PB95-964116
EPA/ROD/R05-95/291
February 1996
EPA Superfund
Record of Decision:
Reilly Tar and Chemical Corp.,
St. Louis Park, MN
6/30/1995
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Reilly Tar and Chemical Corporation Site
Northern Area of the Platteville Aquifer
St. Louis Park, Minnesota
STATEMENT OF BASIS AND PURPOSE
This decision document represents the selected remedial actions for the Northern Area of the
Platteville Aquifer, Reilly Tar and Chemical Corporation Site (the "Site"), developed 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 Oil and Hazardous Substances Pollution Control
Plan.
This decision is based upon the contents of the Administrative Record for the Site. The
attached index identifies the documents which comprise the Administrative Record upon
which the selection of the remedial action is based. The U.S. Environmental Protection
Agency and the State of Minnesota agree on the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the Northern Area of the
Platteville Aquifer at this Site, if not addressed by implementing the response action selected
in this Record of Decision, may present an imminent and substantial endangerment to public
health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The objectives of the response actions approved for the Site are to protect public health,
welfare, and the environment, and to comply with applicable federal and state laws.
The Northern Area of the Platteville Aquifer represents one operable unit within the overall
Site strategy. This remedy addresses only the Northern Area of the Platteville Aquifer, and
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will prevent the further spread of ground water contaminated with Polynuclear Aromatic
Hydrocarbons in this aquifer.
The major components of the selected remedy include:
1) The interception and containment of contaminants by use of a gradient control
well, which will prevent the further spread of contaminated ground water in the
Northern Area of the Platteville Aquifer.
2.) The discharge from the new well will initially be routed to the sanitary
sewer for treatment at the Metropolitan Council Environmental Services
wastewater treatment plant to remove contaminants from the collected ground
water.
3.) Continued water level and water quality monitoring of the ground water
contaminant plume during remediation activities.
4.) Within three to five years, it is anticipated that the water quality of ground
water pumped from the gradient control well will be improved sufficiently to
meet National Pollutant Discharge Elimination System (NPDES) limits. This
would allow the city to route the ground water pumped from the gradient
control well to a storm sewer for eventual discharge to Minnehaha Creek. If
necessary, an off-site treatment facility, will be built to treat ground water
discharge from the gradient control well and a NPDES permit will be obtained
for the discharge from such facility.
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 technologies to
the maximum extent practicable and satisfies the statutory preference for remedies that employ
treatment that reduces toxicity, mobility, or volume as a principal element. Because this remedy
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will result in hazardous substances remaining on site above health-based levels,
a review will be conducted within five years after commencement of remedial action to ensure that
the remedy continues to provide adequate protection of human health and the environment.
Date7
Vkldas V. Adamkus
Regional Administrator, Region V
U.S. Environmental Protection
Agency
7
W/Williams
Commissioner
Minnesota Pollution Control
Agency
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DECISION SUMMARY FOR THE RECORD OF DECISION
REILLY TAR AND CHEMICAL COMPANY CORPORATION SITE
I. SITE NAME, LOCATION, AND DESCRIPTION
The Reilly Tar and Chemical site (the Site) is defined in Part C.I of the Consent Decree and in
Section 1.21 of the Remedial Action Plan (RAP) as the 80 acre property where Reilly Industries
(Reilly) operated a coal tar refinery and wood preserving plant. The Site is located hi the western
part of the Twin Cities metropolitan area, in St. Louis Park, Minnesota (Figure 1). The
approximate location of this Site is west of Gorham, Republic and Louisiana Avenues, south of 32nd
Street, east of Pennsylvania Avenue and north of Walker Street.
This Record of Decision (ROD) addresses the contamination in the Northern Area of the Platteville
Aquifer underlying the Site. The Northern Area is located adjacent to the Site and is bounded by
West 32nd Street to the north, Alabama Avenue to the east, Highway 7 to the south, and Louisiana
Avenue to the west. The Platteville Aquifer is composed of glacially deposited sand and gravel, and
begins at 70 feet and extends to 100 feet below the ground surface. There are no wells that use the
Northern Area of the Platteville Aquifer for drinking water.
H. SITE HISTORY AND ENFORCEMENT ACTIVITIES
Site History
The Site history information summarized in this section is excerpted from the Proposed Plan for the
Northern Area of the Platteville Aquifer Report dated May 1995.
Between 1917 and 1972, Reilly operated a coal tar distillation and wood treatment plant, known as
the Republic Creosote Company, on 80 acres of land in St. Louis Park (the "City"). See Figure 1.
Wastewater containing creosote and coal tar from plant operations was discharged to a ditch that
drained to a swamp south of the Site.
Additional releases of creosote and coal tar resulted from drippings and spills onto the soil at the
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Site. These releases led to extensive soil, surface water and ground water contamination, not only
at the Site, but also in areas downstream and downgradient (i.e., south and east) from the Site
• (Figures 1 and 2).
The major constituents of coal tar are phenolic compounds and Polynuclear Aromatic Hydrocarbons
(PAHs). Some PAH compounds are carcinogenic and are a concern when they occur as
contaminants in a source or potential source of drinking water. As used here, "contaminated" or
"contamination" means that PAHs or phenolics are present in the soil, surface water or ground
water due to the wood treatment activities of Reilly at the Site. ,
Due to extensive residential development in the area around the Site in the 1940s and into the 1950s,
complaints about shallow well contamination and odor (i.e., air quality) problems became common.
As a result of the continuing problems with air emissions, and soil and surface water contamination,
the City and the Minnesota Pollution Control Agency (MPCA) filed suit against Reilly in 1970. In
1972, the City purchased the Site from Reilly, and the plant was dismantled and removed. The City
dropped its lawsuit against Reilly as a condition of the sale. The MPCA's suit was eventually
dismissed as a part of a comprehensive settlement in 1986.
In the mid 1970s, Louisiana Avenue was constructed through the Site and some multi-family
housing units were constructed on the northern half of the Site. In 1978, the Minnesota Department
of Health (MDH) began a program to analyze water from municipal wells in the City and nearby
communities for trace concentrations of PAHs. The City uses ground water from the St. Peter,
Prairie du Chien-Jordan, and Mt. Simon-Hinckley Aquifers as sources of drinking water. Nearby
communities, such as Hopkins and Edina, rely primarily on the Prairie du Chien-Jordan Aquifer for
their drinking water. During the period from 1978 to 1981, the analytical program revealed
unexpectedly high concentrations of PAHs in six city wells and one well in the city of Hopkins. As
the PAH contamination in these municipal wells was discovered, the wells were closed.
In 1978, after results of the MDH program indicated that extensive ground water contamination had
occurred, the MPCA amended its complaint in the lawsuit with Reilly to include claims for ground
water contamination. Subsequent legal actions were taken by the U.S. Environmental Protection
Agency and the Minnesota Pollution Control Agency (the Agencies) against Reilly under the
Resource Conservation and Recovery Act (RCRA), Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA), and Minnesota Environmental Response and Liability
Act (MERLA). Both Agencies instituted administrative actions against Reilly pursuant to the
applicable federal and state Superfund acts. In these actions the Agencies sought to compel Reilly to
undertake necessary remedial actions. Following the administrative actions, negotiations resumed
between the U.S. Environmental Protection Agency (EPA), MPCA, the City, and Reilly. A general
agreement for the remediation of the Site was reached in the summer of 1985. However, because of
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the complex nature of the agreement and the number of parties involved, final agreement was
delayed until September 1986. The agreement is embodied in the Consent Decree/Remedial Action
Plan (CD/RAP) entered by the U.S. District Court for the District of Minnesota in U.S. vs. Reilly
Tar (Case No. 4-80-469).
The remedial action discussed in this ROD is the latest in a series of remedial actions at the Site.
The remedy as described in this ROD is specifically intended to prevent the further spread of
contaminated ground water in the Northern Area of the Platteville Aquifer, and, as such, is only one
part of the overall remediation of the Site. The following is a list of completed and ongoing
remedial actions that are required by the CD/RAP:
Ground Water Sampling (CD/RAP Section 3) A sampling plan, which specifies municipal and
monitoring wells to be sampled during the coming calendar year, is submitted each year for
Agencies' approval. Reilly may propose to cease monitoring certain wells, to change monitoring
locations, to change analytical procedures, or to implement such other changes that may be effective
in achieving the monitoring objectives of the RAP.
By March 15 of each year, an annual report presenting the analytical results of the previous year's
sampling is submitted for the Agencies' approval.
Drinking Water Treatment Systems at St. Louis Park (SLP) Municipal Wells 10 & 15
(CD/RAP Section 4) Reilly submitted plans and specifications for the construction of a granular
activated carbon (GAC) treatment system at SLP 10 & 15. The treatment system has been
constructed and has been hi operation and maintenance (O&M) since June 25, 1986. Monitoring of
the treatment system is according to the Annual Sampling Plan.
Mt. Simon-Hinckley Aquifer (CD/RAP Section 5) Annual sampling of the Mt. Simon-HinckJey
wells is ongoing. Municipal drinking water from this Aquifer will be treated with GAC if the
monitoring data show that drinking water criteria (defined in Section Vin below) have been
exceeded. Monitoring of the Mt. Simon-Hinckley Aquifer will continue for the duration of the
CD/RAP according to the Annual Sampling Plan.
Ironton-Galesville Aquifer (CD/RAP Section 6) Source control well W105 began operating in
November 1987. Having met the cessation criteria outlined in the CD/RAP, the Agencies granted
the City's request to cease pumping, and the pump was turned off in December 1991. Monitoring
of well W105 will continue for the duration of the CD/RAP according to the Annual Sampling Plan.
Prairie du Chien-Jordan Aquifer (CD/RAP Section 7) As noted above, drinking water from City
Wells 10 and 15 currently undergoes treatment with GAC as outlined hi a ROD issued on June 6,
1984, and according to Section 4 of the CD/RAP.
Source control well W23 has been pumping at a rate of 50 gpm since November 1987 to control the
spread of contaminated ground water. Water from the well undergoes GAC treatment before being
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discharged to Minnehaha Creek. Municipal Well SLP 4 has been pumping at a rate of 1200 gpm
since August 19, 1992, for drinking water supply. In addition to providing drinking water, the
pumping of SLP 4 also provides gradient control of the aquifer. Monitoring of wells in the Prairie
du Chien-Jordan Aquifer is according to the Annual Sampling Plan.
St. Peter Aquifer (CD/RAP Section 8) Gradient control well W410 began pumping at a rate of 70
gpm in May 1991. Discharge from the well is currently being routed to the sanitary sewer for
treatment. This remedial action was detailed hi a September 28, 1990, ROD. Monitoring of wells
in the St. Peter Aquifer is according to the Annual Sampling Plan.
Drift and Platteville Aquifers (CD/RAP Section 9.1 & 9.2) Drift source control well W420 and
Platteville source control well W421 have been operating since October 1987 at the CD/RAP
required pumping rates of 40 gpm and 25 gpm respectively. Discharge water from these wells
undergoes GAC treatment and is subsequently released into Minnehaha Creek. Drift gradient
control well W422 has been pumping since October 1987 at the CD/RAP required rate of 50 gpm
with its discharge being routed to the sanitary sewer for treatment. Monitoring of wells in the Drift
and Platteville Aquifers is according to the Annual Sampling Plan.
Drift Aquifer Northern Area (CD/RAP Section 9.3, 9.4 & 9.5) A ROD was issued by the
Agencies on September 30, 1992, and the City has constructed the Remedial Action (RA) according
to the Northern Area Drift Aquifer Gradient Control Well Plan approved on May 9, 1994. On
December 15, 1994, the City notified the Agencies that the RA was complete. The MPCA
inspected the gradient control well on January 3, 1995, and the RA began full-scale operation within
ten days of the inspection date. Monitoring of wells in the Northern Area of the Drift and
Platteville Aquifers is according to the Annual Sampling Plan.
Leaking Multi-Aquifer Wells (CD/RAP Section 10.1) Reilly has submitted an Investigation Plan
for the multi-aquifer wells open to the Mt. Simon-Hinckley, Ironton-Galesville, or Prairie du Chien-
Jordan Aquifers. The City received the Agencies' approval of the Plan on February 14, 1994.
Reilly had one year from receipt of approval notification of the Plan to complete the investigation
and submit a report to the Agencies for approval. The City has submitted the multi-aquifer report
which the Agencies are presently evaluating.
Leaking Multi-Aquifer Wells (CD/RAP Section 10.2) Reilly has submitted an Investigation Plan
for the multi-aquifer wells open to the St. Peter Aquifer. The City received the Agencies' approval
of the Plan on February 14, 1994. Reilly had one year from receipt of approval notification of the
Plan to complete the investigation and submit a report to the Agencies for approval. The City
submitted the multi-aquifer report which the Agencies are presently evaluating.
Near Surface Contamination (CD/RAP Section 11) A contaminated wetland to the south of the
Site was filled hi 1986. A soil investigation conducted hi September 1988 found no further soil
contamination in the area of investigation defined hi the CD/RAP. Before undertaking any
construction or demolition activity onsite, a plan shall be submitted for Agency review according to
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Part G of the Consent Decree.
Contingent Actions For Municipal Drinking Water Supply Wells (CD/RAP Section 12) If any
analytical results of any samples taken from an active municipal drinking water well exceed a
Drinking Water Advisory Level, this section identifies the requirements and contingency actions
which shall be taken.
HI. HIGHLIGHTS OF COMMUNITY PARTICIPATION
Various community relations activities were conducted to solicit public comment on the proposed
plan for the Northern Area of the Platteville Aquifer. A fact sheet of the Proposed Plan was mailed
in May 1995 (Attachment 1). MPCA issued a news release on May 9, 1995 which indicated the
availability of the Proposed Plan and also announced the duration of the public comment period
(Attachment 2). The MPCA published an announcement of the public meeting and public comment
period in the Star Tribune newspaper on May 9, 1995 (Attachment 3). The public comment period,
specified in the news release and the Star Tribune, was from May 10, 1995, through June 9, 1995.
The Agencies also held a public meeting on May 23, 1995, at the City Council chambers to present
the Remedial Investigation and Feasibility Study (RI/FS) and the Proposed Plan for containing the
spread of contaminated ground water. All of these documents are available at the St. Louis Park
Public Library which is the repository for the Site. Comments received during the public cor
period were to be considered in the Agencies' final decision hi selecting a remedial alternative.
comments were received on the Proposed Plan during the comment period or public meeting.
IV. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION WITHIN SITE
STRATEGY
This ROD summarizes the alternatives considered for the Northern Area of the Platteville Aquifer
and, in particular, formally evaluates the preferred alternative specified in the CD/RAP against the
nine criteria identified in Section VIII of the ROD. The preferred remedy consists of using a
gradient control well to prevent the further spread of contaminated ground water hi the Northern
Area of the Platteville Aquifer.
In accordance with the remedial objective stated hi the CD/RAP of maintaining drinking water
quality in the Northern Area of the Platteville Aquifer, this alternative addresses water quality hi the
Northern Area of the Platteville Aquifer. The CD/RAP specified that: "The Regional Administrator
and The Director (Commissioner) may, for the purpose of preventing the further spread of ground
water exceeding any of the drinking water criteria defined hi Section 2.2, require Reilly to install
and operate a gradient control well system consisting of one or more gradient control wells." The
Northern Area of the Platteville Aquifer gradient control well will operate independently of other
remedial actions required by the CD/RAP for the purpose of preventing the further spread of
contamination. Remedial Actions (RAs) taken at other areas of the Site may, however, influence
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the duration of this alternative.
The activities described in this ROD are intended to remediate the contamination in the Northern
Area of the Platteville Aquifer, which is one of the six aquifers underlying the Site. The full range
of site-related activities that address other remaining contamination issues is specified hi the
CD/RAP. This RA is the final major action required by the CD/RAP to address site contamination.
V. SUMMARY OF SITE CHARACTERISTICS
Contamination in the Northern Area of the Platteville Aquifer exists in the form of dissolved
concentrations of PAHs in the ground water. PAHs may have arrived hi the Northern Area of the
Platteville Aquifer by dissolved PAHs following ground water flow patterns from the Drift-
Platteville Aquifer. Migration of PAHs through this pathway has created the current plume of
dissolved contaminants in the Northern Area of the Platteville Aquifer. Based on these conditions,
the primary potential effects of contamination are on drinking water supplies and on the natural
resource value of uncontaminated portions of the aquifer.
The Remedial Investigation (RI) goal was to define the area of ground water contaminated with
PAHs above the drinking water criteria. The PAH and phenolic data results of ground water
monitoring since 1988 show that, near the source of contamination, PAH concentrations in ground
water are consistently in the range of several hundred nanograms per liter to high micrograms per
liter. The trend of this data suggests that contaminant levels have fluctuated approximately ten
percent in the past several years. Based on this ground water monitoring, the current interpretation
of the extent of contamination in the Northern Area of the Platteville Aquifer is shown in Figure 2.
VI. SUMMARY OF SITE RISKS
The ground water, soil and surface waters on and near the Site have been impacted by site-related
contaminants. This document represents the objectives of response actions for one operable unit,
the Northern Area of the Platteville Aquifer, within the overall site strategy. The purpose of this
section is to discuss the risks posed by contaminated ground water in the Northern Area of the
Platteville Aquifer to human health and the environment.
The exposure pathway of greatest concern for human health is the ingestion of contaminated ground
water through drinking or cooking. Presently, there are no drinking water wells hi the Northern
Area of the Platteville Aquifer. The main supply of drinking water for the City is obtained from the
deeper bedrock aquifers. It is important to note that the Northern Area of the Platteville Aquifer is,
in places, hydraulically and geologically connected to the Drift and St. Peter Aquifers. In addition,
the Northern Area of the Drift-Platteville Aquifers provides recharge water for the bedrock aquifers.
Because of these factors, and because of the potential for future use of the Northern Area of the
Platteville Aquifer as a source of drinking water, exposure through ingestion of water from the
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Northern Area of the Platteville Aquifer is a primary concern.
Actual or threatened releases of hazardous substances from the site if not addressed by implementing-
the response action selected in this ROD, may present an imminent and substantial endangerment to
public health, welfare or, the environment. Drinking water criteria for site contaminants were
developed to establish safe levels for the public water supply. See Section VIII of this ROD for
actual drinking water criteria concentrations. The drinking water criteria for the site represent an
excess lifetime cancer risk of approximately 1 x 10"6. This means that a person using ground water
at the site for drinking, showering, etc. would have a 1 in 1,000,000 chance of exposure to a
carcinogenic compound. .
During the investigation of the ground water in the Northern Area of the Platteville Aquifer, PAH
concentrations ranging from several hundred nanograms per liter to high micrograms per liter were
detected. The concentrations of contaminants which were detected significantly exceed the drinking
water criteria and would thus pose an unacceptable risk to persons using this ground water. The
Platteville Aquifer is not currently used for drinking water; however, the potential may exist for
contamination to migrate down to deeper bedrock aquifers used for the public water supply.
The remedy will contain the spread of contaminated ground water through interception and
containment effects created by the pumping of a gradient control well, identified as well W440. By
containing the spread of contamination in the Northern Area of the Platteville Aquifer, the remedy
will preserve and protect the quality of ground water in the rest of the Platteville Aquifer and wi
also reduce the potential for additional contamination of deeper aquifers currently used for drinki
water supplies and on the natural resource value of uncontaminated portions of the aquifer.
VH. DESCRIPTION OF ALTERNATIVES
The purpose of the remedial action is to prevent, reduce, and control the spread of contamination in
the Northern Area of the Platteville Aquifer. The objective of this section is to provide an
understanding of the remedial alternatives developed for the Platteville Aquifer Northern Area of the
Site and their specific components.
Alternative 1: No Action Alternative
The National Contingency Plan (NCP) requires that the "No Action Alternative" be developed and
evaluated to serve as a baseline at every site for comparison with other alternatives. With this
alternative, no remedial efforts would be made to mitigate the effects of or control the migration of
ground water contaminants at the Reilly Tar and Chemical Corporation Site.
Alternative 2: Multiple Gradient Control Well(s).
This alternative includes the installation of four gradient control wells on the eastern edge of the
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Northern Area. Gradient control wells are ground water extraction wells that would be installed in
the downgradient portion of the Northern Area Platteville Aquifer to attempt to prevent contaminants
from migrating from the area. The wells would be six-inches or larger in diameter and open to the
Platteville Aquifer.
The discharge from the gradient control wells would be contaminated with PAHs and would initially
be routed to the sanitary sewer for treatment at the Metropolitan Council Environmental Services
(MCES) water treatment plant. The discharge would eventually be routed to the storm sewer or to
surface water, provided that all effluent limitations set by the CD/RAP or by National Pollutant
Discharge Elimination System (NPDES) permits are met. To meet discharge limitations, the
discharge may require treatment with activated carbon at a treatment facility that will be
constructed, if necessary. If this treatment facility is constructed off site, a NPDES permit will
need to be obtained from the MPCA. One of the requirements for implementing this remedy is
continued water level and water quality monitoring, not only to document the effectiveness of the
remedy, but also to determine the need for off-site treatment.
Alternative 3: Single Gradient Control Well.
Alternative 3 consists of the installation of a single gradient control well near the south eastern edge
of the Northern Area. This alternative utilizes the area with the highest aquifer transmissivity
within the Northern Area. A pumping well located near existing well W428 is expected to provide
the greatest degree of gradient control achievable, A new pumping well (designated W440),
constructed using water-production optimizing techniques, such as an over-size well diameter to
intercept more fractures in the Platteville Aquifer and/or gravel-packing the screen, will be utilized.
The proposed pumping rate for Well W440 is 50 gallons per minute on a continuous basis. The size
of the higher transmissivity zone near well W428 is not believed to be large enough to warrant
additional pumping wells to provide a greater degree of control at this time. Additional pumping
wells may be required if monitoring results warrant such action.
Similar to Alternative 2, the discharge from W440 would be contaminated with PAHs and will
initially be routed to the sanitary sewer for treatment at the MCES water treatment plant. In three
to five years, it is anticipated that the discharge will eventually be routed to the storm sewer or to
surface water provided that all effluent limitations set by the CD/RAP and by NPDES permits are
met. To meet discharge limitations, the discharge may require treatment with activated carbon at an
off-site treatment facility, if necessary. If this treatment facility is constructed, an NPDES permit
must be obtained from the MPCA. One of the requirements for implementing this remedy is
continued water level and water quality monitoring, not only to document the effectiveness of the
remedy, but also to determine the need for off-site treatment prior to discharge to the storm sewer
or to surface water.
. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
This section summarizes the relative performance of the remedial alternatives the City developed in
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the RI/FS. The alternatives were evaluated by the Agencies using EPA's nine criteria by comparf
the advantages and disadvantages of each alternative to evaluation criteria to identify the alternative
providing the best balance. The nine evaluation criteria are:
1.) Overall Protection of Human Health and the Environment addresses whether an
alternative provides adequate protection and describes how risks are eliminated, reduced
or controlled through treatment and engineering or institutional controls.
2.) Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
addresses whether an alternative will meet all of the applicable or relevant and
appropriate requirements or provide grounds for invoking a waiver.
3.) Long-term Effectiveness and Permanence refers to the ability of an alternative to
maintain reliable protection of human health and the environment, over time, once clean-
up objectives have been met.
4.) Reduction of Toxicity, Mobility or Volume Through Treatment addresses the statutory
preference for selecting remedial actions that employ treatment technologies that
permanently and significantly reduce the toxicity, mobility and volume of hazardous
substances as a principal element.
5.) Short-term Effectiveness involves the period of time needed to achieve protection and
any adverse impacts on human health and the environment that may be posed during the
construction and implementation period until clean-up objectives are achieved.
6.) Implementability is the technical and administrative feasibility of an alternative,
including the availability of goods and services needed to implement the remedy.
7.) Cost including capital costs, as well as O&M costs.
8.) Support Agency Acceptance indicates whether, based upon its review of the RI/FS and
Proposed Plan, the support agency, in this case U.S.EPA, agrees with the selected
alternative.
9.) Community Acceptance indicates the public acceptability of a given alternative. This
criteria is discussed hi the Responsiveness Summary.
The following is a detailed analysis of each of the evaluation criteria for the three alternatives
considered:
Overall Protection of Human Health and the Environment
Alternative 1, No Action, provides no additional protection of human health and the environment.
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The risks posed to human health would continue unabated. Contaminants would continue to
migrate, uncontrolled, from the facility to downgradient areas, possibly impacting other aquifers and
downgradient city water wells.
Alternatives 2 and 3 would provide protection of human health and the environment by restricting
the further spread of contaminants from the Northern Area.
Alternative 3 provides the greatest overall protection of human health and the environment by
limiting the further spread of contamination within the Northern Area of the aquifer. Well W440 is
located in the area of greatest transmissivity known in the Northern Area. At this time there are no
drinking water wells in the Platteville Aquifer and thus human exposure to the contamination is
limited.
The primary function of gradient control wells is to provide overall protection to uncontaminated
portions of the Northern Area of the Platteville Aquifer, a potential source of drinking water.
Alternative 3 will also reduce the potential for contamination of deeper aquifers currently used for
drinking water. By limiting the further spread of contamination, overall protection of the
environment will be achieved.
Compliance With ARARS
ARARs are defined in the CD/RAP, Sections 2.2 and 2.5. These two sections of the CD/RAP
define drinking water criteria and advisory levels, and surface water discharge criteria, respectively.
Drinking Water Criteria
Advisory Drinking Water
Level Criterion
The sum of benzo(a)pyrene 3.0 ng/1* 5.6 ng/1*
and dibenz(a,h)anthracene
Carcinogenic PAH 15 ng/1** 28 ng/1
Other PAH 175 ng/1 280 ng/1
* Or the lowest concentration that can be quantified, whichever is greater.
** ng/1 = nanogram/liter (1 part per trillion)
The Safe Drinking Water Act (SDWA) specifies Maximum Contaminant Levels (MCLs) for
drinking water from public water supplies. Since MCLs for PAH compounds were not developed
through the SDWA regulations, it was necessary to derive Site-specific drinking water criteria. This
was accomplished through consultations with representatives from MDH, MPCA and EPA. These
drinking water criteria are not ARARs since they are not promulgated requirements. However, the
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drinking water criteria are defined as a To Be Considered (TBC). TBCs are advisories, criteria,
guidance that were developed by EPA, other federal agencies or states that may be useful in
developing CERCLA remedies. The drinking water criteria developed for the site are as shown
above.
The Clean Water Act (CWA) and its implementing regulations are applicable to the proposed
remedial activities concerning the discharge of extracted ground water, or contaminated surface
water from the site, to either the surface water or the sanitary sewer. The CWA and its regulations
set forth permitting requirements for point source discharges that implement minimum treatment
technology standards and protect the quality of the receiving water. The conditions hi the CD/RAP
are intended to require full compliance with the CWA regarding NPDES permitting and
pretreatment requirements. The NPDES discharge limits are as shown below.
Surface Water Discharge Criteria (SWDC)
Daily Maximum 30-Day Average
Parameter Concentration
Concentration
Carcinogenic PAH - 65 ng/1*
Other PAH 34 ug/1** 17 ug/1
Phenanthrene 2 ug/1 1 ug/1
Phenols - 10 ug/1
*ng/l = nanogram/liter (1 part per trillion)
**ug/l = microgram/liter (1 part per billion)
RCRA may be an ARAR for the Site. If off-site treatment is required for the future discharge from
W440, the process will probably generate "spent carbon." This term refers to GAC contaminated
with PAHs. Spent carbon will be returned to the manufacturer for regeneration and reuse. If the
testing of spent carbon indicates that the carbon is a hazardous waste as defined by RCRA, and if
regulated quantities of spent carbon is generated, then the requirements of RCRA would be an
ARAR for the Site. The Land Ban requirements of RCRA will not apply to the disposal of spent
carbon since the carbon will be regenerated and re-used and no land disposal is contemplated.
Alternative 1 does not comply with the NCP requirements that ground water that is a current or a
potential source of drinking water be remediated to MCLs. This alternative does not achieve the
drinking water criteria, established for the site, which have been identified as TBCs.
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Alternatives 2 and 3 would meet ARARs, TBCs or other limits established by the Agencies. The
drinking water criteria will be used to assess the need for ground water control measures throughout
the aquifer, while discharge options for extracted ground water will be evaluated against the SWDC.
Long Term Effectiveness and Permanence
Alternative 1 does not provide an effective or permanent means of achieving the goals of the
CD/RAP. Significant risks would continue to be posed by site contaminants for a long time period.
Contaminants from the site would continue to migrate into the aquifer, and subsequently through the
aquifer, for an indefinite period of time. Over an extremely long tune period, some natural
attenuation of contamination in the aquifer would occur, as contaminants are spread over a larger
area and concentrations decrease somewhat due to dispersion, and possibly some degradation of
organic compounds. However, because of the environmental persistence of site contaminants and
the potential presence of residual PAHs in subsurface saturated soils remaining at the site under this
alternative, the time period required for natural attenuation to occur would be on the order of
centuries.
Alternative 2, the pumping of four gradient control wells, will not be entirely effective in preventing
the further spread of contamination, but can be used to reduce or limit the further spread of
contamination. The effectiveness of these wells would be very limited based on the size of their
capture zones. The variable transmissivity in the Northern Area precludes an accurate prediction of
the capture zones for the four wells. The transmissivity is lowest in the northern portion. Pumping
rates as low as 5 to 10 gallons per minute are not sustainable, and the resulting capture zones would
only be a few feet wide. However, the southernmost well adjacent to Well W 428 has shown a
relatively high transmissivity in short-term pump tests. The calculated capture zone of this location
from the short-term pump test (approximately 5000 feet at a pumping rate of 200 gallons per
minute) is unrealistic because the extent of the high transmissive zone is much less than 5000 feet,
and is not known if the short-term test results are applicable to a permanent pumping activity. The
variable transmissivity in this area leads to a range of predicted pumping rates of from less than 5
gallons per minute to 200 gallons per minute.
Alternative 3 is the best option for limiting the further spread of contamination within the Northern
Area. Well W440 to be constructed near Well W428 in the southeastern corner of the Northern
Area has shown the highest transmissivity in short-term pump tests. The production goal for W440
is approximately 50 gallons per minute on a continuous basis.
Once the response objective is met, and the further spread of contamination has been prevented,
residual levels of PAHs will remain hi the aquifer. On the basis of then- relatively large volume and
low mobility, residual PAHs are expected to remain in the aquifer for at least the 30-year life of the
CD/RAP. Pumping will continue as long as it is necessary to prevent the further spread of
contamination. The potential risks posed by residual contamination in the aquifer after plume
15
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management activities are concluded are very small because the spread of contamination will be
hydraulically controlled, and because the relatively low mobility of the PAH compounds will reduce
their tendency to migrate.
The potential need for additional response actions in portions of the Northern Area of the Platteville
Aquifer that are outside the influence of the pumping wells will be addressed based on future ground
water monitoring results. Monitoring of available wells completed in the Northern Area of the
Platteville Aquifer is ongoing. •. .
Reduction of Toxicity, Mobility, or Volume Through Treatment
Alternative 1 includes no treatment and therefore, provides no reduction in toxicity, mobility and
volume.
The most important feature of Alternatives 2 and 3 is the control exerted by the pumping well on
the volume and mobility of contaminants within the aquifer. During pumping, the more mobile
PAHs will be removed first, leaving less mobile PAHs hi the aquifer.
Although treatment of the pumped water under Alternatives 2 and 3 will only destroy a relatively
small portion of the total volume of contamination in the aquifer, alternatives 2 and 3 comply with
EPA's statutory mandate of treatment to the maximum extent practicable.
Short-Term Effectiveness
Alternative 1 provides no short-term effectiveness.
The construction and implementation of Alternatives 2 and 3 does not present a great potential for
worker or community exposure, and will not cause adverse environmental impacts. Alternative 2
potentially has four wells being installed versus one well for Alternative 3. During the short
construction project, the well(s) will be constructed, well house(s) will be built and well pumps
installed. During the construction activity, measures will be taken to minimize workers and
community exposure. These alternatives present no other short-term risks to the community at large.
Implementability
Alternative 1 is technically implementable, since it requires no action. However, this alternative is
not acceptable because it does not protect human health and the environment nor does it meet
ARARS.
The heterogeneous and low transmissive nature of the Platteville Aquifer creates difficult conditions
for siting new well locations hi the Northern Area; however, short-term pump tests have identified
the most feasible well siting locations. There are no outstanding issues relative to the technical
16
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feasibility of implementing Alternative 2 or 3. The technology for pumping ground water is
reliable, and easy to maintain. There should be little potential for schedule delays, or conflicts with
other remedial actions taken at the Site. Repair work on system components will be similarly
straightforward. Services and materials for this work are all available at competitive bid prices, and
will not limit the implementability of this alternative.
There are no administration problems that would prevent implementation of the preferred
alternative. Similar remedial actions are currently being practiced elsewhere at the Site. Other
Agencies such as the MCES, the Minnesota Department of Natural Resources, and/or the
Minnehaha Creek Watershed District have a precedent to follow in dealing with impacts from this
remedial action.
Costs
Alternative 1 has no costs.
Project costs for Alternative 2 are estimated at $400,000 for capital costs for equipment, installation,
engineering, permits, startup, and contingencies assuming four wells are installed. O&M, materials,
energy, disposal of residues, purchased services, administrative costs, and other post-construction
costs that may be required to ensure the effectiveness of this remedial action are estimated at no
more than $120,000 per year. Major components of the annual O&M costs include: sewer charges
of $32,000, electricity costs of $8,000 and labor costs of $80,000. If a treatment facility is required
for surface water disposal, the capital cost of the facility is estimated at $ 500,000.
Costs identified for Alternative 3 hi the FS for the installation of W440 are approximately $100,000.
These costs would cover equipment, installation, engineering, permits, startup, and contingencies.
O&M, materials, energy, disposal of residues, purchased services, administrative costs, and other
post-construction costs that may be required to ensure the effectiveness of this remedial action are
estimated at no more than $30,000 per year. Major components of the annual O&M costs include:
sewer charges of $8,000, electricity costs of $2,000 and labor costs of $20,000. If a treatment
facility is required for surface water disposal, the capital cost of the facility is estimated at
$300,000.
If monitoring results indicate additional gradient control wells are needed for Alternatives 2 or 3, the
above anticipated cost for Alternative 3 would be required for each additional well needed to achieve
the remedial goals of the project.
Agency Acceptance
The Agencies concur with the remedy since it is protective of public health and the environment and
satisfies the nine required evaluation criteria. The remedy is also consistent with the remedial action
specified in the CD/RAP.
17
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In summary, Alternative 3 provides the best balance of tradeoffs among available alternatives \
respect to the criteria used to evaluate remedies. Based on information available at this time, the
Agencies believe the selected alternative will protect human health and the environment, will comply.
with ARARs, will be cost-effective, and will utilize permanent solutions and alternative treatment
technologies or resources recovery technologies to the maximum extent practicable. This alternative
will satisfy the preference for treatment as a principal element to the maximum extent practicable.
Community Acceptance
There were no comments received during the public comment period on the Proposed Plan.
IX. SELECTED REMEDY
Alternative 3, which consists of the installation and pumping of well W440 to provide gradient
control, is the selected remedy. The well will be pumped at a rate, depending on the extent of
contamination hi the aquifer as determined by ground water monitoring, to control the further spread
of contamination in the Platteville Aquifer. The remedial action alternative involves the installation
of the pumping well W440, building a new well house and installing appropriate pumping equipment
in the well.
For the first five years following the effective date of this ROD, ground water samples will be
collected on a semiannual basis from the following wells: Wl, W18, W19, W20, W22, W27,
W101, W120, W121, W124, W130, W131, W143, W420, W421, W422, W424, W426, W428,
W431, W432, W433, W434, SLP3, and from the new gradient control well W440 constructed
under this remedy. These samples will be analyzed for carcinogenic PAHs and other PAHs listed in
Appendix A of the CD/RAP. The sampling results will be reported and summarized in table
format in the Annual Monitoring Report, which is submitted to the Agencies by March 15th of each
year.
The Platteville Aquifer wells to be sampled and the frequency of sampling will be re-evaluated after
the five year period. Water level measurements will be taken at all the above wells on a quarterly
basis for the first year, and semiannually thereafter. If the proposed range of pumping rates is not
sufficient to control the spread of contamination, additional wells may be required for gradient
control.
Well W440 will initially discharge to the MCES wastewater treatment plant for treatment of the
contaminated ground water. The discharge will be monitored, as stated above, to determine if
treatment is necessary to route the discharge to a storm water sewer within approximately three to
five years. If necessary, an off-site treatment facility will be built to ensure that the ground water
meets NPDES limits.
The selected remedy is consistent with the CD/RAP, Section 9.5 which specifies the installation and
operation of one or more gradient control wells to prevent the further spread of ground water
18
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exceeding any of the drinking water criteria defined in CD/RAP Section 2.2. Because the CD/RAP
requires that the Potentially Responsible Parties (PRPs) control the gradient in the Northern Area of
the Platteville Aquifer and specifies this particular remedial action, the analysis of this alternative
builds on various earlier studies, referenced in the CD/RAP, that developed and screened
alternatives.
X. STATUTORY DETERMINATIONS
The selected remedy must satisfy the requirements of Section 121 of CERCLA, which are:
1.) Protect human health and the environment;
2.) Comply with ARARs or justify a waiver;
3.) Be cost effective;
4.) Utilize permanent solutions and alternative technologies or resource recovery
technologies to the maximum extent practical; and
5.) Satisfy the preference for treatment as a principal element or explain why preference was
not satisfied.
Protection of Human Health and the Environment
The selected remedy provides overall protection of human health and the environment by limiting
the spread of contamination within the aquifer. The most important effect of this remedy is to
provide protection to uncontaminated portions of the Northern Area of the Platteville Aquifer, thus
achieving overall protection of the environment.
Compliance with ARARs
The selected remedy will meet all ARARs of federal law or more stringent state laws. The
following discussion provides details of the ARARs that will be met by this remedial action.
SDWA
As previously discussed in Section VIII of this ROD, the drinking water criteria developed for this
Site are a TBC. The remedial action is required by the CD/RAP to prevent the spread of
contaminated ground water in the aquifer that exceeds these drinking water criteria.
CWA
SWDC for the Site are set forth in Section Vm of this ROD. Treatment of the discharge from well
W440 will initially occur at the MCES wastewater treatment plant. The discharge from the Site will
comply with the pretreatment requirements of the CWA (40 CFR Part 403). In three to five years,
the ground water from the gradient control wells may be discharged to a storm sewer. The
19
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discharge to the storm sewer will require a NPDES permit which will incorporate the surface watel
discharge criteria identified above. An off-site treatment facility may be necessary so that the
discharge from the wells will meet NPDES permit limits.
RCRA
RCRA may be an ARAR for the Site. If treatment is required for the discharge from the wells, the
process will generate "spent carbon." This term refers to GAC contaminated with PAHs. "Spent
carbon" will be tested before being returned to the manufacturer for regeneration and reuse. If the :
testing of the spent carbon determines it to be a hazardous waste as defined by RCRA, and if
regulated quantities are generated, then the requirements of RCRA would be an ARAR for the Site.
The Land Ban requirements of RCRA do not apply to the disposal of spent carbon since the carbon
is to be regenerated and reused and no land disposal is contemplated.
Cost Effectiveness
The installation of W440 is approximately $100,000. These costs would cover equipment,
installation, engineering, permits, startup, and contingencies. O&M, materials, energy, disposal of
residues, purchased services, administrative costs, and other post-construction costs that may be
required to ensure the effectiveness of this remedial action is estimated at no more than $30,000 per
year. Major components of the annual O&M costs include: sewer charges of $ 8,000, electricity
costs of $ 2,000 and labor costs of $20,000. If a treatment facility is required for surface water
disposal, the capital cost of the facility is estimated at $300,000. The selected remedy was the mosH
cost-effective of the alternatives evaluated, exclusive of the no action alternative.
Utilize Permanent Solutions and Alternative Technologies or Resource Recovery Technologies
to the Maximum Extent Possible
The PAHs are expected to remain in the aquifer for at least the 30 year life of the CD/RAP.
Pumping will continue as long as necessary to contain the spread of contamination in the aquifer
above drinking water criteria levels. Pumping is a standard, reliable and proven technology for
meeting remedial objectives. In three to five years, the discharge from the gradient control wells
may be routed to the storm sewer at which time off-site treatment may be necessary to meet NPDES
discharge limits.
Satisfy the Preference for Treatment as a Principal Element
The most important feature of this alternative is the control exerted by the pumping well on the
volume and mobility of contaminants within the aquifer. During pumping, the more mobile PAHs
will be removed first, leaving less mobile PAHs in the aquifer that will be released slowly over
time. As previously indicated, this alternative is primarily intended to control the spread of
contamination. However, the extracted ground water will be treated in a publicly-owned treatment
works initially, and hi an off-site treatment facility in the future, if surface water discharge near the
20
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site is implemented.
21
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Reillv Tar and Chemical Corporation
St. Louis Park Minnesota
****************************
Responsiveness Summary
Introduction
This community responsiveness summary has been developed to document community involvement
and concerns during the selection of a clean-up remedy for the Northern Area of the Platteville
Aquifer at the Reilly Tar Superfund site in St. Louis Park, Minnesota, and to respond to comments
received during the public comment period on the Feasibility Study/Proposed Plan.
Responsiveness Summary for the Record of Decision
I. Overview
The Minnesota Pollution Control Agency's (MPCA) and the U.S. Environmental Protection
Agency's (EPA) recommended clean-up alternative for the Reilly Tar Site (Site) was announced to
the community through a news release to local newspapers, a legal notice hi the local newspaper of
record, and a fact sheet mailed to the media and all interested parties. The recommended alternative
is to install and operate an extraction well in the Northern Area of the Platteville Aquifer, with the
discharge from the well going directly to the sanitary sewer system.
The Site has a long and complicated history of investigation and cleanup. The cleanup has been
divided into a number of operable units, with the Northern Area constituting a relatively small part
of the overall effort. Since the remedy is basically an expansion of actions already operating for
Platteville Aquifer under the Consent Decree, it may be understandable that despite public
notification and solicitation of comment, there has been almost no public interest hi this proposal or
operable unit.
Public interest does remain high hi ensuring the safety of local drinking water supplies, and also in
possible future remedial actions to address the source of the contamination; however, those issues
are only indirectly related to this operable unit and are not addressed hi this responsiveness
summary.
Following is the chronology of community relations actions performed to support the selection of a
remedy for this operable unit.
n. Background on Community Involvement
1.) Proposed Plan fact sheet mailed to media and interested parties, May 9, 1995,
Attachment 1.
2.) News release for the Proposed Plan, May 9, 1995 (Attachment 2). Advertisement hi Star
Tribune newspaper of legal notice of Proposed Plan public meeting, May 9, 1995
-------
(Attachment 3).
3.) Public meeting on Proposed Plan, May 23, 1995. (Following the execution of the ROD,
a legal notice of its availability will be published in the local newspaper of record. It is
anticipated this will occur in July 1995).
III. Public Comment on Proposed Plan/Feasibility Study
The public comment period on the Proposed Plan and Feasibility Study extended from May 10,
1995, to June 9, 1995. The Proposed Plan was summarized in a fact sheet distributed to local
media, government officials, and interested parties. A public meeting on the Proposed Plan was
held in St. Louis Park on May 23, 1995.
Only a few interested parties attended the meeting. A few questions were asked after the Agencies'
presentation, but most of the questions were for clarification. The transcript of the meeting shows
that no substantive comments were expressed that would require response from the MPCA or
U.S. EPA.
No other comments were received by the Agencies either during or after the comment period.
-------
N
j Northern Area Boundary •
^' -''' .-«'.^' "~^>
FIGURE 1
w Constdting
and Engineering
Location of Well W440
St. Louis Park, Minnesota
fil£ 1520-007
DATE; 2/27/95
riU. NO. 1620-007
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Uill LU UJ yJ LIJ m UJ LJJ
COMMUNITYO4W428
\
Pai its
Mar Bettmlc Wefls
nottnik
Infened Exlert of
Comcmncnon in
Nonnern Area of
Hcflmle
Consulting and
Figure 2
Platteville Aquifer Wells for
Water Quality Monitoring
SL Louis Park, MN
OUMt US I BUt VVT7
iru. 10.-
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ATTACHMENT 1
Minnesota Pollution Control Agency
A Superfund Fact Sheet on
Reilly Tar and Chemical:
Platteville Aquifer Northern Area
May 1995
This fact sheet summarizes the
cleanup plan for the northern area of
the Platteville aquifer, beneath the
Reilly Tar and Chemical site, as
proposed by the U.S. Environmental
Protection Agency (EPA) and Minne-
sota Pollution Control Agency
(MPCA). The proposed plan follows
an extensive investigation of ground-
water contamination in the Platteville
aquifer northern area and a study of
possible cleanup options.
This site in St. Louis Park is north of
Highway 7 and west of Louisiana
Avenue. Oak Park Village condo-
miniums are located on the northern
portion of the site.
What is the history of the site?
Between 1918 and 1972, Republic
Creosote, a subsidiary of Reilly Tar
and Chemical Corporation, operated a
coal-tar distillation and wood-preserv-
ing plant on an 80-acre site in SL
Louis Park. During those years,
wastewater from the distillation
process was disposed of in a series of
ditches emptying into a swampy area
south of the site. Spills and leaks also
contaminated the surface soils, and
tar-like materials were found deep in
an on-site well.
The ground water in the area of the
ReiUy site is contaminated with
creosote and polynuclear aromatic
hydrocarbons (PAHs). Contamination
was detected in public water supplies
as early as 1974. The site has been the
object of state and federal Superfund
investigation and cleanup actions since
the early 1980s. Although the imme-
diate drinking-water problems have
been resolved, ground water in the
area is still contaminated.
In 1986, the former owners of the
Reilly site, along with the City of St.
Louis Park, signed a Consent Decree
with the EPA and MPCA. Under this
agreement, the panics responsible for
the site are to continue investigating
the extent of the problem and conduct
necessary cleanup actions.
What is meant by the "Platteville
aquifer" and the "Northern Area?"
The Reilly site is underlain by six
separate aquifers flayers of earth and
porous rock containing ground water).
These aquifers are stacked on top of
one another, separated by various
confining layers, going down hundredi
of feet below the surface. All of them
are contaminated to varying degrees
beneath the area of the site. Because
The MPCA wants your opinion
The public is invited to comment on this proposed plan between
May 10 and June 9, 1995. The MPCA will present the plan at a
public meeting on Tuesday, May 23.1995, beginning at 7:00 p.m..
at the St. Louis Park City Hall. 5005 Minnetonka Boulevard.
Comments will be accepted at the meeting, or by phone or mail
during the above comment period.
For more information or to comment on the proposed plan.
contact:
Doug Beckwith. Project Manager
MPCA Ground Water and Solid Waste Division
520 Lafayette Road
St. Paul, MN 55155
(612)296-7792
Printed on recycled paper
with at least 10% post-consumer fibers.
-------
Page Three
Why was this plan chosen?
Remedies in Superfund cleanups
are evaluated against a number of
criteria. The proposed plan was
carefully considered in light of the
following criteria:
1. This remedy provides overall
protection of human health and the
environment by limiting the further
spread of contamination within the
aquifer.
2. The remedy complies with
applicable local requirements.
Ground water treated and
discharged from the MWCC's
treatment plant will meet state
surface-water criteria.
3. The toxicity, volume, and
mobility of the contaminants in the
aquifer will be effectively reduced
over time by the pump-out.
4. The remedy will provide long-
term effectiveness and permanence
by ensuring that the pump-out will
continue as long as necessary to
prevent the further spread of
contamination in the aquifer.
5. The construction and
implementation of this remedy
presents no worker or community
exposure, nor any adverse
environmental impacts.
6. The technology for this remedy
is proven, cost-effective, reliable,
and easy to maintain.
7. The final criteria are state and
community acceptance. The
MPCA prefers this remedy, and
now the community has an
opportunity to review and comment
on the proposed remedy before it
becomes final.
How long will the pump-out need
to continue?
Water coming from the pump-out
wells would be tested periodically,
and the pump-out would continue
until the wells produce water that is
within state guidelines for drinking
water. This may take as long as 30
years, and possibly longer.
What is being done to clean up
the other aquifers?
The other aquifers associated with
the site have their own
investigations and action plans.
They are all in various stages of
completion, but basically, the same
type of ground-water pump-and-
treat will be performed, with minor
variations, for each aquifer.
Ground water moves very slowly,
and the cleanup is keeping ahead of
the problem.
What is the next step?
The MPCA is holding a 30-day
public comment period on this
proposed plan, from May 10 to
June 9,1995. The comment period
includes a public meeting (see box
on first page) at which the MPCA
will discuss the proposed plan.
After considering the public's
comments, the MPCA will finalize
the cleanup alternatives for the
northern area of the Platteville
aquifer. The MPCA's response tc
comments will be available for
review at the St. Louis Park Publi
Library, along with the Record of
Decision for the site, which
documents the reasons foe this
cleanup plan. ' "
Comments or questions?
The compete reports of the
investigation and study of respons
alternatives for the northern area c
the Platteville aquifer are availabli
for review at the MPCA's St Paul
headquarters at 520 Lafayette Roa
In addition, the EPA maintains an
Information Repository containing
these documents at the St.
Park Public Library. Th
located at 3240 Library Lane in St.
Louis Park, Minnesota.
For additional information or to
comment on the proposed cleanup
plan, please contact:
Doug Beckwith, Project Manager
Ground Water/Solid Waste Divisic
MPCA
520 Lafayette Road
SL Paul, MN 55155
(612) 296-7792
Comments should be phoned in by
4:30 p.m. or postmarked no later
than midnight Friday, June 9,1995.
On request, this fact sheet can be
made available in Braille, large type or audio tape.
-------
ATTACHMENT 2
News Release
Minnesota Pollution Control Agency
520 Lafayette Road North, St. Paul, Minnesota 55155-4194
Printed on recycled paper with at
least 10% fibers from paper
recycled by consumers.
OR RELEASE: May 9, 1995 Contact: Emmy Reppe, (612) 296-6706 (voice)
(612) 282-5332 (TTY)
Toll free 1-800-657-3864 (vbice/TTY)
MPCA AND EPA PROPOSE CONTAINMENT PLAN
FOR REILLY TAR'S PLATTEVILLE AQUIFER
The Minnesota Pollution Control Agency (MPCA) and the U.S. Environmental Protection
Agency (EPA) today announced a proposed containment plan for the Platteville aquifer northern
area, beneath the Reilly Tar and Chemical Superfund site in St_ Louis Park. The agencies will
present the plan for public comment during a public meeting on Tuesday, May 23,1995, at 7:00
p.m. at the St. Louis Park City Hall, the MPCA said.
The 80-acre Reilly Tar and Chemical site was operated as a coal-tar distillation and wood-
preserving plant from 1918 to 1972. As a result of these activities, ground water in the area is
contaminated with creosote and polynuclear aromatic hydrocarbons (PAHs).
The site is underlain by six separate aquifers (layers of earth and porous rock containing
ground water). All six aquifers, stacked on top of one another, are contaminated to varying
degrees below the site. Each aquifer has or will have its own cleanup plan.
The current proposed plan deals only with the Platteville aquifer northern area, located
approximately 70 to 100 feet beneath the surface. The plan calls for installing an extraction well to
contain the spread of contaminated ground water. No drinking-water wells in the area use the
Platteville aquifer northern area.
The MPCA and EPA seek public comment on the proposed plan during a comment period
from May 10 to June 9,1995, as well as at the public meeting. Comments may be submitted to
Doug Beckwith of the MPCA at 520 Lafayette Rd, St. Paul, MN 55155; or call 612/296-7715
(toll-free in Minnesota, 1/800/657-3864). After comments are received at the public meeting and
during the comment period, the MPCA and EPA will make a final decision on the proposed plan.
it ft it
TTTrTr
-------
586301500
CLASS #203
71 .LINES
ATTACHMENT 3
MN Pollution Control Agency
Attention: Emmy Reppe
520 Lafayette Rd. N.
St. Paul, MN 55155-4102
RECE;VED
MPCA Inrorraarion Cenfer
7T ot pieces ^
MAY i f,
THE MINNESOTA
POLLUTION CONTROL
AGENCY
and me
- u.s. ENVIRONMENTAL
PROTECTION AGENCY
ANNOUNCE
a puOllc comment period *no
public me en ng regarding me >
Proposed Plan 10 control ma I
spread oi contaminated i
ground water at ma !
REtLLY TAft AND CHEMICAL
SUPEPFUNO SITE
In St. Louis Park. Minnesota
The Minnesota Pollution Con-
iroi Agency (MPCA) and me
U.S. Environmental Protection
Agency (U.S. EPA) announce a i
OuPiic comment period ana I
OUDIIC meeting regarding the |
Proooseo Plan to control me i
spread ot contaminated
grouna water at tna Reiiiy Tar
and Chemical Suoenuno Site
(Site). The Proooseo Plan is lor
control ol contamrnateo
I grouna water in tna Piatteviiie
aquifer. Nonnern Area. The
MPCA ana U.S. EPA orooose
adamg a pump-out wen in ma
aouiler to prevent lurtner mi-
gration ol contaminateo
' ground water.
' Tna public is invited to com-
! m«nt on mis Proposed Plan
l between May 10 and June 9.
i 1995. The MPCA will present
: me oian at a ouDiic meeting on
Tuesday. May 23 at 7:30 p.m.
Comments are welcome at me
mealing, or py pnona or mail
during the comment period.
The meeting wilt oe neid at:
SI. Louts Park City Hall
5005 Minnetonka Boulevard
The tacnnical documents used
to make mis cleanup decision
are available tor ouDiic viewing
al tna St. Louis Park Public Li-
brary. 3240 Library Lane. St.
Louis Park. Minnesota, and at
the MPCA's Central Ottica at
520 Latayetta Aoao in St. Paul.
For more information or to
comment on me Proposed
Plan, contact:
Doug Beckwitn
Ground Water and Solid Waste
Division. MPCA
520 Lafayette Road
St. Paul. MN 55155
(612)296-7715
Toll-free m Minnesota at
1(800)657-3864
STAR TRIBUNE
a. division of Cowles Media Company
STATE OF MINNESOTA
COUNTY OF HENNEPIN
ss.
AFFIDAVITOF PUBLICATION
Diane Kise. being duly swom. on oath says she is and during all times herein stated has been an
employee of the Star Tribune, publisher and printer of the newspaper, published 7 days a week, known as Star
Tribune and has full knowledge of the facts herein stated as follows:
(1) Said Newspaper is printed in die English language in newspaper format and in column and sheet
form equivalent in printed space to at lease 1200 square inches. (2) Said newspaper is printed daily and is
distributed at least five days each week. (3) Said newspaper has 25 per cent of its news columns devoted to news
of local interest to the community which it purports to serve and does not wholly duplicate any other publication.
(4) Said newspaper is circulated in and near the municipality which it purports to serve, has at least 500 copies
regularly delivered to paying subscribers and has entry as second-class matter in its local post office. (5) Said
Newspaper purports to serve the city of Minneapolis and vicinity in the County of Hennepin and has its known
office. of issue in the Ciry of Minneapolis, in said county. (6) Said newspaper files a copy of each issue
immediately with the State Historical Sociery, (7) Said newspaper is made available at single or subscription
prices to any person, partnership or other unincorporated association requesting the newspaper and making the
applicable payment. (8) Said newspaper has complied with all foregoing conditions for at least one year.
She further states on oath that the printed copy of the matter hereto attached as a pan hereof was
cut from the columns of the Star Tribune, and was printed and published therein in the English language, on
the following days and dales: Tuesday, 9 May 1995; and that the following is a printed copy of the lower
case alphabet from A to Z. both inclusive, ar.d is hereby acknowledged as being the size and type used in the
composition and publication of said nonce, to wit:
abcdefghijUnuiopqmuvwxyz
Diane Kise
12 day of May, 1995
VICKILHUSOME
NOTARY PUBUC • MINNESOTA
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U.S. EPA ADMINISTRATIVE RECORD
REMEDIAL ACTION
REILLY TAR & CHEMICAL/DRIFT PLATTEVILLE AQUIFER
ST. LOUIS PARK, MINNESOTA
UPDATE #2
O5/O4/95
AUTHOR
RECIPIENT
TITLE/DESCRIPTION
PASES
1 OS/27/90 Srsss, K.. ENS.R
04/12/91 Sruis, J.. City of
St. Lsuis rars
?ec*»ith, D., HPCA
Caens, y.
U.l. EPA
and BeckMith, 3.,
HPCA; et ai.
Letter -e: Addendus for Platteville Aquifer
Puipirg last
Letter r=: Expedited Schedule for the :
Suppleisntal Northern Area RI/FS a/Attached
EMSR Letter of April 9, 1991 to the City of
St. Louis Park
3 02/03/92 Sruce, J., City of
St. Louis Park
t. LGUIS rarr.
U.S. EPA, SPCA, and
.Seiily Industries,
Inc.
U.S. EPA, »PCA, and
fieiliy Industries,
Inc.
Letter re: Coipietion of the Installation of
the Platteville Aquifer Kcnitsr Veils and
Chances in Field Activities
PiatteviIIe Aquifer Northern Area Feasibility
Study »/Attached Cover Letter
17
5 12/23/93 Beckwith, D., «PCft
and Owens, D., U.S.
EPA
6 01/11/94 Srube, J., City of
St. Louis Park
City of St. Louis
Park and Reilly
Industries, Inc.
Letter re: HPCA/U.S. EPA's Review of the FS
and Request for an Aiended FS Plan
U.S. EPA, HPCA, and Letter re: City's Request for a 30 Day
Reilly Industries Extension to the Subiittal of the Proposed
List of Alternatives for the Amended FS and a
60 Day Extension to the Subaittal of the
Aiended FS Plan
7 02/09/94 Becmth, D., «?CA
and Osens, D., U.S.
EPA
City of St. Louis
Park and Reilly
Industries, Inc.
Letter re: BPCA/U.S. EPA's Approval for a 30
Day Extension for Subiittal of a Proposed
List cf Alternatives to the FS and a 60 Day
Extension for Subiittal of the Revised FS
8 02/23/94 Srube, J., City of
St. Louis Park
U.S. EPA, HPCA, and
Reilly Industries,
lac.
Letter re: Proposed List of Alternatives to
be Included in the Aiended FS
9 03/14/94 Srube, J., City of
St. Louis Park
U.S. EPA, HPCA, and
Reilly Industries,
Platteviiie Aquifer Northern Area Feasibility
Study a/Attached Cover Letter
inc.
37
10 C7/13/94
sruta, J., Citv of
:t. Lcuis Fsrk
U.S. EPA, HPCA, and
Reiiiy Industries,
In:.
Letts' '»: City's Asendient to the flarch 14,
1994 F:
St. Louis Park
L'.i. EPA, HPCA. snc Lsttsr '=: Request fcr Hcdificaticn to Add
Rsiily industries, *sll **34 tc the Drift Piatteviiie Aquifer
In:. Sradie'-t Centra! Nell Systsi
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OCt DATE
AUTHOR
RECIPIENT
TITLE/DESCRIPTION
PAEES
12 09/29/54 Secknith. 3., SrCft City of St. Lc-jis
and Ovens, 5.. L'.5. Park and R=ii!r
EPA industries, In:.
Letter re: Approval of City's Request to Add
fell M34 to the Drift rlsttsville Aquifer
Grandient Controi *sll Srstsa
13 10/12/54 Beckwith, D., fPCA City of St. Lcuis Letter re: BPCA/U.5. EPfl's Approval of
and Owens, D., U.S. Park and Reilir
EPA Industries, Inc.
Aiended Alternative 3 ts tie F5
H 02/23/95 Srsgg, «,, ESSR
Beckwith, D.. H?CA Letter Forwarding Attached 'Location of Neil
N44C' Rap
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GUIDANCE ADDENDUM
DOCUMENTS MAY BE VIEWED AT
U.S. EPA REGION 5
77 W. JACKSON BLVD.
CHICAGO, IL 6O6O4-359O
05/04/95
DOC! DATE
AUTHOR
RECIPIENT
TITLE/DESCRIPTION
PASES
10/00/63 U.S. EFA/DERR
U.S. EPA
07/00/89. U.S. EPA/OSHER U.S. EPA
3 03/03/90 rsdsral Register Public
4 05/00/90 U.S. EPA/OSHER U.S. EPA
Suidance for Conducting Resesiai
Investigations and Feasibility Studies Under
CERCLA (OSHER Directive 9355.3-01;
EPA/540./5-5?/004!
Interii Final guidance en Presaring Super-fund
Decision Docuients (OSHER Directive
9355.3-02)
National Oil and Hazardous Substances
Contingency Plan, Final Rule (Vol. 55:
8666-8665)
A Buide to Developing Superfund Proposed
Plans (OSHER Directive 9335.3-02FS-2)
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U.S. EPA ADMINISTRATIVE RECORD
REMEDIAL ACTION
REILLY TAR & CHEMICAL/DRIFT PLATTEVILLE AQUIFER
ST. LOUIS PARK, MINNESOTA
UPDATE »3
05/08/95
DATES AUTHOR RECIPIENT TTTT.E/DESCRIPTION PAGES
05/00/95 U.S. EPA, Superfund Program 17
MPCA Proposed Plan for the
Platteville Aquifer
Northern Area
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