PB95-964110
                                 EPA/ROD/R05-95/283
                                 March 1996
EPA  Superfund
       Record of Decision:
       Pine Bend Sanitary Landfill,
       Dakota County, MN
       9/28/1995

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                    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                         REGION 5
                                77 WEST JACKSON BOULEVARD
                                   CHICAGO. IL 60604-3590
                                                           REPLY TO THE ATTENTION OF:
MEMORANDUM

SUBJECT:   PINE BEND SANITARY LANDFILL CONCURRENCE
            CLARIFICATION

   FROM:   William Muno, Director
            Superfund Division
      TO:   John Smith
            Senior Process Manager, Pipeline Integration

The purpose of this memo is to provide clarification with respect to the Pine Bend
Sanitary Landfill Site concurrence letter signed by Region V Administrator, Valdas
V. Adamkus, on September 28,  1995.

The basis for U.S. EPA Region V concurrence is based on the following facts: (1)
the human health and  ecological risks lie in an acceptable range, refer to Section
VI of the Decision Document; (2) the completion of Operable Unit #1, which
involved a permanent connection of residences in the vicinity of the landfill to a
municipal water supply, therefore, reducing the risk posed by contaminated
groundwater, refer to Record of Decision for Operable Unit #1 signed June 1991
and Section  IV of the Decision Document; (3) the accomplishment of the closure
requirements stated in the existing operating permit (installation of a landfill cover,
clay liner, etc.), refer to Section II of the Decision Document; and (4) the new solid
waste operating permit, refer to Section II of the Decision Document. The human
health and ecological risks lie in  an acceptable range because of the full
implementation of the  remedy for Operable Unit #1.  Due to the fact that the site
is an active and permitted facility, there are closure requirements under the
existing permit that the facility must meet. All of the closure requirements
(capping, clay liner) have  been completed. With respect to the new solid waste
operating permit, it will address  groundwater contamination based on the State's
requirements, and not because it represents a risk to human health and the
environment. At present, the contaminated groundwater does not represent any
recognized risk to human  health and the environment.

Based on the above explanation, U.S. EPA Region V concurs with the no further
action under CERCLA alternative selected by Minnesota Pollution Control Agency

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(MPCA).  In addition, U.S. EPA and MPCA believe that the site meets all the
requirements to qualify for inclusion on the site construction completion list since
all construction at the site had been completed and there are no human health and
environment risks associated with the site. If you have any questions regarding
this matter, please contact Mr. Ramon Torres of my staff at (312) 886-3010.

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      J
      9         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                REGION 5
 ' *lolty                   77 WEST JACKSON BOULEVARD
                           CHICAGO, IL 60604-3590 .
                              SEP 28' 1995'

Mr. Charles W. Williams                               SEPLV-oTHEATTENT.ONOF
Commi s s i one r
Minnesota Pollution  Control  Agency
520 Lafayette Road
St. Paul, Minnesota  55155

Dear Mr. Williams:

In accordance with 40  CFR  300.515(e)(2)(i)  and (ii),  the United
States Environmental Protection Agency (EPA)  hereby concurs with  -
the no-action alternative  selected in the enclosed Decision
Document prepared by the Minnesota Pollution  Control  Agency.
(MPCA) for the Pine Bend Sanitary  Landfill Superfund Site.

The basis for EPA's concurrence is twor-fold:   (1)  Further action
to control the source  of contamination (installation  of a.
landfill cover, clay liner,  leachate  collection system, etc.)  and
to address contaminated groundwater will  be conducted under the
facility's MPCA operating  permit,  such that no further action
under CERCLA is required.   (2)  Completion of  operable unit #1,
which involved connecting  residents in the vicinity of the
landfill to a municipal water supply,  reduced the  risk posed by
contaminated groundwater.

While EPA endorses MPCA's  no-action decision,  EPA  would like to
clarify the statement  in the Decision Document concerning the
necessity of a five-year review.   The Decision Document suggests
that because annual data reviews are  required under Minnesota
rules, a formal five-year  review in this  case will not be
necessary.  EPA disagrees.   A formal  five-year review is an
obligation imposed under section 121(c) of CERCLA,  42 U.S.C.
J§ 9621 (c).  MPCA's annual  data  reviews may be used to complete  a
five-year review - no  doubt,  they  will make 'composing a five-year
review report quicker  and  easier;  but they do not  automatically
fulfill the federal statutory requirement.

If you any questions regarding  this matter, please contact Mr.
Ramon Torres of my staff at  (312)  88S-3010.   We look  forward to
continue working with  MPCA.

Sincerely yours,
       V. Adamkus
Regional Administrator

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                                                      -2-
         The MPCA has determined, and the USEPA concurs, that their response at the Site is complete and no
         further action under CERCLA is necessary at this Site. Therefore, the Site now qualifies for inclusion on
         the site construction completion list. The reason for this determination is that source control is being
         completed under a solid waste operating, permit issued by MPCA, and the ground water contamination will
         be addressed under the same operating permit.  Also, the remedial action disclosed in the Record of
         Decision (ROD June 1991) which is the extension of the existing city of Inver Grove Heights municipal
         water supply has been completed and actions required under the Response Onjer by Consent between the
         MPCA and Pine Bend T^nAfill  (1985,  1990) have eliminated potential exposure to source related
         contaminants.  Continued monitoring of the Site and implementation of contingency actions are specified in
         the Pine Bend Landfill's operating permit.

         Federal and State Concurrence:

         The USEPA and the MPCA believe that the selected remedy is the best choice balancing of the evaluation
         criteria required by CERCLA.

                W. Williams       (j                      Date
"7       Commissioner
 \J       Minnesota Pollution Control Agency

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                                Minnesota Decision Document
                                 Pine Bend Sanitary Landfill
                              Operable Unit 2:  Source Control
I.   Site Name. Location and Description

    The Pine Bend Sanitary Landfill (PBSL) site is located in northeast Dakota County, on the periphery
    of the Minneapolis/St. Paul metropolitan area, in Sections 27, 28 and 33, Township 27 North, Range
    22 West, city of Inver Grove Heights, Minnesota (Attachment 1).  PBSL encompasses approximately
    255 acres and is an open operating mixed municipal solid waste facility. Crosby American Demolition
    Landfill (CADL) is located immediately north of the PBSL (Attachment 2). The PBSL and CADL
    were operated as separate landfills under separate ownership. CADL encompasses approximately 52
    acres and ceased accepting waste in 1989 and is inactive.  CADL and PBSL are connected
    hydrogeologically in the surficial aquifer, with CADL being immediately down and sidegradient of
    PBSL, and PBSL being sidegradient of CADL.

    The PBSL site is included on the Minnesota Permanent List of Priorities with a Hazard Ranking
    System Score of 52. PBSL is on the National Priority List (NPL) with a Hazard Ranking System
    Score of 52. The MPCA has considered the two landfills as one site because hydrogeologic data
    demonstrates that the ground water contamination plumes emanating from each landfill commingle east
    of their common border.  The MPCA considers the Responsible Parties for both landfills jointly and
    severally liable for the commingled ground water contamination hydrogeologically down and
    sidegradient of the PBSL Site.

    The PBSL site (the Site) is bordered on the south by industrial areas, to the east by residential and
    industrial areas, to the north by residential areas, and to the west by pasture and residential areas.  The
    terrain is generally flat to gentry rolling and possesses an immature natural surface drainage system
    resulting in numerous ponds and wetlands. The Mississippi River is located approximately one mile to
    the east of the Site.

    The geology of the area in the vicinity of the Site consists of a thick sequence of glacial drift overlying
    approximately 700 feet of cambrian bedrock. The bedrock is generally flat lying but has been deeply
 '  eroded in some areas and subsequently filled with glacial drift. The axis of a pronounced buried
    bedrock valley trends •west-northwest to east-southeast near the northeastern comer of the Site. The
    valley is nearly two miles wide and 450 feet or more deep in places, although there is no surface
    indication 'of its presence. The gradient flow of surficial ground water, supported by extensive
    hydrogeological data is found to be east-northeast running from south of PBSL, through PBSL,
    continuing in a northeasterly direction through CADL, then east along the buried bedrock valley to the
    Mississippi River (Attachment 3). The ground water contamination plume emanating from die Site is
    moving through the surficial aquifer in this area and it is believed that it will eventually discharge to the
    Mississippi River via springs in the  river bottom.

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                                             -2-
II.  Site History and Enforcement Activities

    The PBSL was first issued a permit (SW-045) to operate by the MPCA on September 7, 1 97 1 .  Since
    then, it has operated as a sanitary landfill accepting mixed municipal solid waste (mmsw) and
    nonhazardous industrial waste.  Pine Bend FanHfill Inc. (PBLI), a wholly-owned subsidiary of
    Browning Ferris Industries, is the owner and permittee of the PBSL.

    In April 1985 under MERLA, Pine Bend Landfill, Inc. entered into a Response Order by Consent with
    the MPCA to carry out a Remedial Investigation (RI), Feasibility Study (FS) and Response Actions
    (RA). The Consent Order was amended on October 23, 1990. Pursuant to that Consent Order,  PBLI
    has, among other things, conducted an RI (1986), conducted additional RI activities (1987), conducted
    a pump test (1989-90), submitted a Preliminary Alternatives Report (1989),  undertaken an interim
    ground water monitoring program (1988-1994), submitted an MPCA approval final RI report in
    August 1991 and an MPCA approved Detailed Analysis Report in November 1994.  PBSL has
    completed the operable unit for a permanent alternative water supply and now is addressing source
    control (OU2). The following work is being completed under MPCA operating permit:

       Placement of final cover on portions of the landfill that are filled to final elevation, installation of a
       combustible gas collection system, installation of a  clay liner and foachate collection system  in an
       expansion area, and the installation of a surface drainage control system. The existing ground
       water contamination will be addressed through a compliance permit with Pine Bend
       Browning Ferris Industries, Inc. by signing the Amended Order dated October 23, 1990,
       guarantees PBLI's performance of the obligations established in said Amended Order.

   The CADL was permitted on September 15, 1970. In April 1985 under MERLA, Crosby American
   Properties, Inc. (CAPI) entered into a Consent Order to address ground water contamination including
   VOCs. Due to bankruptcy proceedings, CAPI claimed it could not carry out the terms of its Consent
   Order and suspended all activities at the CADL site. MPCA entered into a Settlement Agreement
   (Attachment 4) for the CADL site on September 28, 1992.  In the Agreement, Amdura Corporation
   Agreed to implement die preferred remedy for the CADL site, with the exception that the MPCA will
   provide a portion of the materials for the engineered cover.  PBLI and Amdura entered into a
   Settlement Agreement regarding environmental claims (No. 9226) on November 1 1, 1992.

    Highlights of Community Participation

    The Superfund activities at the Site have been followed closely by the 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. Notice of availability for the Proposed Plan for OU1 was published in the  Sun Current (Inver
    Grove Heights Edition) Newspaper in the form of a display ad on May 1, 1991.  This ad initiated a 30
    day public comment period. The public comment period is consistent with CERCLA, Section 1 17 (a).

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                                              -3-
     Notice of the public meeting held on May 15, 1991, was included. Additionally, a news release
     providing notification of the proposed remedy and public meeting was sent to interested parties and
     the press.

     A public information repository has been established in the Wescott Branch Library, of the Dakota
     County Library System, in the neighboring city of Pagan, Minnesota. This is the closest public
     library to the Site.  The Administrative Record for the Site is located at the main office of the MFC A
     in St. Paul, Minnesota. The Record includes the documents listed on Attachment 5.

     Notice of availability for the Decision Document for this operable unit was published in the Dakota
     County Tribune (Inver Grove Heights Edition) Newspaper in the form of a display ad on June 22,
     199S.  This ad initiated a 30-day public comment period. The public comment period is consistent
     with CERCLA, Section 117 (a).  Notice of the public meeting held on June 28, 1995, was included.
     Additionally, a news release providing notification of the proposed remedy and public meeting was
     sent to interested parties and the press.

IV.  Scope and Role of Remedial Activities

     The USEPA and MPCA initially agreed to divide the project into three operable units in order to
     facilitate progress toward remedial action at this Site. The three operable units were (OU1), (OU2)
     and ground water contamination (OU3). Since OU2 and OU3 essentially related to Source Control,
     USEPA staff recommended that OU2 and OU3 be combined for administrative and technical reasons.
     MPCA staff concurred with this recommendation. Subsequently, source control and the ground water
     contamination operable units were combined into one operable unit (OU2).

     Alternative Selected for OU1 was a Permanent Alternative Water Supply

   .  The work under this operable unit was completed in November 1994. The components of this selected
     remedy are:

      • •   The extension of the existing city of Inver Grove Heights municipal water supply.

      _ •   The .connection of impacted or potentially impacted premises to the municipal water supply.

       •   The permanent sealing of the private water supply wells which presently serve the premises
           that were connected to the municipal water supply.

     Source Control and GrymnH W^ter Contamination (OU2)

     The actions occurring at the Site are not being initiated under CERCLA authority but are being
     completed as a permit requirement.  The unlined portion of the Pine Bend Landfill is being covered in
     accordance with current Minnesota Solid Waste Rules. Construction of the last stage of the final
     cover is planned for the summer of 1995. In addition to the landfill cover, the active landfill gas
     collection system operates to limit the migration of landfill gas, and secondly, has the benefit of
     removing substantial quantities of VOCs as demonstrated by the quantity and quality of condensate
     that is removed from the system.  Minnesota Solid Waste Management Rules meet or exceed
     CERCLA requirements for  source control.

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                                              -4-
     The ground water contamination action recommended under Superfund for this portion of OU2 is a no
     action alternative.  The existing ground water contamination will be addressed through an amended
     compliance permit with Pine Bend Landfill. These actions are necessary to address compliance with
     MPCA solid waste rules for an ppen operating sanitary landfill. In addition, PBLI is addressing
     ground water contamination from the CADL.

V.   Summary of Site Characteristics

     The work at the Site involved determining the nature and extent of the contamination associated with
     the Site and conducting a Human Health and Ecological Risk Assessment. The Remedial
     Investigation concluded in pan that

     The problem of primary concern is the VOC contamination in ground water due to leachate migrating
     from the Site.  The Site is the only known source of the contamination of ground water in the impacted
     area east of the Site.

     Ground water was die only medium found to be contaminated off Site that could be attributable to the
     Site. With the exception of benzene and the chlorinated fluoromethanes, all of these  substances
     identified may be related to the transformation of certain chemicals to vinyl chloride through both
     chemical and biological processes. These substances are found at locations both outside and within
     the boundaries of the Site. The ground water contamination is most likely the result of precipitation
     infiltrating through the permeable landfill cover material and coming in contact with the buried waste.
     Specific compounds may also result from the degradation of waste products. The compounds of
     concern can be .classified as to carcinogenicity (the likelihood that they may cause cancer in humans).
     A "Group A compound" means that sufficient information exists to classify it as a human carcinogen.
     "Group B 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 C compounds" are possible carcinogens.
     "Group D compounds" are not classifiable as to human carcinogenicity;  The classes of the
     compounds of concern are as follows:
Chemical
Benzene
1, 1 Dichloroethane
1, 1 Dichloroethylene
1, 2 Dichloropropane
Methylene Chloride
Tetrachloroethylene
Trichloroethylene
Vinyl Chloride
Oral
Group
A
C
C
B
B
B
B
A
Inhalation
Group
A
C
C
B
B
B
B
A
     All other VOC contaminants that have been found in on and off Site wells are classified as Group D
     compounds.

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                                               -5-
VI.  Summary of Site Risk

     Part of the Remedial Investigation for the Site involved conducting a baseline risk assessment, which
     is intended to measure the potential current and future risks posed by chemicals of concern at the Site.
     The risk assessment evaluates both human health and environmental risks.

     Human Health Risk

     The baseline risk assessment indicated that current exposure to residents and workers was acceptable.
     An excess lifetime cancer risk (ELCR) of 10"* (1 in 10,000) is used as a benchmark by the USEPA for
     sites warranting remediation (USEPA 199 1 b.).  For non-carcinogens, a hazard index (HI) of less than
     1 is considered acceptable by the USEPA.  The ELCR for residents was 2 x 104 and the HI was 0.4.
     The ELCR for site workers was 3 x 10"' and the HI was 0.000005.

     Future exposure to residents resulted in an ELCR OF 5 X 10"3.  The HI was  1.3 and equals the
     guidance value when rounded to one significant figure.  Vinyl chloride was responsible for more than
     90 percent of the ELCR, and cis-I,2-dichloroethene was responsible for more than 75 percent of the
     HI. Future risk estimates for the Site worker were identical to the current risk estimates. Therefore,
     future hypothetical exposure to vinyl chloride in ground water was identified as potentially posing an
     unacceptable risk to residents. The likelihood that the shallow ground water will be utilized as a
     potable water source in the foreseeable future has been reduced, however, by the extension of the
     municipal water supply.  In the absence of future potable use of the shallow ground water, the future
     hypothetical risks associated with VOCs are eliminated.
                                   •
     Current data obtained from the Detail Analysis Report (October 1994) indicate that vinyl chloride is
     degrading at rates comparable to formation rates in the shallow ground water. Based on these data,
     degradation of higher chlorinated ethane and ethene derivatives to vinyl chloride will not result in
     increasing vinyrchloride concentrations at the Site.  Risk estimates based on a lognormal distribution
     of the data, a 30-year exposure period, and calculated constituent-specific permeability constants
     (PCs) are shown in Table 1 . The ELCR was 1 x 10"4 when vinyl chloride was included and 5 x 10'5
     when vinyl chloride was factored out These alternate risk estimates meet the regulatory guidance of 1
    -Ecological Risk

     The ecological risk associated with the Pine Bend and Crosby American landfills was qualitatively
     assessed by comparing die level of each contaminant of concern with the identified criteria or
     toxicological value. If the concentration of a given contaminant is lower than the respective criteria or
     value, then the potential risk was determined to be unlikely. Likewise, if the concentration of a given
     contaminant is greater than the respective criteria or value, then the potential risk was determined to
     be likely. If no criteria or toxicological value are available in the literature, then the risk was not
     characterized.

     Based on the available data, mere are not any cases in which the concentration of a given contaminant
     exceeds the selected criteria or toxicity value.  Thus, no likely ecological risks were identified in
     association with the release of contaminants from the PBSL site.

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                                          -6-
Based on the findings in the Remedial Investigation and the Health and Ecological Risk Assessments,
the continuation of action under Superfund is not necessary. The low potential for Site impacts can be
adequately addressed under the Minnesota Solid Waste Rules for landfills. The Site is an open
operation landfill permitted by the MPCA. The permit requires continued monitoring, long-term care
and contingency actions.

Continued monitoring to insure compliance with Minnesota Solid Waste Rules will adequately protect
human health and the environment.  Annual reviews of the data collected are a current requirement
under the Rules and thus a formal five-year review will not be necessary to ensure that the selected no
action alternative remains protective.

This decision document presents the selection of the no-action remedial alternative for the PBSL,
Superfund Site. The selected remedial alternative was chosen in accordance with CERCLA; as
amended by SARA, and to the extent practicable  the NCP.  Also, the selection is consistent with
MERLA.  This no-action alternative is the same as the preferred remedy presented at the public
meeting for the Site on June 28, 1995, at the Inver Grove Heights City Hall.  .

This decision is based upon the reports, information and public comments, which constitute the
Administrative Record for the Site.

The USEPA concurs with the selected no-action alternative for the PBSL  Superfund Site.

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Table  1 .  Excess Lifetime Cancer Risk Estimates bused on a 30-Year Exposure Period, and the
           95 Percent Upper Confidence Limit of the Geometric Mean Groundwalcr Concentration,
           Pine Bend a*nd Crosby American Landfills, Invcr Grove Heights, Minnesota.
ELCR
Constituents Cgw PC CSFo
Inorganics
Arsenic 0.0018 0.001 1.8
VOCs
Benzene 0.0015 0.0204 0.029
1,2-Dichlorocihane 0.00026 0.0053 0.09l'
1,2-Dichloropropane 0.00062 0.0103 0.068
Telraclilorocthcnc 0.0023 0.013 0.051
Trichlorocihcnc 0.0015 0.0147 0.011
Vinyl chloride 0.0015 0.0076 1.9
CSFi

15

0.029
0.091
NA
0.0018
0.017
0.29
Total ELCR
Total (minus vinyl chloride)


Ingeslion

3.8E-05

5.1E-07
2.8E-07
5.0E-07
I.4E-06
1.9E-07
3.3E-05
7.4E-05
4.1E-05

Dermal

1.7E-08

4.7E-09
6.7E-10
2.3E-09
8.1E-09
1.3E-09
I.2E-07
1.5E-07
3.4E-08

Shower

NS

1.6E-07
8.6E08
-
1.5E-08
9.3E-08
1.6E-06
1.9E-06
3.5E-07

Household

NS

5.0E-06
2.7E-06
-
4.8E-07
3.0E-06
5.0E-05
6.2E-05
1.1E-05

ELCR

3.8E-05

5.7IE-06
3.IE-06
5.0E-07
1.9E-06
3.2E-06
8.6E-05
lE-OTj
5E-05 1

Cgw Concentration in ground water (milligrams per liter).
PC Permeability constant (centimeters per hour).
CSFo Oral cancer slope factor.
CSFi Inhalation cancer slope factor.
ELCR Excess lifetime cancer risk.
NS Not a significant exposure route.






























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                     PINE SEND SANITARY LANDFILL/CROSBY AMERICAN DEMOLITION LANDFILL
                          Anoka County
                                                   Washington ;
                                                   County    ,_[
                  -"-Hennepin
                    County   r?
                                        -Ramsey
                                         County
Carver
County
                                               Dakota
                                               County
Scott County

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CROSBY-AMERICAN
PROPERTIES (CAP>

PINE BEND LANDFILL, INC.
PROPERTY

SKB RICH VALLEY
LANDFILL PROPERTY

KOCH REFINERY PROPERTY
ADDITIONAL COMMERCIAL
PROPERTY

RESIDENTIAL PROPERTY /
AGRICULTURAL PROPERTY/
OPEN SPACE
                       SOURCE:
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 ^•'GERAGHTY
 *f& MILLER. INC.
    LAND USE
                           PINE BEND SANITARY LAMO*LI
                          INVER GROVE HEIOHIS. MINNESOTA
                                                   FIGURE
                                                     2

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                                                       ATTACHMENT 4
                  UNITED STATES  BANKRUPTCY COURT
                   FOR THE DISTRICT OF COLORADO
In Re:                          §  CHAPTER 11
                                §
AMDURA CORPORATION;             §  CASE NO. 90 B  03811 E
AMDURA NATIONAL DISTRIBUTION    §  CASE NO. 90 B  03813 E
  COMPANY, f/JC/a/ FOK;          §
COASTAMERICA CORPORATION;       §  CASE NO. 90 B  03813 E
COAST TO COST HOLDINGS, INC.;   §  CASE NO. 90 B  03814 E
COAST TO COST STORES, INC.;     §  CASE NO. 90 B  03815 E
and INTERTRADE CARGO, INC.;     §  CASE NO. 90 B  03816 E
                                §
               Debtors.         §  Jointly Administered Under
                                §  Case No. 90 B  03811 E


                       SETTLEMENT AGREEMENT
         REGARDING ENVIRONMENTAL CLAIMS (NOS.  8963, 8964,
      8965. 8966T OF THE MINNESOTA POLLUTION CONTROL AGENCY


     This Settlement Agreement  (the  "Agreement")  is entered  into

this  ^°  day of  .Say^—Ix^— /  1992, by and between  Amdura

Corporation, Reorganized Amdura,  Crosby American  Properties,

Inc., the Trustee for  the  Amdura  Liquidating Trust, and the

Minnesota Pollution Control  Agency.



     WHEREAS, on  April 2,  1990, Amdura Corporation ("Amdura")

filed its voluntary petition for  relief under  Chapter 11  of  the

BarJcruptcy  Code,  11 U.'S.C. Section  101 at  sea,  in the above-

captioned action (the Amdura bankruptcy proceeding) in the United

States"  Bankruptcy Court for the District  of Colorado; and

      WHEREAS, the Minnesota Pollution Control Agency ("MPCA") is

an  administrative agency of the state of Minnesota created,  by
                             EXHIBIT

                              A

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Minnesota  Statutes  §116.02 (1990),  acting for and on behalf of
the State  of Minnesota.
      WHEREAS,  on January 9,  1991,  the MPCA properly filed,  in the
Amdura banJcruptcy proceeding Proofs of Claim Nos. 8963,  8964,
8965 and 8966 on behalf of the KPCA and the State of Minnesota,
related to releases or threatened releases of hazardous
substances,  pollutants or contaminants at or from three
facilities located in the State of Minnesota specifically the CAP
Site, the Roberts Street Site and the WDE Site;  and
      WHEREAS, the claims of the MPCA in the Amdura BanJcruptcy
Proceedings arise under or are related to the Comprehensive
Environmental Response, Compensation and Liability Act, 42 U.S.C.
. §§ 9601 et sea.  (CERCLA), the Minnesota Environmental Response
 and Liability Act, Minn. Stat. §§ .1153.01 to 115B.24  (MERLA) , and
the United States BanJcruptcy Code; and
      WHEREAS, the claims.of the MPCA involve or  are related to
 the  -ffect of releases  or threatened releases of hazardous
 substances, pollutants  or contaminants at  or from the three
 facilities;  and
      WHEREAS, the  MPCA is authorized by  law to investigate,
• remove or remedy releases or threatened  releases of hazardous
            .      •             - '  '  '        . >'
 substances,  pollutants'or contaminants at or from the three
 facilities,  and recover costs so incurred solely from any or all
 responsible parties, including Amdura and the Reorganized Aiadura,
 if found responsible; and
                                 -2-

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     WHEREAS, one or more responsible parties have agreed to
undertake or have undertaken remedies affecting releases at or
froxa two of the three facilities in lieu of the MPCA taking such
action and seeking to recover its costs from those parties; and
     WHEREAS, on May 22, 1991, Aadura filed Objections to Proofs
of Claim Nos. 8963, 8965, and 8966, and on July 11, 1991, filed
an Objection to Proof of Claim 8964; and
     WHEREAS, MPCA filed its responses to Amdura's Objections to
Proofs of Claim Nos. 8963,  8965, and 8966 on June 5, 1991, and
its Response to Amdura's objection to Proof of Claim No. 8964 on
July 25, 1991; and
     WHEREAS, pursuant  to the Order of the Bankruptcy Court dated
June-5,  1991, establishing  a procedure for the resolution of
clains objections, the  MPCA filed  a written statement with Amdura
explaining the basis  for its  claims and the reason  for  responding
to Amdura's  objections; and
     WHEREAS, on September  19,  1991,  the  Bankruptcy Court entered
an Order confirming Amdura's Fifth Amended Joint  Plan of
Reorganization;  and
     WHEREAS, pursuant to the confirmed Amdura Reorganization
Plan,  Amdura has become the Reorganized Amdura,  and the Amdura
                                          - >               •
Liquidating Trust has been established to hold property to be
used by the Trustee to pay general unsecured claims in the Amdura
bankruptcy proceeding; and

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     WHEREAS,  in accordance with the Orders of the Bankruptcy
Court establishing procedures for resolution of claims
objections, the MPCA, Reorganized Amdura and the Trustee have
engaged in good faith discussions of settlement of the HPCA's
claims and, pursuant to those discussions, have reached an
agreement to compromise and fully and finally settle those claims
and to resolve all of the settlors' liability with respect to the
CAP site, the Roberts Street site, and the WDE site? and
     WHEREAS, this Agreement has been approved by the Board of  •
the MPCA after public notice and opportunity for public comment
at a meeting held on September 22, 1992; and
     WHEREAS, the parties to this Agreement believe that the
settlement of the MPCA claims as provided  in this Agreement  is
fair and reasonable, and is  in the public  interest.
     NOW, THEREFORE, in consideration of the recitals and the
mutual covenants contained! herein, and the mutual benefits to be
derived therefrom,  the receipt and sufficiency of which is hereby
acknowledged, the  Parties do STIPULATE AND AGREE as follows:
                     I. JURISDICTION  AND VENUE
     This  court has jurisdiction over the subject matter  of  this
action, and. over the Parties to this  Agreement  pursuant to 28
U.S.C.  §§1334,  157(a)  and 157(b),  and General Procedural Order
1984-3  of  the United States District Court for the District  of
Colorado.
                                -4-

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     This Agreement shall apply to and be binding upon the
      *
following Parties, who shall not contest its validity in any
subsequent proceeding:
          A.   Amdura, Reorganized Amdura, and their
               predecessors, successors and assigns;
          B.   Crosby American Properties, Inc.;
          C.   the Trustee on behalf of the Amdura Liquidating
               Trust; and
          D.   the MPCA, its successors or assigns.
                         III.  DEFINITIONS
      1.   "Agreement" means this Settlement Agreement by and
between Amdura, Reorganized Amdura, Crosby American Properties,
Inc., the Trustee and the HPCA in the Amdura bankruptcy
proceeding.
      2.   "Amdura" is Amdura  Corporation, a Delaware Corporation
as defined  in the Fifth Amended Joint Plan of Reorganization, As
Modified, With Respect  to Amdura, as confirmed  by Order of  the
Bankruptcy  Court on September 19, 1991.
     • 3.    "Amdura Liquidating Trust'1  is the Amdura Liquidating
Trust as defined in the Fifth Amended Joint Plan of
       '                                  •  >            .      .
Reorganization, As Modified,  With Respect to Amdura,  as confirmed
by Order of the Bankruptcy Court on September 19, 1991.
      4.   "Bankruptcy Court" or "Court" means the United States
 Bankruptcy Court  for the District of Colorado.
                                 •3-

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     5.   "Amdura Bankruptcy Proceedings" means all natters,
actions and proceedings in In. re:  Amdura Corporation, No.
90 .B 038HE: Amdura National Distribution Company, f/k/a FOK, No.
90 B 03812A; Coast America Corporation,  No. 90 B 03813D; Coast to
Coast Holdings, Inc., No. 90 B 03814D;  Coast to Coast Stores,
Inc., No. 90 B 03815J; and Intertrade Cargo, Inc., No.
90 B 03816E, filed in the United States Bankruptcy Court for the
District of Colorado.
     6.   "CAP Administrative Claim" means Proof of Claim No.
8965 filed by the KPCA in the Amdura Bankruptcy Proceedings and  •
any  and all claims or causes of action the KPCA has or may have,
whether known or unknown, that could have been made or set forth
in the.Amdura Bankruptcy Proceedings, including but not  limited
to those under  § 107(a) cf CERCLA, §§ 115B.03, 115B.04,  115B.17
or 115B.1S  of MERIA,  or  § 7003 of the Resource Conservation  and
Recovery Act, that directly  or indirectly  arise from  or  are  in-
any  way  related to transactions  (including but not limited  to  any
such claims made through or  on behalf of the  KPCA) or occurrences
 (including  but not  limited to releases  or  threatened releases  of
hazardous  substances, pollutants  or contaminants  and the effects
thereof)  involving,  connected to, or in anyway related to  the
 CAP  site'or the PBSL/CAP site.          '
      7.    "CAP Site" is that part of .the PBSL/CAP site consisting
 of the Crosby American Properties,  Inc. Landfill, in the city of
 Ir.ver Grove Heights, Dakota County,  Minnesota owned by Crosby
                                -6-

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American Properties, Inc., a wholly owned subsidiary of Amdura,
which MPCA, in Proof of Claim No. 8965, alleges to be the alter
ego of Amdura.
     8.   "CAP Unsecured Claim" means Proof of Claim No. 8966
filed by the MPCA in the Amdura Bankruptcy Proceedings and any
and all claims or causes of action the MPCA has or may have,
whether known or unknown, that could have been made or set forth
in the Amdura Bankruptcy Proceedings, including but not limited
to those under § 107(a) of CERCLA, §§ 1158.03, 115B.04, 1158.17
or 1153.18 of MERLA, or § 7003 of the Resource Conservation  and  .
Recovery Act, that  directly or indirectly arise from or are  in
any way related to  transactions  (including but not  limited to  any
such claims made through  or on behalf of the  MPCA)  or  occurrences
 (including but not  limited to releases  or threatened releases  of
hazardous  substances,  pollutants  or  contaminants  and the  effects
thereof)  involving, connected to,  or in any way related to the
CAP  site  or  the  PBSL/CAP  site.
      9.    "Consent Order" is  the "Response Order  by Consent  in
the.Matter of the Crosby American Properties, Inc.  Landfill,"
 attached  to  this Settlement Agreement as Exhibit "A."
      10.   "Crosby American. Properties,  Inc."  means the Minnesota
     •                          ''••>'
 corporation that is -a wholly owned subsidiary of Amdura.
      11.   "MPCA Claims" means the CAP Administrative Claim<  the
 CAP Unsecured Claim, the Roberts Street Claim, and the WDE Claim.

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     12.  "Farcies" means Amdura, Reorganized Amdura, Crosby
American Properties, Inc., the Trustee, and the MPCA.
     13.  "Pine Bend Sanitary Landfill/Crosby American
Properties, Inc. Demolition Landfill Site" or "PBSL/CAP Site", is
a site listed on the Minnesota Permanent List of Priorities under
MZRLA.
     14.  "Reorganized Amdura" is the Reorganized Amdura, a
Delaware Corporation, as defined in the Fifth Amended Joint Plain
of Reorganization,  As Modified, With Respect to Amdura, as
confirmed by Order  of the Bankruptcy Court on September 19, 1991..
     15.  "Roberts  Street Claim" means Proof of Claim No. 8963
filed by 'the MPCA  in the Amdura  Bankruptcy Proceedings and any
and  all claims  or  causes of  action the MPCA has or may have,
whether known or unknown, that could have been made  or set forth
in the Amdura Bankruptcy  Proceedings,  including but  not  limited
'to those under  § 107(a)  of  CERCLA,  §§  115B.03, 115B.04,  11SB.17
or 115B.18  of MERLA,  or §  7003 of the-Resource Conservation and
Recovery Act, -that either directly  or  indirectly  arise from or
are. in any way  related to transactions (including but not limited
to any such claims made through or on behalf of  the MPCA) or
occurrences- (including but not limited to releases or threatened
           *                               • '
releases of hazardous substance, pollutants or contaminants and
the  effects thereof) involving,  connected to, or in any way
related to the Roberts Street Site.
                                 -8-

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     16.   "Roberts Street Site" means the property 'formerly owned
and operated by Amdura as a.hoist and derrick manufacturing
facility located on South Roberts Street in the city of St.. Paul,
Ramsey County, Minnesota.
     17.   "Settlors" means Amdura, the Reorganized Aiadura, Crosby
American Properties, Inc. and the Trustee on behalf of the Amdura
Liquidating Trust.
     18.   The "Trustee" or the "Trustee on behalf of the Amdura
Liquidating Trust" is.the Amdura Trustee as defined in the Fifth'
Amended Joint Plan of Reorganization, As Modified, With Respect
to Amdura, as confirmed by Order of the Bankruptcy Court on
September 19, 1991.
     19.  "WDE Claim" means Proof of Claim No.  8964 filed by  the
MPCA in the Aiadura Bankruptcy  Proceedings and  any  and  all claims'
or causes of  action the MPCA has  or may have,  whether  known or
unknown, that could have been  made or set forth in the Amdura
Bankruptcy Proceedings,  including but not limited  to those under
§ 107(a) of  CSRCIA, §§ 1158.03,  115B.04, 1158.17 or  1158.18 of
MERLA, or §  7003  of the  Resource conservation and Recovery Act,
that  either  directly  or  in'directly arise from or are in any way
relatec, to transactions  (including but  not limited to any such
claims made  through or on behalf of  the MPCA)  or occurrences
 (including  bu- not limited to releases  or threatened releases of
hazardous  substance,  pollutants or contaminants anc the. effects

-------
thereof) involving, connected to, or in any way related to the
WDE Site.
     20.  "WDE Site" means the Waste Disposal Engineering
Landfill Site, in the city of Andover, AnoJca County, Minnesota,
at which MPCA alleges that Aisdura arranged for the disposal, or
the transport for disposal, of certain hazardous substances.
                         IV.  AGREEMENTS
A.   settlers7 Obligations
     1.   Reorganized Amdura shall have executed the Consent
Order a copy of which is attached as Exhibit "A", prior to
submitting the Agreement to the  Court for approval.
     2.  . The. Trustee hereby allows the claim of the HPCA for
costs to respond to releases or  threatened releases of hazardous
substances, pollutants  or  contaminants at the.Roberts Street
Site, designated as Proof  of Claim No. 8963, in the amount  of
$944,817.18,  and such claim shall be  paid in the same time  and
manner  as all other allowed general unsecured claims pursuant  to
Article IV, Section 4.5 of the Fifth  Amended Joint Plan  of
Reorganization,  as modified, with respect to Amdura,  as  confirmed
by order of the Bankruptcy Court on September  19,  1991,  and not
later than  11 days after entry of an. order jdt  the Court  approving
this Settlement Agreement, the Trustee shall execute an agreed
order that allows the claim as a general,  unsecured claim in the
amount of $944,817.18, and that statas substantially that the
MPCA is prohibited from ever reasserting Claim  No. 8963 and  is
                                 •10-

-------
prohibited from ever commencing or pursuing any administrative,
legal or equitable action against Amdura based in whole or in
part on the claims or causes of action asserted in Claim No.
8963.
     3.   The Trustee hereby allows the claim of the MPCA for
costs to respond to releases or threatened releases of hazardous
substances, pollutants or contaminants at the WDE site,
designated as Proof of Claim No. 8964, in the amount of
$213,118.00, and such amount shall be paid in the same time and
manner as all other allowed general unsecured claims pursuant to
Article IV, Section 4.5 of the Fifth Amended Joint Plan of
Reorganization, as modified, with respect to Amdura, as confirmed
by order of the bankruptcy court on September 19, 1991, and not
later than 11 days after entry of an order of the Court approving
this Settlement Agreement, the Trustee shall execute an agreed
order that allows the claim as a general unsecured claim in that
amount, and that states, substantially that the MPCA is prohibited
from ever  reasserting Claim  No. 8964 and is prohibited from ever
commencing or pursuing  any administrative, legal  or equitable
action  against  Amdura based  in  whole  or  in part.on the claims or
causes  of  action asserted in Claim No.  8964t.
    "4.  '  The Settlors  hereby release and waive  the  right  to
assert any claims or causes  of action against the KPCA,  its,
members or employees,  arising from or related to the release or
threatened release of any h-zardous substance,  pollutant or

-------
contaminant at Che CAP Site,  Roberts Street site or WDEl Site.
Nothing in this paragraph shall  waive any right of the Settlors
to enforce the terms and conditions of this Agreement or of the
Reorganized Amdura to enforce the terms and conditions of the
Consent Order.
B.   MPCA's  Obligations
     1.   Upon receipt of the agreed orders executed by the
Trustee as described herein,  the KPCA shall execute the agreed
orders allowing the Roberts Street Claim in the amount of
$944,817.18, and allowing the WDE Claim ir. the amount of.
$212,532.15, .and shall submit them to the Court.  The KPCA hereby
withdraws with prejudice both the CAP Administrative Claim and
the CAP Unsecured Claim, and is prohibited from ever reasserting
Claim Nos. 8965 and 8966 and is prohibited from commencing or
pursuing any  administrative, legal or equitable action against.
Amdura based  in whole or in part on the claims and causes of
action asserted in Claim Nos. 8965 and 8966, provided- however,
that the KPCA has reserved its rights to seek enforcement of the
Consent Order attached  as Exhibit A to this Settlement Agreement.
.The KPCA shall execute an order  that withdraws the CAP
Administrative Claim and the CAP Unsecured Claim  with prejudice.
The  order  shall  further' provide  that  in  the event the order
approving  this Settlement Agreement is vacated or otherwise
rendered  ineffective,  Claim Nos. 8965 and 8966 shall be deemed
                               -12-

-------
not to have been withdrawn and the KPCA may pursue the claims in
the Amdura Bankruptcy Proceedings.
     2.   The MPCA shall not directly or indirectly commence or
pursue in the Bankruptcy Proceedings any action regarding or any
appeal cf any order concerning Proofs of Claim Nos. 8963, 8965,
8966 and 8964 as resolved under this Agreement.
     3.   The MPCA shall not directly or indirectly commence or
pursue any administrative', legal or equitable action  (including
but not limited to an action to recover civil penalties, or past
or future response costs incurred) against the Settlors based in
whole or in part, on the MPCA Claims, provided, however, that the
MPCA reserves the right to seek enforcement of the Consent Order.
C.   General Conditions
     1.   The Parties agree that  this Agreement embodies a
"settlement," as that term is used in Section  113(f)(2)  of
CERCLA, 42 U.S.C. Section .9613(f)(2), as amended,  and the
                        •
Settlors are entitled, with respect  to  the CAP Site,  the PBSL/CAP
Site, the Roberts Street Site and the WDE Site, to contribution
protection and  to contribution  from  any person not a party to
this Agreement  to the. extent provided by  Section  113(f)(2) and
 (3) of  CERCIA,  42 U.S.C.  §§  9613(f)(2)  and  (3)  for matters
            •                                -*
addressed  in th,is  Agreement.
      2.    Nothing in this Agreement is  intended to nor shall be
construed  to release any claims,  prevent the commencement of any
causes of  actions,  or bar any demands in lav or equity which may

-------
be ma'de by the MPCA against any person,  firm,  partnership,
corporation or other entity that is not a party to this Agreement
or expressly bound by its terms for any liability arising out of
the release or threatened release of any hazardous substances,
pollutants or contaminants at or from the PBSL/CAF Si-^e, the
Roberts Street Site or the WDE Site.
     3.   Nothing in this Agreement shall be construed to prevent
the enforcement of the Consent Order in a court other than this
Court, to the extent that such enforcement is provided by the
terns of the Consent Order.
     4.   Reorganized Amdura and the MPCA may amend the Consent
Order by execution of a written amendment in accordance vith the
provisions of the Consent Order, and such amendment shall not
require the  approval of this Court.
     5.   This  agreement vas entered into .to compromise disputed
claims.  The Settlors by entering  into this Agreement do  not
intend to make  any admission concerning  facts or lav, but only
wish to  avoid the expense  of preparing for  litigation concerning
the KPCA Claims.   Settlors do  not  admit  any allegation  in any  of
the• MPCA's  proofs of claim nor in  the.Consent Order.   This
Agreement and the Consent Order shall. not he admissible in
evidence in any proceeding other than  a  proceeding for
enforcement of this Agreement or the Consent Order.  The Settlors
by executing this Agreement are not admitting or confessing to
 the allegations, conclusions or inferences contained in any proof
                                -14-

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of claim the MPCA has filed in the Amdura Bankruptcy Proceedings
or in the Consent Order which allegations, conclusions or
inferences the Settlors have always strongly denied.  Neither
this Agreement nor the Consent Order shall constitute
adjudication of fact or law, an admission, a judicial admission,
an admission against interest or otherwise, and shall not be
admitted against any party hereto in any legal proceeding except
in an action by a Party.to enforce the terms and provisions of
this Agreement or the Consent Order.
     6.   The originals of all documents or instruments
pertaining to any. distribution by the Trustee on account of the
MPCA claims shall be sent to:  Commissioner, Minnesota Pollution
Control Agency, 520 Lafayette Road, St. Paul, Minnesota 55155,
with a copy to the Minnesota Attorney General's Office,
Environmental Protection Division,  Suite  200, 520  Lafayette Road,
St. Paul, Minnesota 55155..  Transmission  of any funds in payment
on the MPCA claims shall be in the  fora of a check payable to* the
Commissioner  of the Minnesota Pollution Control Agency and such
check shall reference  which site is involved.
     7.   Except  for paragraph  8 below, this Agreement and the  •
Consent  Order shall  not be binding upon the^. Parties hereto until
the  Agreement has been duly approved by  the Court.  Upon approval
by the  Court, this Agreement and the Consent Order shall be
binding on the Parties hereto.   Following such approval,
Reorganized Amdura shall fulfill its obligations under the

-------
consent Order consistent with the schedule set forth in the
Consent Order, unless the order approving this Agreement is
subsequently stayed, vacated, or otherwise rendered ineffective.
     8.   within ten days after execution of this  Agreement,
Reorganized Andura and the Trustee shall cause to  be -submitted  to
the Court a motion for approval of this Agreement,  shall provide
proper notice of this motion to all interested parties as
required by the Rules of Bankruptcy Procedure or by order of the
Court, and shall prosecute that motion with due diligence.
     9 .   To the extent there is any conflict between the Consent-
Order  and the order confirming Amdura's Fifth Amended Joint Plan
of Reorganization, the Consent Order shall control.  In all other
respects the Order of "Confirmation shall remain in full force and
effect.
     10.  By  their  signatures to this Agreement, each of the
        t                  %
undersigned certifies that he or she is  fully authorized to
execute  this  Agreement  and to bind the respective Parties to it.
           TEE PASTIES TO TEE SETTLEXZ1TT AGRE2HZHT HAVE EXECUTED
 THIS SETTLEKEHT AGREEMENT IHTEKDIKG .TO BE  BOUHD THEREBY :
 For Aadura.and the Reorganized Amdura     >'.
 By:
-2-?2.
                                -16-

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For The Amdura Liquidating Trust
   Trustee
                                            7/27/9
Date f
          I
For Crosby American Properties,  Inc.
                                       Date   '<  .7
For Minnesota Pollution Control
   Charles W; Williams, Commissioner
   Minnesota Pollution Control Agency
   Daniel D. Foley,
      Chairman
   Minnesota Pollution control Agency
Date
Datfe
•And Hubert K. Humphrey, III
     Attorney General
     State of Minnesota
 Bv:
                                        Date
 O:\02781\02250\SS031736

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                                ATTACHMENT 5


              PINE BEND ADMINISTRATIVE RECORD
                      -SffE^^
 •   REMEDIAL INVESTIGATION WORK PLAN
    HARDING LA WSON ASSOCIATES/PACE LABORATORIES, INC7SUNDE ENGINEERING
 •   REPONSE ORDER BY CONSENT
    MINNESOTA POLLUTION CONTROL AGENCY
    APRIL 23,1985
 •   REMEDIAL INVESTIGATION AND FEASIBILITY STUDY: EVALUATION REPORT/
    ALTERNATIVE RESPONSE ACTIONS/REMEDIAL INVESTIGATION WORK PLAN/
    QUALITY ASSURANCE PROJECT PLAN
    BFI WASTE SYSTEMS
    JULY 1985
 •   POSSIBLE ALTERNATIVE RESPONSE ACTIONS
    HARDING LA WSON ASSOCIATES
    JULY 22,1985
 •   REVISION PAGES TO THE STATEMENT OF WORK FOR ORGANICS ANALYSIS MULTI-
    MEDIA MULTI-CONCENTRATION
    RCOCY MOUNTAIN ANALYTICAL LABORATORY
    MAY 1984, REVISED JANUARY 1986	

 *   QUALITY ASSURANCE PROJECT PLAN FOR 465.B VOLATILE ORGANICS
    PACE LABORATORIES, ING   .
    RECEIVED APRIL I4» 1986  •            	

 »   QUALITY ASSURANCE PROJECT PLAN FOR PRIORITY POLLUTANT METALS AND
    CYANIDE
    PACE LABORATORIES, INC,
    RECEIVED APRIL 14.1986:	

••.  QUALITY ASSURANCE PROJECT PLAN SUBMITTALS
    PACE LABORATORIES^ INCL    .
    APRIL 8,1985:-APRIL 29,1987	'
   REMEDIAL INVESTIGATION VOLUME I
   BFI WASTE SYSTEMS?
   NOVEMBER? 1987
    REMEDIAL INVESTIGATION VOLUME II (PART I)
    BFI WASTE SYSTEMS
    NOVEMBER 1987
    REMEDIAL INVESTIGATION VOLUME II (PART 2)
    BFI WASTE SYSTEMS.
    NOVEMBER 1987

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   FEASIBILITY STUDY ALTERNATIVES REPORT: DOWNGRADIENT WATER USER
   OPERABLE UNIT
   HARDING LAWSON ASSOCIATES/SUNDE ENGINEERING, INC.
   JANUARY 1989
•  FEASIBILITY STUDY: SOUTHERN WATER SYSTEM
   PROGRESSIVE CONSULTING ENGINEERS, INC.
   OCTOBER 1990
   AMENDED RESPONSE ORDER BY CONSENT
   MINNESOTA POLLUTION CONTROL AGENCY
   OCTOBER 23, 1990
»  ADDENDUM 1 TO THE FEASIBILITY STUDY: SOUTHERN WATER SYSTEM
   PROGRESSIVE CONSULTING ENGINEERS, INC.
   NOVEMBER 1990
•  ADDENDUM 2 TO THE FEASIBILITY STUDY: SOUTHERN WATER SYSTEM
   PROGRESSIVE CONSULTING ENGINEERS, INC.
   APRIL 1991	;	•

*  PUBLIC MEETING ON THE FEASIBILITY STUDY/PROPOSED PLAN FOR AN
   ALTERNATIVE WATER SUPPLY FOR RESIDENTS AFFECTED BY PINE BEND/
   CROSBY AMERICAN PROPERTIES LANDFILLS
   MAY IS, 1991      	.	

•  QUESTIONNAIRES TO IMPACTED CITIZENS REGARDING ALTERNATE WATER SUPPLY
   RECEIVED JUNE - JULY 1991
   UPDATED REMEDIAL INVESTIGATION FINAL REPORT VOLUME 1 OF 2
   GERAGHTY & MILLER, ING.
   AUGUST 1991
   UPDATED REMEDIAL INVESTIGATION FINAL REPORT VOLUME 2 OF 2
   GERAGHTY & MILLER, INC.:
   AUGUST 1991
   UPDATE TO THE FEASIBILITY STUDY: SOUTHERN WATER SYSTEM
   PROGRESSIVE CONSULTING ENGINEERS. INC.
• :  DETAILED ANALYSIS REPORT VOLUME I OF 2
   GERAGHTY& MILLER, ING.
   JUNE 17,1994	
•  DETAILED ANALYSIS REPORT VOLUME 2 OF 2
   GERAGHTY & MILLER, INC.
   JUNE 17,1994
   PERMIT APPLICATION
   JUNE 6,1995

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 •   PUBLIC INFORMATION MEETING
    JUNE 28,1995
 •   COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY
    ACTOF1980(CERCLA)
    1980
 •   MINNESOTA ENVIRONMENTAL RESPONSE AND LIABILITY ACT (MERLA)
    1983 _ _

~   THE SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT OF 1986 (SARA -
    WITHIN CERCLA)
    1986 _ _ '

T   PERFORMANCE OF RCRA METHOD 8280 FOR THE ANALYSIS OF DIBENZO-R-DIOXINS
    AND DIBENZOFURANS IN HAZARDOUS WASTE SAMPLES
    ENVIRONMENTAL PROTECTION AGENCY
    APRIL 1986 _ _ _ _ ___

 «   DRAFT RCRA METHOD 8280 WITH REVISIONS BASED ON MULTI-LABORATORY   ~~
    TESTING: METHOD OF ANALYSIS FOR POLYCHLORINATED DffiENZO-E-DIOXINS
    AND POLYCHLORINATED DIBENZOFURANS
    JUNE 12. 1986 _ •   _

 •   GUIDANCE ON PREPARING SUPERFUND DECISION DOCUMENTS: THE PROPOSED
    PLAN; THE RECORD OF DECISION, EXPLANATION OF SIGNIFICANT DIFFERENCES*
    THE RECORD OF DEaSION AMENDMENT, INTERIM FINAL
    OFFICE OF EMERGENCY AND REMEDIAL RESPONSE/EPA
    JULY 1988?           _ _ _

1   GUIDANCE FOR CONDUCTING REMEDIAL INVESTIGATIONS AND FEASIBILITY
    STUDIES UNDER CERCLA. INTERIM FINAL
    OFFICE OF EMERGENCY AND REMEDIAL RESPONSE/EPA
    OCTOBER
    MINNESOTA SUPERFUND FACT SHEETS 1-9
   -MINNiSQTAPOU,imONCONTROL AGENCY
    MAYTANBNOVEMERfvl98S
    DETERMINING SOIL RESPONSE ACTION LEVELS BASED ON POTENTIAL
    CONTAMINANTMIGRATION TO GROUND WATER: A COMPENDIUM OF EXAMPLES
    OFFICE OF EMERGENCY AND REMEDIAL RESPONSE/EPA
    OCTOBER 1989                                          -
 •   NATIONAL OIL AND HAZARDOUS SUBSTANCES POLLUTION CONTINGENCY PLAN,
    FINAL RULE (NATIONAL CONTINGENCY PLAN)
    ENVIRONMENTAL PROTECTION AGENCY
    MARCH 8,1990	

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 •   CONDUCTING REMEDIAL INVESTIGATION/FEASIBILITY STUDIES FOR CERCLA
    MUNICIPAL LANDFILL SITES
    OFFICE OF EMERGENCY AND REMEDIAL RESPONSE/EPA
    FEBRUARY I99t	

~JSUPERFUND PERMANENT LIST OF PRIORITIES            '•             '
    MINNESOTA POLLUTION CONTROL AGENCY
    PUBLISHED ANNUALLY	

 UPDATED AUGUST 3, 1995

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