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.

-------
                                                                       stt^a
                                                                    r- ftwyilft^'J
K^!:^^-^ gjfi,;:;;^;-;.,;:,

J^VT^-,);^  • -.i.:g-j^i• J1'31-•'...>..  *'„'.'•

'•' :liV''':f'j'^" •^~-'~ir( V  '''-i-  ~J\^'**''
                                     -^^/OvOO':^;

                                      vl Vvi-tif& >'
                                    fjar ' IV"J - ^i-^
                                                        KUMMER
                                                             LANDFILL  ~ .^^J.
                                       . . -\        | IV.f»a%. "-si  • it'll!1
                                     ^xrVtl.7^t-U' |TvJ?1Jinv»   -P!t:

                                     r-^V^^f*ijcM;
                                     !\--r;r-,:Vyr::v«,f:i.:r-.. t^     H-S««r^
                                     .'X^ji^'/cr^-r'^V-^ r^i^.^ J   ' _fc
                                     N    0  "  K   T32. II   ID   «n
                                     •• N ciiiiriHiAii;     . iiiioNiMiiv j" _ :
                :^    ^.^

I HOW OEMIDJI WEST (1968) AND PETEHSON

I AKE (1972) 7 t/2 MINUTE IISGS

lOPOGRAPIIIC QUADI1ANGLES
MAIJOOyVt
  IMRNiE
KUMMER  LANDFILL

                SITE LOCATION
                                                                                                          " •! COL" unin
FIGURE

-------
                o
                D
                               NOMTH COUNTRY
                               NOSPIT AL
           APPROXIMATE CLUSTER
              WELL LOCATIONS
ABC

AB ONLY

A ONLY
     O    BOO   KXX>

  »»0   160   ^O^^

•KAPHIC »CAU[ M
EXTENT OF VINYL CHLORIDE

—— A ZONE

	B ZONE

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

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                                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.

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                                              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.

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                                                             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.

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                         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.





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                       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.

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                                                      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
    $
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                                                        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.

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                    TABLE 8
          GROUND WATER  DISCHARGE COST

Capital Cost                  .            $230,000
Excavation
Erosion control
Pumping
Annual O&M Cost                           $29,000
_«•»«• 
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      APPENDIX A
RESPONSIVENESS SUMMARY

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                     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
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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

-------
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                                                                                                 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

-------