
Ccntaunation
1 85/03/25
Letter re.-Iortoern
fornsoip
Letter re.-Sroond facer
Contaunatioa
(response to letter froi
recipient/
Jt.Lopio
S.Iicnol
Correspondence
7 85/04/04 letter responding to i.5tanjeland
correipaadeflce receired
tin recipient
r.falitorsti
Correspondence
5 85/04/05 letter responding to f.falitofsti
revest for infonation
i.Stanieland
Correspondence
6 35/04/19
Letter respuYdi'aff'
revest for infocl*«ao *
fi.Boscnritz
Correspondence
8 S5/04/19 Letter responding to r.faJitorsti
C.Darfnberffer Correspondence
-------
:ss/mu PAHS DATS
mmsmiut
ami suimi IUDIILL
BSSIDJI, KflfSOM
rim
revest, for Jnfonation
KKltlllt
tm oocirem
3 8S/0
-------
?• Ho. 12
css/mns mis
IIDSI
mm suimr LAID/ILL
stum, wmsofa
nut
iffffOR
oociwur mi
1 85/10/K
Letter
re.'fleioral/fleiedial
Action Contract vita IfPCJ
L.fflom?
S.Sfctian
Correspondence
1 85/1U/17
J 85/11/18
Letter re.-Iortbern
Contract
Letter translating.
nerspaper articles-'PCJ:
lortbern sboold sbare
rater
cost' and 'Landfills
expected
to be scarce of future
ground-
rater contaiination*
f Joosbar
L.fbomff
SJiner
Correspondence
Correspondence
1 85/11/25
Letter responding to
ingoirr of 11/12/85
public
itetin;
B.felsoo
S.Serqlusi
Correspondeaee
S SS/fll/23
1 96/02/21
86/03/04
Letter re Heftiest for
Infonation, fnuer
Sanitarf
Landfill Inreitijation
5Jiner
S.Iensler/Hensler
into
Response to refoeit for B.Eensler/ffensler's into SJiner
inforiation Sopplf
Letter trifliiittia? reio- I.BcCordf
lotioi rejirdiu?
f.rontllp
necr ifftci, ind a leio
cone«niflf ia-iind
contri-
botion torards proposed
Sfstei
L.fnorri?
Correspondence
Correspondence
Correspondence
4 8f/03/04
Letter traosiitcin? a
resolotion regarding
f.fornsnip rater S7stei,
and a teio re.-Citf's
K.lcCnrdf
L.fborfi?
Correspondence
-------
cat/mm mis
rim
ia-kiai contribution
tonrds proposed tjsttt
mm SUITMT
SSKIDJI, mitson
MTBOl
rww
ucmur
DOCUHSIT TTPS DOCimtR
86/03/11 Letter responding n
Beiidji resident's
request
for couents on issues
relitiag to proposed
driakiag rater systtt
.S.Siaer
S.Skirt
Correspondence
86/03/21 Letter saiiariria?
progress,
discassiag a proposed
cbtage
in rater distribution
sfitei
S.tiaer
Correspoadeoce
36/H/97 Letter re.-Coastrnctiofl of S.Riaer
Driakiag later 5/stei
J.Ghostler
Corrtspoadtact
86/01/11
Letter re.-foaie 1 later- f.Aoosoar
Ccastractioo/lortfiern
forosoip
S.Riatr
Correspsadtace
86/01/21 Letter re.-fnestiofls/cflfl- I.Stroiierj
ceres at people roo
attended pooiic leetin?
86/01/24 Letter re.-coflcerni 6. Skirt
expressed
of tie Joird of
Stftnitori
of lartbtn toniaif
86 /OS/02 Letter re
-------
H
'01. 'SO
CEI/IUU PICK
rim
Remits
non
IIHHII
IMIWI. unison
HTSOK
ucmtit
Docmur
ooamn
2 ss/as/n
Lttttr to Bniiji
rssideat,
descrifiiay toe grooad
rac;r iartscigjcioe co a<
coadactti of toe JfPCi
S.Siner
G.fioffiao
Correspondeace
2 8S/OS/22
Letter respoodia? tt
qotstiaas nisti of
5tere JJiaer
rerisiooi to flflfl
C.PoJford
Correspoodeace
Letter adrisio; of
fortaer step* aeeded to
ajjare resideats lost
affected of coataiioatioo
are aooted op to
S. Riser
rater sfstei
J.Gbostlef
Correspoodeace
Letter re.>opdate oo
progress
torard coostroctioo, vater
5f5t«i for l.forosoip
5Jiaer
J.Scostief
Correipoodeoce
SS/ol/21 Letter requesting asiist-
aoce ID easonay taat
oecessarf re fieri aod
approraii occor n
if poniile
Correspoodeoce
1 Sf/07/24
leair oo otoaif of
Icurfjl aoieoroeri
reoyeitiij
appro nj
of a«r plao
L.Cooraf
0.0oreooer;er
Correjpoodeace
2 8S/D8/22
Letter to poteotialir
respoosjoie partf,
icfonatioo
L.JOOOJOO
(f.JODDSOD
Correspoodeoee
-------
JJf Hi.
PIGSS
HKI
uxuismrm MCOSD IIMI
mm stumr LMDIILL
BS1IDJI, IIIKJOH
at SOR
mmiir
rm
Doctums
2 86/09/21
Letter responding to
Bendji resident's
concern
orer delays in coastrflft'-
ing H.tatnsbip drinking
Correspofld«ace
5 8S/10/13
2 S7/01/23
Latter detailing a ttadf
conducted at senral
residences
and a business to gather
intortation to be used to
apply co the VSSPl for
the
cost of in-honse hookups.
Letter responding to a
request to utilize tat
tonitoring tells as part
of the SI in a research
project
Stephen Riner • IfCH iiltn Vojtas - VSSPl Correspondence
I.Chang
Correspondence
2 97/02/02
letter to Setidji
resident,
regarding selection of
his
tell ts a possible
tonitoring
site
S. Riser
J.Setschian
Correspondence
2 87/02/05 Letter io response to T.Salitotsli
01/01/17 letter,reguiing
tin upectf of SUl and
relttet iiptctt on
fioaeiotj
t.ldaikas
Correspondence
10 «7/04/02
Letter to Betidji
residents,
regarding resaits of
vater
analysis
S.Kiner
Betidji residents Correspondence
87/04/10 Letter to Beiidji
S.Riner
H.Soberg
Correspondence
-------
;,• Hi. 16
..•<)>.;10
•ess/mas PIGIS cm
nmusmtin meow IIDSI
mm suimr IIIDTILL
tint MTHOR
rtsiiest,
rejardiay results oa
titer
analysis
HClPIttt
rm
QOCIVHBSR
87/QV16 Letttr tc J.Gbostltf, J. timer
to request for
ioforutioa OB tht
coastrtetioB of racer
iistri-
batioa 5f5t«i in lorthera
fatasaip
J.Gbastlef
Carrespoaieace
87/05/14 letter reqirtiaq Fropased S.Rioer
Betidji-lortaera Jonabio
tracer sfscei
intircoaatctisa
J. Sbcstler/S.Peterso Correspoateace
o
87/07/25
87/07/31
87/08/U
Leccer to Coagrtsstaa ia faldas Mailcas-tlStPl
aaster to coastitatat's
qoestioa
regtrtiag tie progress of
the installation of tie
vacer
ijstei.
5tepojo
Sep. irlao
5cranelaBd
Sec letten
Correspoadeace
Correspondence
letcer co
residences
detailio; toe resales of
the
tell saipJiflff. condocced
in
lif JJ87.
feipooie of tie IfCI co
resident'i ^nestions
reyardiflj
tne lortnern forosolp
facer
frojecc.
Leccer iecailin? tie ROD Basil ConstanteJos-JSm Iticnard Sranda-«?CA Correspondence
sciedoJe
Stepnen Riaer • 1PCI lertai Jonnson
Correspondence
-------
•« #0. 17
cst/mm PISIS DATS
miiismtin
suirm
i, HIIISSOU
TITU
MCIPISH
Docmur mi
87/98/31
87/10/12
I 87/10/22
87/10/87
87/11/02
87/11/02
S*/07/2i
Request to tie ffSfM tor Thoias [ali'totski-SPCi
approral
o( parti;ipacioQ if tie
Citf of
Seiidji, ^anesota ;o tie
lortiern
fotra5i:p vattr sjstei
project.
5tepiea Riutr-HPCi
firee Jett«rs jent to
area
residents on status of
rater
srstei project.
fotification tiat a local Stepieo Rintr-SPCi
resident
alleges tiat coostroctioo
actirities
iare daia?ed tro trees on
ier property.
XPCi request to iocai
iandovoer
for coacarreoce ia a
ciaaae IB
tie oaiier of loaitorioj
upoa tieir property.
XPCl request to
Jaadoraers for
penissioa to instalJ
lonitorio?
telJs opoa tiier property
Stepieo Jtiaer - SPU
repett to iaadomer Stepieo Kioer - KPCi
tor
ptnlnioa to instill
loaitorlaj
tells upon iis property.
/act 5ieet 'faner
Landfill
Ground Vater
Coataiiaatioo
froiiei'
to.Jtsf.Res.tr
Prop.Owner
Pat
Correspoadjflce
Correspondence
Correspondence
Stephen fliaer • HPCl fo?ene Srooks Correspondence
«r. & frs.Ciarles Correspondence
flenardo
Valter /antianel Correspondence
/act Sieet
-------
.:• li. IS
. 01/30
•ess/mas PAGIS om
mm
itoti
momi
. umson
rim
UtHOK
Docwiir nts
souosm
4 88/01/13 furthers fcrasaip rater Liz ffelhiaaj - H?Cl
Sf5tei /act Sheet ffpdate
4 00/00/00 Jfeio recardiaf fi.Coastantelos
Km
Aorionzatioo
far Suppleientai
for
toe HSU tith the IPCi
a Stitt-ltii &D/R& far
latter
Jeoar fall - ffSJPI /act Sheet
Xeioraadai
J 82/02/17 Site Iflspectioo Seport
-------
ite to. 19
-.css/mts PIGIS am
RSCOKO
mm siiirm
SHIOJI, tmsson
rim
mintir
mmnt mi DOCHUU
3 84/93/13 Ktia re.-Selated response L.Olson
of an inspection of
.Toilers Sanitary Landfill
Jaat 20JJS4 -
Xfioraodai
J Si/11/20 Htto rc.Sitt lajpeccicfl L.Olson
OB Jfl/8/84
2 84/12/17 Keio re.-Inspectics of L.Olson
foner
Sanitary Laadtill on
11/15/84
R.tasstf
1 85/02/07 Jftio re.-I/I fitspoose R.Lapio
Statas
Keioraadai
J 85/03/21
Keio rtiOftnble tlait
fab lie Coiieoc Period
J.Sect
D.Stnill
2 85/09/19 Veto re:foner Saaitarf
Jospectioa
I.ffiorrig
Xeioraodai
J SS/08/26 leio re.'Jfeetiny fitfi fPl L.Tiorny
on tie faiier Laudfil]
*^ Drifltifl? later Operatic
ffoit
SJiaer
Jfeioraadai
4 86/08/26 Letter traosiittiag a L. thorn?
leio ooeiioifl; a;reeieot<
reacted doriny a
tettini to t/H/IS
S.tintr
Keioraodai
16 86/ll/li floarterir Jieports
C.Vatat
5 8«/12/2J toathlf Progress Reports C.fakat
1J 87/02/0$ lontiJr Progress Reports Ciadf laltac
i.fojtas
j.Vojcai
ille:
(feioraadai
Meioraodoi
leiorandai
-------
:i li.
•01/30
.'0
:?.!/imi PASJS
firii
wmisturm RJCORD non
AiirARf LAJD/IU
BHHJI, mutton
AfttOJ!
rrpf
oocimsi
7 87/02/09 XanthlT Progress Reports Ciadf
rojtas
10 87/05/07 Ooarterlf
Reports
S7/OS/21 Action
tfeioraodai-Aot&onzatiofl
to Aieod toe Haiti -Silt
Cooperatire A;reeieot
ritt
tie tfPCJ
12 87/12/03 ffnarterlf Progress Report Cindf fatat -
for /r 1S87 /oartfi
Barter
2 88/01/04 Keio rerfPJ Coosideratioo R.tfassef
of fortiero
Alien rojtas-[f5IP4 treioraadm
Proj.Officer
Basil Coastantelos-ffSfPA Paidas
Veioraodoi
later Sfjtei
latercoaoectioo
Allan rojtas - JSffPA Keioraadai
G.rillet
(Teioraadai
1 88/01/0$ tTeio re.-faiier LandfiJJ- J.lfe
response to leetio? oeid
on 12/23/87 regardia?
process outlined for
rater soppif
^
2 00/00/00 rerspaper Article
1 84/06/28 lerspaper Article foe Pioneer
Toner's Landfill jireo
Soperfand Status'
SJiner
leiorandui
ferspaper Article
lerspaper Article
l 85/01/11 ferspaper Article 'PCA foe Pioneer
lecif 5aperfnnd lonef to
correct ncer profiler
ferspaper Article
1 85/01/11 ferspaper Article 'fax fie Pioneer
relief Jikeif for
propertf
orners'
8 00/00/00 Coiiuaitf Relations Plaa-
OKA/f
ferspaper Article
Otner
-------
21
'ess/mm PI&SS mi
mimsmmi MCORD
mm sium? IIIBIIIL
mwi, unison
Tins
acimn
mi
23 00/03/00 Pirious Site Iosp«ctioa HPCl
Reports troi '83,'84, '82
Other
3 00/00/00 Site Sanarf vitb BSS S./orrsst(r«ri«rer)
Score
nntv attached
Other
J7 00/00/00 Karioos (fatenaJ Beilth Uaioo Cheiicils Oiritica
and Safety Bulletins
Other
2 80/02/10 Site Iflspectioa J?«purt
Otfier
1 82/01/12 Site latpectioB Report
Other
2 82/03/02 Site Inspection Report JfPCJ
Otier
3 '82/04/21 Site Juspectioa Report
Otaer
Site laspectifffl Report
Otoer
j , S2/J7/J4 Site ;nspectiOB Report WCJ
Otoer
JJ/05/15 Site Iijpectioo Jeporti SfCi
tor
and
Otier
7 84/02/15 Site laipectioD Jieports mi
tor
Other
2 84/03/23 Site Inspection Report KPCi
3/23/84
Otoer
106 84/06/26 Xeetina Iqtndi Itet HPCK
Control
Sheet. re.-Reff.oest far
Otner
-------
is; is.
'.'Ol/BO
:css/iKm PAGIS urn
mnismms mono now
jiirutr uiomi
BSIIOJI, unison
rim
Issuance of i Request tor
Response Action
ittachtents
auric*
mipint
Dociamz
1 35/05/07 Pom of
J.lita
Other
11 05/OS/25 mk Agenda Itei Central R.Lapin
Sheet;
Attichients-Proposed
findings o'
tiet.ConclaiiiB
and Order-.Periit St-31
Other
2 SS/04/00 HPU Penanent List of HPU
Priorities
Other
j 97/93/90 iiesdient to change the HSIPA
project period and budget
period
Other
12 79/12/18 Stipulation igreetent
12 l3/94fli
Count? of BeJtrail
Coart Coiplaiot
MPCl/lauer Sanitarj
Landfill
L.tiegel,isst.
General
Pleadings/Orders
Pleadings/Orders
5 84/05/17 Conner of I.Seoeeoal.issC.ittoroer
Beltrail'5(flaln- General
tiff) first request tar
production of docoieati
Pleadings/Orders
3 94/07/14 Dinetor'i Determination t.falitotski
of ficr;eicf
Pleadings/Orders
j 34/07/17 Director's Determination J.Itlitoiski
of Sttrgtncj
Pleadings/Orders
18 8S/9i/93
lotice of Intent of tPCt
to request perm
rerocatioo
and issuance of closure
Pleadings/Orders
-------
-------
.',-• to. 24
: •)'..'so
icss/mu fisss wn
mnismrm mow urn
mm suitui lamn
BStlSJI, 11IIKOTI
tint
reyirdin? ast of prirate
velli after rater topplf
is installed
WTSOS
mmuf
socmm ms oocimm
JO 00/00/00 Sonar? of tieiedial
lire Selection
Reports/Stadia
4 00/00/00
CoiiafliCf SeJacioas
Ktsponsireoeis Santry
Separts/Staiies
8 00/00/00
Record of Decision
Dejection
Jeporti/5tadie5
3 tt/Ot/00 Conoaitf fielatioos Flan
00/00/00
Sriefiu?/
Delegation
Sanarf
J!eport3/5todiej
Aeport5/5to
-------
iqt Us. .'5
I/O I/SO
icas/rms PUSS
UCOM
mm suimi LUDHLL
BWBJI. unison
tint
minin
socnnt
35/04/00 fadaofferi«flt Jjfemeot
85/08/00 HI/IS tort Plaa Scope of Kalcoli Piraie
for* for; loner Sanitary
landfill
asm
Rtfotts/Staiies
J
-------
lo.
::wnm puts am
rifii
umismtin
mm sum.
BtaiBJi. mitsm
HUSO*
Mcmut tm DOCIMSM
87/01/30 Saipliflff and Jnalrtical (falcoli Pirnie
?laa faiier/Sooarf 2
Scere Sia«r
R«ports/Stadi«s
J3 87/03/H Draft uf tie Ifaltisitse
Cooperatire ^rttttst
jlieaditac frai VFCA
fieports/Starfies
1C 87/04/09 JaipJjn? aod Joalrtkai Nalcoli Pirai«
Haa/Jfcaad 3
i«ports/Stadi<5
«7/fl7/22
10
25 81/09/93
Draft Sopplenatal W farrf Soett-Kaicao Pirais 5t«pa«n Uiaer-lfPCi R«ports/Staifi«5
5cop<
flf fort ritn carer
letter.
Jaartsrlf Proares* ieport ffPCJI
ta toe ?sm far tie H
1587 fflirrf floarter
latat • ffSIPl fiepartJ/Stodies
fecoolcal Specificatlaas Seepoeo fioer - IPCA illeo fo;tas-7SffA JIepart5/Stadle5
far
resideatial semce
caooectiaos
as part af toe lartiero
farosoip
rater Prefect.
$5 St/0(/20 m Scoria?
Reparts/Stadies
2 90/08/18
letter ret to inconfirt
tbat tbe IPCi in ?iren
client, licrieu iiien
5opp|| Caipanr, i tro-
reet txteofiOB of tiie
to eouiat on the Fre-
poi«l Plao for medi-
ation of toe abort re-
ferenced fite
falski, Carolfo ?.
Soraett, I.
Carrespandence
9 90/08/22
Sopenroad Corporation
J(oPl7 0iri5ian Canents
Jolf 1990 Prapased Plan
for Graoodvater Operable
ffou fuiner Saaitarf
Ce&oard,A.,P.I.
Pribblt. Kalpb
Correspondence
-------
:•. Hi. 27
•il.'SO
CBS mm fists DATS
rim
Landfill
mitismrm mow mil
mm suimi LAID/HI
stum, unison
miPisir
DocnsiT TIPS
ooctmss
1 30/08/30 Coiients on Proposed Cnan?,f.,Pn.D.
flan
Horaeff, KfCt dtrtspoaienct
I 90/OJ/ff!
5operfoad
Project Kntiitl
Action Proposals
Boell,B..t.t.,CitT
Sajiaeer
fforaeff,
2 90/09/05
Coiuflt on Pro-
postd Plan
tolski. C., Leonard
Street iCeioard
Prioble, KPC1 Correspondence
U 10/01/05
Letter re.- corer
letter attacned,
Aierican Linen
Sapplf Co. Conents
Jolf 1990 Proposed
Plan tor Sroondrater
Operaole Unit fouer
Saoitarf Landfill
Jacques. J.,t.S.,Dates & Prioble, K.,HPCi Correspondence
80 ore
-------
itt Is. I
I/O I/SO
icss mm mis BITS
2 aa/08/23
It aa/09/00
77 at/09/00
Tint
Litttr rcConeati en Donald Brace
Otitt ?ropos«rf Pita for
Oil Grtrt Sa
Laaititt Sitt
uansrurin mm IIOH • mm n
mm suiruti luoriLL
BHIBJI, muson
ncinur
Docanur
Keitiiii Inrtatiqatiaa
liaal Rtport
Proposed Pita
fenibilitj Stoif
X?Cl
SPCH
Juts tiratr.KPCIi Correspoodeoce i
Keports/Scadies 2
Reports/Studies j
feports/Stadies 4
-------
la.
I/SO
:cES/mu nets
TITO
uunsnum meow um • mm n
mm suimr LUOIILL
BHIDJI,
MJSOR
ucmur
menu? mi
oocmm
S9/0J/00
89/91/99
89/01/99
87/10/12 letter proridiay .
update on rater
jfstei coaitructioo
88/98/39 fraasiittal letter
for ners release
tat JeyaJ ad to
appear in tie
Seiidii Pioneer;
ftatJa? fab lie
leetio? till tit
held on S/1S/M
8S/12/OS Letter proridio;
intonation to
lortaern foratoip
Board on >ite
actJritiei.statioy
Win liqaed toe
{00 oo 9/30/93
88/91/99 net Shteti
'lortaera fonioip
liter Sfitei fact
Saeet Update'
88/99/99 fact 5oeet for
pooilc coiieot oo
IS ut fropoied Piao
41/09/00 fact 5o«t<
•roiier iifldfJH
fioal Corer IS'
8t/lt/2t IMC fllttr
S.Siaer.WCI
toejiin •• tit
fttd- t«rir for
fniir laidfiJl
Site*
aad 5op«r-
food* fact Sheet n
'landfills aad Soptr-
food' fact Saeet K
'Laadfiils aad Saper-
faad' /act Sheet tl
fPCJ
tfd
WC1
UCi
XPCJ
Sesideats/Propertf Correspaadeace i
Qtotrs
Interested fersoni Correspondence 2
I.Siller, fofojoip Correspoodeace
CJert
fact Saeet
fact 5aeet
fact Saeet
fact Saeet
fact Saeet
fact Seeet
fact Saeet
-------
•age la.
'less/ma puts
tint
MCOSO IIDSI - mm n
mm siiimi mot ILL
tm
oocimss
39/01/00
3 89/01/00
89/01/30
89/01/00
85/03/21
88/09/20
1 8S/03/2f
1 88/09/02
1 88/09/15
54 04/09/15
1 88/08/23
'Landfills and Soper-
foad' fact Sbttt II
"landfills and Saper-
foad' Hct Stitt: 13
HPCi
nd 5ap«r-
taad' /act Sbttt n
'landfills and Safer-
food* face Sbtet IS
Jfeio rtsOftrible ffoit
Public Cotitat Period
friflsiittal itio
far tact ibeeti tad
agendas used at
public itttiags to
describe alternatires
and HfCi't proposed
aiteroaeire for tie
landfill corer
operate ooits
iff Ida fit of
Publication
i legal adrertiseieot
for pofiJic coueoc
oa final IS iod
risi assessieit)
iffidirit of Poolieatioi
(JeyaJ adrertiseieoc
for ftblie eoii«flt oo
IS iitf Proposed
for foolle
franscript of
PooJic netting
fers Release.-
'lonbern forosoip
facer Kaio Cooscroc-
tioo Proceeding OB
5coedole:Sircbioot
Drire Coflstrocticn
KPC&
L.Gelbttaa.mi
fact Sheet.
fact Soeet
fact Sheet
fact Soeet
D.Senill,USS?i leionodot
5.Pastor,SSI?i feioraadoi
n
5Cite of II.Beltraii Otfier
Ctf.
Jtate of Iljeltraii Otaer
Ctf.
Jacoosoo Seportiflj
and Fideo Serrices
mi
Otaer
Otaer
Press fielease
u
15
-------
i
< 10. 3
less/mat nsts mrs
2 88/08/30
88/10/2S
2 88/11/1*
09/09/99
ritu
far Ctaie feiporarf
Loctl trtttie fctoar*
Ins
'mi to sold
Ktttiaq oo Proposed
foii«r Landfill Cortr
5f5C«l;fo41iC CdUflt
Period SclxdaJefl"
Itrs
•>PCJ aod
/ioal Carer for
fouer luitiir
lets
'liter ttin Intttl-
Jatloo ifl lor ti era
foroiiip Coipjete*
CononJtf lelaciooi
fits
79 .88/99/30 Record of Ceeisioo
SJCOSD mn • mm 12
mm suiTiRi HID!ILL
BSHIOJI, unison
mimit
asm
KFCJ ifld
rrp« DOCIWBH
Press Release 22
Press Release
Press Release
Jteports/Stddies
Seports/Stadiej
24
25'
-------
HCORD HOtl •
from sjiiMj
smwr, mnson
cat /mm tuts Dirt
rim
Ricmnr
Mcmur tm oocmms
5J0 50/01/00 Rtttiiil lanstijatiaa Halcolt Piraie.Iac. MPCA
final Report
fatter Satitarj Ltodfill
vith taps attached
Reports/Staties l
------- |