Third Five-Year Review Report

For MacGillis & Gibbs Site

(MacGillis & Gibbs Company/Bell Lumber & Pole Company Superfund Site)

City of New Brighton

Ramsey County, Minnesota

June 2011

PREPARED BY:

Minnesota Pollution Control Agency St. Paul, Minnesota

For the

United States Environmental Protection Agency Region 5

Chicago, Illinois

Approved by: Date:

JeffLe~ Manage Closed Landfill and Superfund Section, Remedial Division

Approved by: Date:

_~tP-l~ Superfund Division United States Environmental Protection Agency

------------------------

Third Five-Year Review Report

For MacGillis & Gibbs Site

(MacGillis & Gibbs Company/Bell Lumber & Pole Company Superfund Site)

City of New Brighton

Ramsey County, Minnesota

June 2011

PREPARED BY:

Minnesota Pollution Control Agency St. Paul, Minnesota

For the

United States Environmental Protection Agency Region 5

Chicago, Illinois

Approved by: Date:

Jeff Lewii!' Manager Closed Landfill and Superfund Section, Remedial Division

Approved by: Date:

~~61A,~lchard C. Karl, Director

Superfund Division United States Environmental Protection Agency

T ABLE OF CONTENTS

LIST OF ACRONYMS EXECUTIVE SUl\1MARY FIVE-YEAR REVIEW SUMMARY FORM

I. INTRODUCTION .............................................................................................•........... 1 II. SITE CHRONOLOGY ........................................................................•....................... 2 III. BACKGROUND.............•......................•...........................................•..........•............ 4

Physical Characteristics ........................................................................................................ 4 Land and Resource Use ........................................................................................................ 5 History of Contamination ..................................................................................................... 5 Initial Response ..................................................................................................................... 5 Basis For Taking Action ....................................................................................................... 6

IV. REl\.fED IAL A CTI ONS .............•...................•.........•....................•...................•....... 6 Remedy Selection ................................................................................................................. 6 Remedy Implementation ....................................................................................................... 8 System Operations and Maintenance .................................................................................... 9

V. PROGRESS SINCE THE LAST REVIEW ........................................................... 13 VI. FIVE-YEAR REVIEW PROCESS ........................................................................ 14

Administrative Components ............................................................................................... 14 Community Involvement .................................................................................................... 14 Document Review............................................................................................................... 14 Data Review ........................................................................................................................ 14 Site Visit. ............................................................................................................................. 16 Interviews ............................................................................................................................ 16

VII. TECI-IN"ICAL ASSESSl\-'1ENT•••.••.•..•••••.•••.........•.•.....•.••.••...••.••••••..••.•.•••....•••..•••• 16 VIII. ISSUES .....................................................................•............................................ 19 IX. RECOJ.\lll\;lENDATIONS ........................................................................................ 19 X. PROTECTIVENESS STATEl\fENT ...................................................................... 20 XI. NEXT REVIEW ...................................................................................................... 20

APPENDIX A - FIGURES

APPENDIX B - BIBLIOGRAPHY

APPENDIX C - FIVE - YEAR REVIEW SITE INSPECTION CHECKLIST

APPENDIX D - NEWSPAPER ADD FOR FIVE- YEAR REVIEW and AFFIDAVIT OF PUBLICATION, September 29, 2010

APPENDIX E - PHOTOS DOCU1\1ENTING SITE CONDITIONS

APPENDIX F - SPECIAL WELL CONSTRUCTION AREA DESIGNATION

ARARs CCA CERCLA COC EC E&E EPA HRL IC LNAPL MCES MCLs MDH MERLA M&G MPCA NPL O&M OU PCP POTW PPA PRP RA RAO RCRA RifFS ROD RSE SDWA SWCA TCAAP UECA

List of Acronyms

Applicable or Relevant and Appropriate Requirements Chromated Copper Arsenate Comprehensive Environmental Response, Compensation, and Liability Act Contaminant of Concern Environmental Covenant Ecology and Environmental Services United States Environmental Protection Agency Health Risk Level Institutional Control Non-Aqueous Phase Liquid Metropolitan Council Environmental Services Maximum Contaminant Levels Minnesota Department of Health Minnesota Environmental Liability and Response Act MacGillis & Gibbs Minnesota Pollution Control Agency National Priorities List Operation and Maintenance Operable Unit Pentachlorophenol Publicly Owned Treatment Works Prospective Purchaser Agreement Potentially Responsible Party Remedial Action Remedial Action Objective Resource Conservation and Recovery Act Remedial Investigation/Feasibility Study Record of Decision Remediation System Evaluation Safe Drinking Water Act Special Well Construction Area Twin Cities Army Ammunition Plant Uniform Environmental Covenants Act

Executive Summary

The MacGillis & Gibbs (M&G) and Bell Lumber & Pole (Bell) site consists of two adjacent wood preserving facilities in a mixed residential/commercial area in the City of New Brighton, Minnesota. Both the M&G and the Bell facilities had been involved in wood preserving activities since the 1920's and the M&G facility ceased operations in 1997. The Bell facility is still active today. The cleanup at the Bell facility was undertaken under the Minnesota Environmental Response Liability Act (MERLA), while the site cleanup under CERCLA has been solely related to the M&G facility.

The site has been divided into three operable units: Operable Unit 1 (OU1) includes contaminated soils and debris in a former disposal pit area; Operable Unit 2 (OU2) includes the LNAPL plume and residuals and sludges; and Operable Unit 3 (OU3) includes contaminated soils (other than those addressed in OU1) and groundwater contamination. The remedy for the MacGillis Site includes stabilization and removal of chromated copper arsenic-contaminated soils, biotreatment of pentachlorophenol-contaminated soils, installation of a cap over soils heavily contaminated with organic compounds, and a groundwater pump and treat system to control the groundwater plume and to remove groundwater contamination. The trigger for this five-year review was the completion date for the previous five-year review, September 27,2006.

The remedy is considered protective of human health and the environment in the short term because there is no evidence of current exposures. However, in order for the remedy to be protective in the long term, groundwater cleanup goals must be achieved. The record of decision (ROD) estimated that groundwater cleanup goals would be achieved in 30 years. Also, the effectiveness of institutional controls should be determined by assuring that all necessary restrictions have been implemented to prevent exposure to contaminants in soil and groundwater from the site. Long term protectiveness also requires compliances with effective ICs so that the remedy continues to function as intended. An IC action plan will be prepared to plan additional IC evaluation activities and any corrective measures needed to ensure that effective ICs are implemented and procedures are in-place to ensure that the ICs are maintained, monitored and enforced for long-term site stewardship.

Five-Year Review Summary Form

SITI:' 1I)f.'NTII;/C\ TION

Site name (from WasteLAN): MacGillis and Gibbs Company/Bell Lumber and

Pole Company Superfund Site

EPA 10 (from WasteLAN): MND 006192694

Region: 5 IState: MN ICity/County: City of New Brighton /Ramsey Count

NPL status: Final

Remediation status: Complete

Multiple OUs?- Yes IConstruction completion date: 9/25/02

Has site been ut into reuse? Yes •

REVIFlY 5,1ATl'S

Lead agency: Minnesota Pollution Control Aqencv

Author name: Nile Fellows

Author title: Project Manager Author affiliation: Minnesota Pollution Control Agency

Review period: August 2010 through June 2011

Date(s) of site inspection: 10/19/2010 Type of review: Statutory

Review number: 3 (third)

Triggering action: D Actual RA Onsite Construction at OU # - DActual RA Start at OU#_ D Construction Completion X Previous Five-Year Review Report D Other (specify)

Triggering action date (from WasteLAN): 9/27/2006

Due date (five years after triggering action date): 9/27/2011 ."[OU" refers to operable unrt.]

Five-Year Review Summary Form, continued.

Issues:

IC Action Plan has not been completed.

Recommendations and Follow-up Actions:

IC Action Plan to be completed.

Protectiveness Statement(s): The remedy is considered protective of human health and the environment in the short term because there is no evidence of current exposures. However, in order for the remedy to be protective in the long term, groundwater cleanup goals must be achieved. Also, the effectiveness of institutional controls should be determined by assuring that all necessary restrictions have been implemented to prevent exposure to contaminants in soil and groundwater from the site. Long-term protectiveness also requires compliance with effective ICs so that the remedy continues to function as intended. An IC action plan will be prepared to plan additional IC evaluation activities and any corrective measures needed to ensure that effective ICs are implemented and procedures are in place to ensure that the ICs are maintained, monitored and enforced for long-term site stewardship.

Other Comments: The cost of Operations and Maintenance of the pump and treat system is high. A cost study should be considered prior to transferring operations to the State in 2012.

MacGillis & Gibbs Company/Bell Lumber & Pole Company Five-Year Review Report

I. Introduction

The purpose of a Five-Year review is to determine whether the remedy at a site is protective of human health and the environment. The methods, findings, and conclusions of such reviews are documented in Five-Year Review reports. In addition, Five-Year Review reports identify deficiencies found during the review, if any, and make recommendations to address them.

In cooperation with the United States Environmental Protection Agency (EPA) Region 5, the Minnesota Pollution Control Agency (MPCA) is preparing this Five-Year Review report pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) §121 and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). CERCLA §121(c), as amended, states:

If the President selects a remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the site, the President shall review such remedial action no less often than eachfive years after the initiation ofsuch remedial action to assure that human health and the environment are being protected by the remedial action being implemented. In addition, if upon such review it is the judgment of the President that action is appropriate at such site in accordance with section (104) or (106), the President shall take or require such action. The President shall report to the Congress a list offacilities for which such review is required, the results ofall such reviews, and any actions as a result ofsuch reviews.

EPA interpreted this requirement further in the NCP; 40 CFR §300.430(f)( 4 )(ii) of the Code of Federal Regulations (CFR) states:

Ifa remedial action is selected that results in hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such action no less often than every five years after the initiation ofthe selected remedial action.

This is the third Five-Year Review for this site. The triggering action for this review was the second Five-Year Review, which was completed on September 27,2006. Due to the fact that hazardous substances, pollutants, or contaminants remain at the site above levels that allow for unlimited use and unrestricted exposure, this Five-Year Review is required.

II. Site Chronology

Table 1 lists the chronology of events for the MacGillis & Gibbs/Bell Lumber & Pole site.

a e . rono ogy 0 f S·tI e EventsT bl 1 Ch Operable Unit 1/0perable Unit 3 Organic-Contaminated Soils

Event

Date

1979 Initial Discovery of Problem

1984 NPL Listing

12/31/92 RIIFS Complete

12/31/92 ROD Signature

9/30/99 ROD Amendment

12/14/99 Remedial Design Start

4/28/00 Remedial Design Com~lete 8/7/00 Remedial Action Start 11116/01 Remedial Action Complete

Operable Unit 2 / Residual sludges in storage and process tanks

Event

Date

9/30/91 RIIFS Complete

9/30/91 ROD Signature

5/3/93 Remedial Design Start

3/01195 Remedial Design Complete

6/12/96 Remedial Action Start

5/28/98 Remedial Action Complete

9/97 LNAPL Extraction System Starts Operation 4/02 LNAPL Extraction system is turned off,

LNAPL is bailed out weekly from EW8

2

Operable Unit 3 (Soils) (Metals Contaminated Soils) Date

Operable Unit 3 Groundwater Date

Event

9/22/94 9122/94 RIfFS Complete 9122/94 9122/94 ROD Signature 3/31/95 3/31/95 Remedial Design Start 9/19/96 9/11/97 Remedial Design Complete 9/23/96 9/26/97 Remedial Action Start 2/16/98 9125/02 Remedial Action Complete

-----­ 12/99 OU3 Groundwater Extraction System and monitoring starts and continues to present

Table2. Redevelopment Chronology

Date Event Fall 1997 City purchased MacGillis and Gibbs property Spring 1998 Donatelle Plastics Phase I begins construction Spring 2000 Main Street Village (strip mall) begins construction Fall 2000 Daleo Warehouse begins construction Fall 2002 Donatelle Plastics Phase II begins construction Fall 2002 Residential portion of Main Street Village begins

construction Summer 2006 New Industrial tenants start design on South part of the Site 2008 Daleo expands to the Site 2008 Post Office builds on remaining portion of the Site

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III. Background

Both the MacGillis & Gibbs (M&G) and Bell Lumber & Pole (Bell) facilities have been involved in wood preserving activities since the 1920's, and the Bell facility is still active today. The M&G facility ceased operations in 1997. The M&G and Bell facilities were included as one site on the National Priorities List (NPL) because of their adjacent locations and similarities of processes and contaminants. Bell entered into an agreement with MPCA under the Minnesota Environmental Response and Liability Act (MERLA) in 1985 to perform an investigation and cleanup of its facility. M&G did not enter into a similar agreement. Because the cleanup at the Bell facility was undertaken under MERLA, the site cleanup under CERCLA has been solely related to the M&G facility. Thus, this Five-Year Review is for the M&G facility only. Whenever "site" is referred to in this report, it is meant to apply to the M&G facility only.

Physical Characteristics

The M&G and Bell facilities are located in a mixed residential/commercial area within the corporate limits of the City of New Brighton, Ramsey County, Minnesota. The Bell facility is located on the western portion of the site and the M&G facility is located on the east. See Figure 1 for site location. The elevation of the site is between 900 to 920 feet above mean sea level. Surface drainage at the site is to the northeast toward 5th A venue NW, to the southwest toward the Minnesota Transfer Railroad tracks, and a formerly ponded area in the east-central area of the site ('the disposal area'). Residences lie to the north and northeast of the M&G facility. Commercial properties are to the north, east and south of the M&G facility and to the north of the Bell facility.

The City of New Brighton has ten municipal wells which supply drinking water to the area. These municipal wells are between 400 to 900 feet deep and draw water from the deeper aquifers including the Prairie du Chien formation, Jordan Sandstone, Mount Simon Sandstone, and the Hinckley Sandstone. Seven of the municipal wells are located within 2 miles of the site, to the northwest, west and south. The residences in the area receive their potable water from the municipal wells; however, there are a limited number of private residential wells near the site. A 2006 survey (CH2M Hill / E & E., 2006) found five private residential wells within the site's related groundwater plume, all reported as not used.

The hydrogeology at the site is characterized by a two-aquifer system present within the glacial drift formation overlying bedrock formation. The uppermost aquifer consists of the unconfined New Brighton Sands and the lower aquifer consists of the Hillside Sands which is confined by the Twin Cities Till Formation. In the New Brighton Aquifer there is a groundwater divide which trends east to west in the vicinity of the former disposal pond. Under average climatic conditions, groundwater to the north and northeast of the former disposal pond flows to the northeast, while groundwater to the west flows to the west, and groundwater south of the former disposal pond flows to the south. In the confined Hillside Aquifer, groundwater flow direction is to the north throughout the site area.

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Land and Resource Use

At the time response actions commenced, the site was zoned for industrial use with surrounding areas zoned for commercial and residential use. Redevelopment efforts have enabled the City of New Brighton to reuse portions of the site. Extensive redevelopment of the site has occurred since it was listed on the NPL, including: a strip mall (Main Street Village), residential development, two phases of Donatelle Plastics, and the two phases of Daleo Enterprises. A U.S. Post Office facility occupies the Southern portion of the site.

History of Contamination

M&G began wood preserving operations in the 1920's and changed its processes several times over the years. Pentachlorophenol (PCP), creosote and chromated copper arsenate (CCA) were used at various times. Wood preserving operations at the site resulted in the discharge of contaminants to the soils. Contaminant sources from past operations include spills and leakage from waste PCP materials remaining in the abandoned PCP process/storage tanks and process piping. Spilled solution from the CCA treatment process and the dripping of solution from staged lumber were contaminant sources from the most recent operations at the site. Creosote was used in the early years for wood treatment.

The disposal area was another source area of contamination. The disposal area was filled with wood chips, debris, and spent treatment solutions from the PCP process. A drain line from the PCP process area discharged water collected in piping vaults to the pond in the disposal area. It is likely that some of the process water from the PCP wood treating operations was also discharged via this line. Drum shells which had formerly contained copper chromium arsenic solution were also reportedly placed in the disposal area. PCP solution was reportedly used as an herbicide for weed control at the facility from 1940 to 1974.

Initial Response

In 1979, an initial investigation was conducted at M&G after a spill of 4000 to 5000 gallons of CCA. Studies were conducted from 1981-1987 by both the M&G facility and the MPCA to define the extent of contamination and to propose cleanup activities. Significant contamination of the disposal area was found as well as around the CCA and PCP process areas and in the groundwater beneath the site.

The site was listed on the NPL in 1984. In 1988 EPA monitored some initial cleanup activities performed by the M&G Company. Approximately 200 deteriorated drums of PCP process wastes were stabilized in overpack drums and placed in a newly constructed storage facility. A Light Non-Aqueous Phase Liquid (LNAPL) groundwater plume was also detected and an extraction well was installed to begin the removal of this plume.

The site has been divided into three operable units, as follows:

Operable Unit 1 (OU1) includes contaminated soils and debris in a former disposal pit area on

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the west edge of the M&G facility. Currently the contaminated soils are under a cap, a portion of which serves as a parking lot. A high pressure gas pipeline runs under the cap in OU1.

Operable Unit 2 (OU2) includes the LNAPL plume in the PCP process area and residuals and sludges contained in abandoned aboveground and underground storage and process tanks. Removal and disposal of the above ground tanks and associated piping was also included as part of the remedial action for OU2.

Operable Unit 3 (OU3) includes contaminated soils (other than those addressed in OU1) and ground water contamination. The underground tanks and vaults have been removed. Contamination which has moved off-site to the surrounding area, including small lakes, wetlands and a stream, is also addressed in OU3. OU3 includes operation and maintenance (O&M) of the water treatment plant and groundwater monitoring.

Basis for Taking Action

Hazardous substances that have been released at the site in each media include:

Groundwater Soil Pentachlorophenol Pentachlorophenol Arsenic Arsenic Chromium Chromium Polynuclear Aromatic Hydrocarbons Dioxin

Polynuclear Aromatic Hydrocarbons

Threats to human health were primarily due to groundwater contamination and soil contamination. Carcinogenic (cancer causing) risks, as well as non-cancer health risks were identified for residents who may use groundwater for purposes other than drinking, such as using the groundwater in a swimming pool, or who may be exposed to on-site soils. Carcinogenic risk for worker exposure to contaminated soils also exceeded EPA's upper range for acceptable exposure levels.

IV. Remedial Actions

Remedy Selection

In 1990, EPA conducted a Remedial Investigation and Feasibility Study (RIIFS). This study found contamination of soils in the PCP and CCA process areas. PCP wastes were also found in abandoned tanks on site. Significant contamination of the groundwater under the site was detected in the upper aquifer. The contaminant groundwater plume was also found to be moving off-site. An additional study was proposed to further delineate the extent of contamination.

While the additional study was being performed, EPA issued an Interim Action Record of Decision (ROD) in September 1991 for OU2 to control the spread of contamination from

6

identified source areas into soils and groundwater. The OU2 remedy included:

• Construction of an extraction well and a groundwater treatment facility for the removal of the LNAPL plume;

• Removal of the wastes in the abandoned aboveground and underground storage and process tanks; and

• Demolition and removal of aboveground storage tanks.

A Focused Feasibility Study was conducted in 1992 by the MPCA on OU1 (contaminated soils and wood debris, sediments in and around a pond in the disposal area of the site.) At that time, it was discovered that a high pressure gasoline pipeline runs through this area. The MPCA and EPA subsequently issued a source control ROD for OU1 in December 1992 which required:

• Incineration of wood debris and washing of soils and sediments; and • Treatment of residuals from the soil washing process by either: bioremediation,

incineration, or solidification/stabilization.

The ROD for OU1 required treatability testing of the soil treatment technologies to determine their effectiveness. The ROD indicated that if these technologies proved to be ineffective for soils, a contingency remedy would be incineration.

EPA completed the RUFS for OU3 in 1994. The RI sampling determined that there were organic contaminants in soils in and around the PCP process area and metals in soils in and around the CCA process area. The New Brighton Aquifer, which is the shallow aquifer beneath the site, was found to be contaminated with both organics and metals. The contaminant plume was found to have moved off-site to the northeast in that aquifer. Ecosystems near the site were also found to be contaminated. EPA issued a ROD for OU3 in September 1994 which required:

• On-site incineration of organic soils in the PCP process area of the site; • Solidification of metals contaminated soils in the CCA process area of the site and off­

site disposal; • Groundwater extraction and treatment of the on-site and off-site contaminated ground

water plume in the New Brighton Aquifer; • Long term ground water monitoring of the New Brighton and Hillside Aquifers and long

term monitoring of contaminated ecosystems adjacent to the site; and • ICs including deed restrictions limiting use of groundwater in contaminated areas and if

necessary, future abandonment of residential wells impacted by contamination.

In September 1999, a ROD amendment was issued for both OU1 and OU3 organic-contaminated soils addressing the high cost of incineration, the high cost and unreliability of the soil washing technology, and risk-based management approaches based on land use. Remediation of the OU3 organics-contaminated soils and OU 1 organics-contaminated soils were combined due to the similarity of the contamination and the cost effectiveness of remediating the soils in a single construction contract. The main components of the ROD amendment were:

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• Excavation of wood debris, concrete and metal in the disposal pond area of OU1 and decontamination (if necessary) and disposal of these materials in an off-site Resource Conservation and Recovery Act (RCRA) Subtitle C landfill;

• Excavation and treatment of contaminated soils from OU1 and OU3 with a combination of biopile and oxidation and reduction processes;

• Backfilling of the treated soils that meet site cleanup goals on-site, and off-site disposal of the remainder of the soils in a RCRA Subtitle C landfill;

• Consolidation of less heavily contaminated soils into OU1 disposal pond area and capping the area with a RCRA Subtitle C cap; and

• rcs, including deed restrictions, to limit the potential for exposure to contaminated soils beneath the cap.

The ROD Amendment also stated that if on-site treatment failed to achieve RCRA land disposal restrictions, the soils would be further treated in an off-site incinerator rather than be disposed of in an off-site landfill.

Remedy Implementation

Since the potentially responsible party (PRP) at the site was not financially viable, the remedial action (RA) at the site was fund-financed.

Operable Unit 2

The OU2 RA construction activities occurred from April 1997 to March 1998. Twenty-one process tanks and vaults were cleaned of residual process oils and sludges. Approximately 40,000 gallons of waste oils and 80 cubic yards of sludges were removed and shipped to an off­site incinerator. The aboveground silo tanks were demolished and decontaminated. Underground tanks were left in place to be remediated later with the au1/0U3 organics-contaminated soils.

The OU2 RA also included the construction of a LNAPL extraction well and on-site LNAPL and ground water treatment facility. The LNAPL extraction well was intended as an interim action solely to remove the LNAPL source materials. The ground water treatment plant for OU2 consisted of an oiVwater separator, the biological reactor unit, a settling tank, and carbon adsorption polishing units. RA completion occurred on May 28, 1998.

Operable Unit 3 Metals-Contaminated Soils and Ground Water

The remedial design (RD) of OU3 began in March 1995. The OU3 soils contaminated with organics were included in the OU1 remediation. During the remedial design for the soils contaminated with metals, additional field sampling was conducted to define contamination along railroad tracks contiguous to the M&G facility, to define contamination under site buildings and the concrete treatment pad, and to define the boundaries of the metals contamination at the site. The OU3 RA construction to address soil contaminated with metals began in July 1997.

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A total of 14,831 cubic yards of metals~contaminated soils were excavated from the CCA treatment area of the site. Approximately 45 percent of the soils required treatment by solidification prior to disposal in a RCRA Subtitle C landfill. The site's wood treatment buildings and the concrete CCA drip pad were demolished. Approximately 2000 tons of concrete from the building floors and the drip pad were found to be contaminated and were treated through use of a microencapsulation process before being disposed of in a RCRA Subtitle C facility. The RA was completed on September 14, 1999.

Construction of the OU3 ground water treatment facility began in July 1998. While the OU3 groundwater treatment process is very similar to the OU2 process, it was much larger and was intended to address the area-wide groundwater contamination from the site. The OU3 facility was designed to treat 50 gallons per minute of contaminated groundwater. The construction was substantially complete and full operation began in December 1999. However, two additional extraction wells were constructed in October 2002 and RA completion occurred on September 17,2003.

OU1/0U3 Organic-Contaminated Soils

RA construction for OU1 and OU3 soils contaminated with organics began in August 2000. The project had two components: the biotreatment of soils using biopiles; and the removal of debris from OU1 and installation of a RCRA landfill cap. Approximately 16,192 cubic yards of soil from OU3 and 2,020 cubic yards of soil from OU1 were biotreated. Treatment of the soils produced in 15,380 cubic yards of soil which met the site clean-up goals and were placed back onsite and 2,832 cubic yards of soil which required off-site landfill disposal.

Construction in OU1 consisted of screening wood, concrete, and metal debris from soils and installing a cap over two thirds of the OU1 area, which was then overlain by an asphalt parking lot. Work began in August 2000 and paused in November 2000 to relocate the gasoline pipeline which runs through a portion of the au1 area. The relocation of the pipeline was completed by the end of September 2001. The remaining portion of OU1 was excavated, debris removed and cap installation finished in November 2001. In OU3, some additional soils were removed along with some LNAPL-contaminated soils. The last of the bio-treated soils were removed in October 2002.

System Operations and Maintenance

The system operations at the site consist of the operation and maintenance of the OU3 groundwater treatment process, monitoring, and periodic maintenance of the cap in OU1. The OU2 treatment facility was shut down in April 2002 because it was determined that no further LNAPL could be removed.

EPA is currently operating the OU3 facility through a contractor. EPA is responsible for operation of the treatment facility until September 2012, when its operation will be transferred to the State of Minnesota. MPCA and EPA periodically inspect the asphalt cover/parking lot which covers part of the liner in OU1. Daleo Companies is required to maintain the asphalt and mow

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the vegetation on the berm. The MPCA is ultimately responsible for repairing the berm, as required. At the time of the October 2010 inspection, the asphalt and the berm were generally in good condition. however, two small areas of the berm near EW -11 have vegetation less dense than the surrounding vegetation, which may pose a risk of future erosion.

The OU3 groundwater treatment and extraction system began partial operation in December 1999 and full operation in October 2002. Table 2 lists annual costs for the site. These costs include consultant fees, operator costs, electrical costs for running the pumps and the facility, sewer discharge fees, sampling and analysis costs and waste disposal fees. These costs are significant and a study to find opportunities to reduce costs should be undertaken prior to the State taking over operations of the treatment plant.

Table 2: Annual Costs from 2006·2010

Calendar Year Total Annual Costs (Per Year)

2006 $639,687

2007 $637,343

2008 $699,401

2009 $820,007

2010 $761,617

Implementation of ICs

Institutional controls (lCs) are non-engineered instruments, such as administrative and/or legal controls, that help minimize the potential for exposure to contamination and protect the integrity of the remedy. Compliance with ICs is required to assure long-term protectiveness for any areas which do not allow for unlimited use or unrestricted exposure (UUIUE).

The OU3 ROD required ICs, including deed restrictions, limiting the use of groundwater in contaminated areas and, if necessary, future abandonment of residential wells impacted by contamination. Since the issuance of the RODs, the City of New Brighton has purchased the M&G property, and the City, the MPCA and EPA have signed a Prospective Purchaser Agreement (PPA) and Covenant Not to Sue for parcels which comprise the M&G property. The PPA states that groundwater at the site is not to be disturbed or utilized in any way except for dewatering during construction activities. The OUlIOU3 ROD amendment for organic soil contamination included deed restriction requirements to prevent exposure to soils under the cap located on the M&G property. Similar to the prohibition on groundwater, the PPA places restrictions on the disturbance of soils. The PP A also requires parties purchasing parcels of the site from the City to agree to take title subject to the soil and groundwater restrictions through a conservation easement. Because of the extensive redevelopment at the site, a number of property

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transfers have occurred. Verifying compliance with the PPA is part of the IC Action Plan, which is being developed.

A number of off-site properties have groundwater contamination from the site underlying them. However, there are only a small number of residential wells in the area, as the City of New Brighton's residents are all served by the municipal water system. The five identified residential wells located in the shallow New Brighton Aquifer within the plume were reported by their owners as not being used (CH2M Hill / E & E., 2006). Moreover, since the early 1990's, several residences have abandoned their wells. The IC Action plan will detennine whether further action is needed regarding ICs or outreach for residential wells.

The table below summarizes institutional controls for these restricted areas.

e . on ros S aT bl a 3 . Instltutlonalet I ummaryT bl e Media, Engineered Controls, & Areas IC Objective Title of Institutional Control that Do Not Support UUlUE Based on Instrument Implemented Current Conditions. (note if planned) MG Property - Area of Soil treated to Prohbit Soil Disturbance PPA ,

industrial cleanup standards. Groundwater at the M&G Site - Prohibit groundwater use until PPA

cleanup standards are achieved. Restrictive Covenant 3055028

recorded at Ramsey county (except dewatering during recorder's office on April 21 , 1998. construction activities)

Groundwater downgradient from the Sit&- Prohibit groundwater use until Minnesota Dept. of Health Special current area that exceeds groundwater cleanup standards are Well Contrsuction Area Designation cleanup standards identified. achieved for Twin Cities Army Ammunition

Plant, June 10, 1996

Maps which depict the current conditions of the site and areas which do not allow for Uu/UE will be developed as part of the additional IC evaluation activities in the IC Action Plan.

Current Condition of Site and ICs

IC evaluation activities are in progress. Once the IC evaluation activities have been completed, an IC plan will be developed by EPA and will contain a plan for additional IC activities as needed, including planning for long- tenn stewardship.

As part of the IC evaluation activities, a title committment was ordered for parcels which comprose the fonner MacGillis and Gibbs facility. That commitment is under review. Additionally, a special well construction area (SWCA) was identified that exists to address the area of groundwater contamination. The SWCA is discussed further below. Additional review of the existing ICs is underway to ensure that no unintended uses of the property occurs. ICs are in place for some of parcels occupying the fonner MacGillis & Gibbs Co. manufacturing facility, but not on all parcels of property where remedy components are located and where sampling access is required.

II

Additional IC evaluation activities which are to be completed include completing specific IC maps to deteremine areas which do not allow for UUIUE, reviewing IC objectives and effectiveness of any existing ICs in-place including the SWCA, and to evaluate whether effective procedures are in-place for long-term site stewardship procedures, which are discussed below. The IC Action plan will evaluate the effectiveness of current ICs and plan for further actions as needed to ensure long-term stewardship of ICs.

The record of decision (ROD) estimated that groundwater cleanup goals would be achieved in 30 years. A Special Well Construction Area (SWCA) was designated in 1996 by MDH for the area that includes the contaminant plume from the M&G facility. This SWCA was designated by the MDH because of contamination from an adjacent Superfund site in the City of Arden Hills called the Twin Cities Army Ammunition Plant (TCAAP). The SWCA requires well drillers to obtain approval from MDH prior to construction of a new well. A new well must also be sampled for contamination prior to MDH approving its use. Since the M&G site is within the boundary of the TCAAP's SWCA, the MDH considers all requirements of the SWCA to apply to the aquifers impacted by the site and the wells that are constructed within those aquifers.

The SWCA appears to adequately control construction of new wells in the aquifer and thus, the Agencies do not see a need to place deed restrictions on each residence in the plume area. However, the SWCA will be reviewed to ensure it is effective for the site in the unlikely event that construction of a private well could occur in the area.

ICs to Ensure no Inappropriate Property Uses Occur

As mentioned above, the OUlIOU3 ROD amendment for organic soil contamination included deed restriction requirements to prevent exposure to soils under the cap located on the M&G property. The PPA also requires parties to take title subject to the soil and groundwater restrictions through a conservation easement. Because of the extensive redevelopment at the site, a number of property transfers have occurred. Under the IC Action Plan, EPA will determine which ICs have been implemented and whether the use of a conservation easement is the most effective type of IC to ensure no inappropriate property uses occur. If the ICs for property use restrictions need to be implemented (or re-recorded), then consideration should be given to implementing Environmental Covenants (ECs) under the Uniform Environmental Covenants Act (UECA). The UECA was recently enacted, and it provides numerous benefits. Properly drafted UECA covenants will ensure that the restrictions are enforceable and run with the land to help to ensure long-term Site stewardship. The UECA provides that an owner of property may enter into a restrictive covenant and also be a "holder" of the covenant, with the right to enforce it against a third party even after the property is sold. The IC action plan will be prepared to plan IC evaluation activities and any corrective measures needed to ensure that effective ICs are implemented and procedures are in-place to ensure that the ICs are maintained, monitored and enforced for long-term site stewardship

Long Term Stewardship: Long-term protectiveness at the site requires compliance with effective ICs to ensure that the remedy continues to function as intended. Compliance with effective ICs will be ensured through proper maintenance, monitoring, and enforcement of them

12

by preparing a plan which includes long-tenn stewardship (LTS) procedures. The IC Plan will include a LTS plan. The LTS Plan will include a provision for regular inspection of ICs at the Site and contingency actions if needed.

Current Compliance: Based on inspections and interviews, EPA and MPCA are not aware of any groundwater or property uses which interfere with the intended use. Long-tenn protectiveness will be ensured through compliance with and monitoring of effective rcs.

V. Progress Since the Last Review

Since September 30,2006, the OU3 groundwater extraction system has been operated and maintained. Annual groundwater monitoring to measure the effectiveness of that system has occurred. The last Fi ve-Year Review made two recommendations: (1) to develop an IC Action Plan; and (2) to consider abandonment of all private wells within the groundwater plume boundary. An rc Action Plan is currently under development by EPA, and has not yet been completed. The last Five-Year Review recommendation to develop an IC Action Plan was not implemented. An IC Action Plan is still needed, and a title search has been perfonned to begin developing one.

The last Five-Year Review noted that a small number of private wells remain within the groundwater plume boundary without prohibition of groundwater use, and recommended that abandonment of private wells be considered. A survey of 96 residential properties within the plume was conducted to learn about the presence and status of residential water supply wells in that area. Forty homes responded to the survey; five of those households reported having a well. Of these five wells, two were described as "not used", one was described as "plugged", one was described as "capped off', and one was described as "filled with cement." The IC Action Plan will include an approach to ensure residents living within the groundwater plume boundary do not consume groundwater, including residents which did not respond to the well survey and residents which reported having a private well on their property.

In 2006, the Minnesota Department of Health (MDH) confinned that the site is within the boundaries of the Special Well Construction Area (SWCA) created to prevent people from using groundwater contaminated by the activities of the TCAAP site. The TCAAP is another Superfund site located about 1.5 miles to the northeast of the M&G Site. Construction of new wells or modification of existing wells in the SWCA requires review and approval by MDH.

13

VI. Five-Year Review Process

Administrative Components

This Third Five-Year Review was initiated on June 4, 2010. The review components included:

• Community Involvement; • Document Review; • Data Review; • Site Inspection; • Local Interviews: and • Five-Year Review Report Development and Review.

The members of the review team included Stacey Yonce, Remedial Project Manager, EPA Region 5, and Nile Fellows, Project Manager, MPCA.

Community Notification and Involvement

On September 29,2010, a legal notice was published in the New Brighton Bulletin announcing that a Five-Year Review was being conducted for the MacGillis and Gibbs Superfund site (Appendix D). No comments have been received in response to the notice.

Document Review

This Five-Year Review included a review of relevant documents including the RODs and ROD amendment, groundwater monitoring reports, MPCA staff correspondence and the previous Five-Year Review report. A list of the documents reviewed is presented in Appendix B.

Data Review

Groundwater Monitoring

Baseline sampling was performed in 1999 to establish the groundwater contaminant concentrations that existed prior to startup of the groundwater extraction system. Annual sampling events have been performed since 1999 in the New Brighton Aquifer to assess the performance of the groundwater extraction system. The sampling event in 2009 also included two wells in the Hillside aquifer, which were sampled for arsenic, chromium, and PCP. The two primary purposes of the annual monitoring are to assess whether the system is capturing the groundwater plume and also to evaluate progress toward achieving groundwater cleanup goals.

14

PCP is the most widespread chemical of concern (COC) and it exceeds the cleanup goal in the greatest number of wells. PCP is used as the indicator of the spatial extent of the plume.

Sampling Event Parameters # of wells sampled

# of wells exceeding cleanup goals

November 2006 PCP 51 22 cPAHs 2 0 chromium 15 2 arsenic 15 3

September 2007 PCP 55 31 cPAHs 3 0 chromium 20 2 arsenic 20 2

October 2008 PCP 60 24 cPAHs 4 0 chromium 22 2 arsenic 22 4

September 2009 PCP 60 28 cPAHs 4 1 chromium 24 2 Arsenic 24 3 Dioxin 5 4

In each annual report a discussion is provided of the trend for that COC, for each monitoring well at which a COC is detected above cleanup levels. The annual monitoring reports show a mix of increasing, decreasing, and undefined trends of COC concentrations at specific wells. These trends will continue to be observed as operation of the extraction system and monitoring at the site continue. Generally, however, the data gathered at the site shows correlations and trends which indicate a stable capture zone that is containing, extracting, and treating groundwater with elevated cae concentrations.

The plume is not well-delineated to the southwest, as this area is part of the Bell Lumber and Pole Company (Bell Facility) remediation area. Bell has its own network of monitoring wells and groundwater pumpout system that is not subject to this Five-Year Review and operates separate from the M&G remediation. The COC at the Bell Facility is also PCP.

Ecological Monitoring

Consistent with the ROD, surface water, sediment, fish and crayfish samples were collected from ecological habitats near the site in July 2009 and analyzed for COCs. These data were compared to surface water, sediment, and fish and crayfish sampling data collected as part of the RI in 1992 and 2005. Figure 3 shows the site location and the locations of ecological habitats which were sampled in 2009.

15

In general, the contaminant concentrations in the samples collected in 2009 were either decreasing or were not changing in a consistent trend. The 2009 report concluded that a continued ecological monitoring is not warranted and that "pending other non-technical, administrative, or regulatory considerations, it is recommended that future studies at this site be limited to annual groundwater monitoring."

Site Visit and Inspection

Representatives of the EPA and MPCA performed a site inspection on October 19,2010. The inspection evaluated the treatment buildings, cap and berm, and the recovery and monitoring wells. The monitoring wells are generally in good condition, although a thorough evaluation of all wells at the site is needed to assure compliance with Minnesota well construction code requirements. The buildings are well maintained.

The OU2 LNAPL treatment building is no longer used and has unused pipes and equipment that should be removed. The cap, part of which is now a parking lot, is appropriately maintained. The berm was also generally in good shape. However, two small areas of thin grass vegetation were noticed during inspection, and erosion may develop in those areas in the future. A site inspection checklist is included in Appendix C.

The most recent construction activities at the site occurred in 2008, which included the expansion of Daleo Enterprises and a Post Office Building on the South portion of the site, and have completed the reuse of the site.

Interviews

On October 19,2010, the site inspection team met with Mr. Grant Fernelius, Community Development Director for the City of New Brighton at the City Hall. Mr. Fernelius expressed his opinion that there is a positive public perception about the M&G remedial project, although he admitted that in recent years most people do not pay attention to the site remedial activities nor are they much aware of the past site condition and success of the remedial actions and redevelopment.

VII. Technical Assessment

Question A: Is the remedy functioning as intended by the decision documents?

Yes.

Construction of the remedy for the site was completed on September 25, 2002. The review of monitoring data and the results of the site inspection indicate that the remedy is functioning as intended by the ROD.

The RCRA cap was in good condition at the time of site visit, and is regularly maintained. The groundwater extraction and treatment system is operating and functioning properly.

16

Currently, twelve extraction wells (EWs) pump contaminated groundwater - EW:" 1, 3B, 5, 7, 9, 10, 11, 12, 13, IS, 16 and 18. Out of those wells, water produced by four wells is treated with the bioreactor at the treatment plant, while water from the other eight wells is discharged directly to the sanitary sewer. Also, free product is removed weekly from a thirteenth well (EW8) with a peristaltic pump. EW4 was switched off in 2008 to optimize the operations of the entire groundwater extraction system.

The last Five-Year Review reported that approximately 218 million gallons of contaminated groundwater were pumped and either treated by the groundwater pump and treat facility or discharged directly to the sanitary sewer since startup in December 1999 until July 2005. This discharge represents an average 40 million gallons per year over a period of 5 and Y2 years. Review of the more recent reports of water use (E&E, 2009; E&E, 201Oa) indicates that 27.5 million and 23.2 million of gallons was pumped in 2008 and 2009, respectively. That represents a decrease in pumping, compared to the earlier period of the system's operation (1999 - 2005) and reflects changes made to this system to optimize it, such as turning off EW4.

It is estimated that since January 2001 (through the end of 2010) about 1,500 gallons of LNAPL has been manually extracted from the former extraction well EW 8 (1,000 gallons reported in the last Five-Year Report for a period from the beginning of product extraction through 2005). The groundwater extraction and treatment system has undergone a formal optimization study (RSE study) and several significant changes were made which improved operation and reduced operating costs. The system is very well maintained on a daily basis and routine maintenance is performed on a regular schedule.

Annual groundwater monitoring is performed to assess the progress in achieving the site cleanup goals. The results of this monitoring are an indication that the plume is stable. The effectiveness of the capture zone of the site's groundwater extraction system is assessed annually using groundwater level measurements and a computer program.

Long-term protectiveness requires compliance with effective ICs. ICs are in place for parcels occupying the former MacGillis & Gibbs Co. manufacturing facility, but not on all parcels of property where remedy components are located and where sampling access is required. An IC Action Plan will be conducted to determine what ICs are in place, and what additional ICs are needed, if any, to ensure effective long-term stewardship procedures are in place to monitor, maintain, and enforce the ICs.

Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives used at the time ofthe remedy selection still valid?

Yes.

The soil cleanup at the M&G site has been completed and the risk-based soil cleanup goals were met. ARARS that have been evaluated for changes since the ROD include the Safe Drinking Water Act (SDWA), State of Minnesota Health-Based Risk Limits (HRLs) and the Clean Water Act Standards for Discharge to Publicly-Owned Treatment Works. Standards for the

17

groundwater COCs have not become more stringent since the 1994 ROD, with the exception of the SDW A Maximum Contaminant Levels (MCLs) for dioxin and arsenic and the HRL for pentachlorophenol.

The MCL for dioxin decreased from 50 picograms per liter to 30 picograms per liter. The groundwater cleanup goal set in the ROD for dioxin was 12 picograms per liter and was based on site-specific risk. The site groundwater cleanup goal for dioxin is more stringent than the new MCL for dioxin and thus remains protective. The MCL for arsenic decreased from 50 J..lglL t010 Ilg/L. The groundwater cleanup goal set in the ROD for arsenic was 51lg/L and thus remains protective. The HRL for pentachlorophenol has decreased from 200 Ilg/L to 1 J..lg/L. The groundwater cleanup goal for pentachlorophenol is 1 Ilg/L which was based on the MCL and thus remains protective.

In addition, the on-site treatment plant has been effective in removing site contaminants and is in compliance with the pretreatment permit issued by the Metropolitan Council Environmental Services (MCES) under 40 CPR Part 403 of EPA rules.

There are no new exposure pathways or changes to existing exposure pathways. The exposure assumptions and toxicity data used to develop the Human Health Risk Assessment are considered to be conservative and reasonable in evaluating risk and developing risk-based cleanup levels. No change to these assumptions, or to cleanup levels developed from them, is warranted.

Vapor intrusion associated with contaminated soils and groundwater has been recognized recently as an emerging issue. However, since the site COCs are not volatile except for PAHs, and PAHs are routinely found to be below detection limits during groundwater monitoring since the last Five-Year Review, vapor intrusion is not considered an exposure pathway at the site.

Operation and Maintenance costs for OU3 (groundwater treatment & extraction system plus consultant fees) are shown in Table 2.

Question C: Has any other information come to light that could call into question the protectiveness ofthe remedy?

No.

There is no other information that calls into question the protectiveness of the remedy.

Technical Assessment Summary

According to the data reviewed and the site inspection, the remedy is substantially functioning as intended by the ROD. There have been no changes in the physical conditions at the site, standards, contaminant toxicity or exposure pathways that would affect the protectiveness of the remedy. There is no other new information that calls into question the protectiveness of the remedy.

18

VIII. Issues

Issue

Mfects Current Protectiveness (YIN)

Mfects Future Protectiveness (YIN)

1. An IC Action Plan will be developed to evaluate sufficiency of ICs in place and assess need for additional ICs to restrict groundwater usage at residences or to prevent disturbance of cover and allow maintenance and operation of remedy

N Y

One issue is carried over from the last Five-Year Review: the need to develop an IC Action Plan to assess whether sufficient ICs are in place. and to provide a schedule for any remaining work necessary to put ICs in place. Although there is currently no indication that exposures are occurring. the IC Action Plan is necessary to assure long-term protectiveness at the site.

Maintenance will be performed on monitoring wells and the berm as a result of the site inspection, as part of normal maintenance of the site.

IX. Recommendations and Follow-up Actions

Issue

Recommen­dations and Follow-up Actions

Party Respon­sible

Over­sight Agency

Mile­stone Date

Affects Protectiveness (YIN)

Current Future 1. An IC Action Plan will be developed to conduct additional IC evaluation activities to assess effectiveness of ICs and recommend additional ICs, if needed, along with LTS procedures.

Develop an IC Action Plan EPA EPA 10/31

/11 N Y

No issues related to the protectiveness of the remedy were identified that would require follow­up actions. However, because of the high costs associated with operating and maintaining the present system, a value engineering study should be performed in order to evaluate cost saving measures prior to the State taking over operations and maintenance of the site.

19

x. Protectiveness Statement

The remedy at the M&GlBell Lumber & Pole site is functioning as intended and is protective of human health and the environment in the short-term; however in order for the remedy to be protective in the long-term, the groundwater cleanup goals must be met. Also, the effectiveness of rcs should be determined by assuring that all necessary restrictions have been implemented to prevent exposure to contaminants in soil and groundwater from the site. Long term protectiveness also requires compliance with effective rcs so that the remedy continues to function as intended. An IC action plan will be prepared to plan additional IC evaluation activities and any corrective measures needed to ensure that effective ICs are implemented and procedures are in-place to ensure that the ICs are maintained, monitored and enforced for long­term site stewardship.

XI. Next Review

The M&G Company/Bell Lumber & Pole Company site is subject to CERCLA 121(c)'s requirement of ongoing five-year reviews. EPA, or the MPCA if it is delegated to do so by EPA, will conduct another review five years from the signature date of this report.

20

APPENDIX A Figures

Figure 1 - Site Location Map (from the USEPA Brochure titled: Cleanup and Mixed-Use Revitalization in the Twin Cities - The MacGillis & Gibbs Superfund Site Property at New Brighton, MN - EPA Region 5, Apri1201O)

Figure 2 - Groundwater Monitoring Well Location Map (Figure 2-1 from the report by CH2M Hill, 20 lOb)

Figure 3 - Area Hydrologic Features and 2009 Phase I Ecological Sample Location Map (Figure 2-1 from the report by CH2M Hill / E&E / EDE, 2010)

Figure 4 - Estimated PCP Contaminant and Capture Zone (Figure 4-1 from the report by CH2M Hill, 201Ob)

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APPENDIXB Bibliography

(arranged chronologically)

MGS, 1989. Geologic Atlas of Hennepin County, Minnesota. County Atlas Series - Atlas C-4. Minnesota Geological Survey, University of Minnesota, St. Paul, 1989.

Howard, P.H., R.S. Boethling, W.F. Jarvis, W.M. Meylan, E ..M. Michalenko, 1991. Handbook of Environmental Degradation Rates. Lewis Publishers, 1991.

Remedial Investigation and Feasibility Study Work Plan MacGillis and Gibbs!Bell Lumber and Pole E & E, 2/5/91

Record of Decision OU2, 9/30/91

Record of Decision OU 1,12/31/92

MGS, 1992. Geologic Atlas of Ramsey County, Minnesota. County Atlas Series - Atlas C-7. Minnesota Geological Survey, University of Minnesota, St. Paul, 1992.

Record of Decision OU3, 9/22/94

MOH, 1996. Notice of Designation of Special Construction Area in the Vicinity of the Twin Cities Army Ammunition Plant. Issued by Patricia A. Bloomgren, Director of Division of Environmental Health, Minnesota Department of Health, to Licensed and Registered Well Contractors, Local Government Officials in Effected Cities and Counties, June 10, 1996.

Agreement and Covenant not to Sue City of New BrightonIDOIlEP AlMPCA, 6/26/97

Amendment to Record of Decision for OU1 and OU3, 9/30/99

The First Five Year Review Report for MacGillis & Gibbs !Bell Lumber & Pola Company, City of New Brighton, Ramsey County, Minnesota. Prepared by the Minnesota Pollution Control Agency for the United States Environmental Protection Agency, Region V, Chicago, IL. September 200 1.

Completion Report for the Relocation of Williams Pipe Line Company's #2-8" Minneapolis­Duluth Line through the MacGillis Gibbs Pole Yard New Brighton, Minnesota; Williams Pipeline, October 11,2001

Remedial Action Report; MacGillis and Gibbs Superfund Site, New Brighton, Minnesota EPA Cerclis ID Number MND006192694; Treatment of Contaminated Soil (OU1 and OU3), Terracon, February 27,2003

Draft Phase I Ecological Monitoring Report, MacGillis & Gibbs Site, Ecology and Environment Inc., 612006

MDH,2006. TCAAP Special Well Construction Area (SWCA) covers the MacGillis & Gibbs Site - e-mail from Patrick Sarafolean of Minnesota Department of Health to USEPA and MPCA, August 07,2006 (subject: New Brighton, MN -- MacGillis & Gibbs --"institutional controls").

CH2M Hill / E & E. 2006. Residential Well Survey for the MacGillis & Gibbs Site LTRA. August 18, 2006.

The Second Five Year Review Report for MacGillis & Gibbs !Bell Lumber & Pola Company, City of New Brighton, Ramsey County, Minnesota. Prepared by the Minnesota Pollution Control Agency for the United States Environmental Protection Agency, Region V, Chicago, IL. September 2006.

CH2M Hill et aI., 2007a. Data Evaluation / Cleanup Status Report No.5, MacGillis & Gibbs Site, New Brighton, Minnesota. Long-Term Response Action, WA No. 21O-RALR-OSLl / Contract No. 68-W6-002S. Prepared by CH2M Hill / Ecology and Environment, Inc., TN & Associates, Inc, Tucker, Young, Jackson, Tull, Inc. in April 2007.

CH2M Hill et aI., 2007b. Data Evaluation / Cleanup Status Report No.6, MacGillis & Gibbs Site, New Brighton, Minnesota. Long-Term Response Action, WA No. 21O-RALR-OSLl / Contract No. EP-S5-06-01. Prepared by CH2M Hill / Ecology and Environment, Inc., Environmental Design International, Inc., Teska Associates, Inc. in August 2007.

E&E, 2007. Phase 1 Ecological Monitoring Report, MacGillis & Gibs Site, New Brighton, Minnesota. Long-Term Response Action, WA No. 21O-RALR-OSLl / Contract 68-W6-0025.

E&E,2009. 2008 Annual Report of Water Use for Permit No. 1999-6094, M&G OU3 Groundwater Treatment System, New Brighton, MN to the MDNR - Water Permit Staff. Ecology and Environmental Services, January 21,2009.

E&E,201Oa. 2009 Annual Report of Water Use for Permit No. 1999-6094, M&G OU3 Groundwater Treatment System, New Brighton, MN to the MDNR - Water Permit Staff. Ecology and Environmental Services, February 5,2010.

E&E,20IOb. 2010 Second Quarter Special Discharge Report to the MCES. Ecology and Environmental Services, July 8,2010.

CH2M Hill / E&E / EDE, 2010. Draft 2009 Phase 1 Ecological Monitoring Report, MacGillis & Gibs Site, New Brighton, Minnesota. Long-Term Response Action, WA No. 002-LRLR-05L1 / Contract No. EP-S5-06-01. Report prepared by CH2M Hill, Ecology and Environment, Inc. and Environmental Design International, Inc., May 2010.

ABCOM,2010. Characterization of Groundwater Conditions of the Valentine Clark Site, Minneapolis, Minnesota; ABCOM Project No. 60141263. The Report prepared for the Minnesota Pollution Control Agency, June 22,2010.

CH2M Hill, 201Oa. Data Evaluation / Cleanup Status Report No.7, MacGillis & Gibbs Site, New Brighton, Minnesota. Long-Term Response Action, W A No. 002-LRLR-05Ll / Contract No. EP-S5-06-01. Prepared by CH2M Hill in November 2010.

CH2M Hill, 201Ob. Data Evaluation / Cleanup Status Report No.8, MacGillis & Gibbs Site, New Brighton, Minnesota. Long-Term Response Action, W A No. 002-LRLR-05Ll I Contract No. EP-S5-06-01. Prepared by CH2M Hill in November 2010.

APPENDIXC

RECE,veo AUG 142006

OSWER NQ. 9355.7-03S·P

Please note that "O&M" is referred to throughout this checklist. At sites where Long-Term Response Actions are in progress, O&M activities may be referred to as "system operations" since these sites are not considered to be in the O&M phase while bcing·remediated under the Superfund program.

Five-Year Review Site Inspection Checklist (Template)

(Working document for site inspection. Infonnation may be completed by hand and attached to the Five-Y ear Review report as supperting documentation ofsite status. "NIA" refers to "not applicable.")

I. SITE lNFORMATION

Site name:{lj Cl c.. b(I r, 0f G, (/tJPS Datc of inspcction: 1 21/6L Location and Region: Ale. tV /It Llih f.111 \h A) EPA 1D:f{N D.()()(p Jq 2- t, if 4-Agency, orr 0pompt!i;Qa'3ln~ '{f{e nve-year Weather/temperature: review: M LA Remedy Includes: (Check all that apply)

@ Landfill cover/containment G Monitored natural attenuation G Access controls G Groundwater containment G Institutional controls G Vertical barrier walls ~roundwateT pump and treatment G Surface water collection and treatment G Other

Attachments; G Inspection team roster attached G Site map attached

11. INTERVIEWS (Check all that apply)

l. O&M site.manager __________ ---------- ­ ---- ­N~me Title Dale

Interviewed G at site G at office G by phone Phone no. . Problems, suggestions; G Report attached ._" ___..

--.--..-- ­----'.._"._--_.,,_._-_.....

2. O&M slaff ~R-, c. ~.J~~fL~r- Plc:(~ o~:! ('.101 1/2-110bIName TitlJ Dale

Interviewed G at site G at office G by phone Phone no. _tS-/-':.fJ3.· 'is-/7 Problems, suggestions; G Report attached __ ---_. ~---.-----~-

D-7

OSWER ,110_ 9355_7-0.1B-P

3. LOCIII regulatory authorities and response agencies (i.e., Stale and Tribal offices. emergency response office, police department, office of public health or environmental health. zoning office, recorder of deeds, or other Ctty and cOlmty offices, etc.) FiU in all thai apply.

Agency MPC A-Contact PIle & lIa_l,.~J5__

Name Phone no. problems; suggestioJl5; G Repon attllched __________.....__..____ . _______._____

---_._-_. __..._------­ ----------------------------Agency __ ________________ Contact ______________

Name Title Date Phone no. Problems; suggestions; G Report attached _________._______._._____

---_._--_.. ----- ----­ ------Agency ________.___,___________ Contact ____________

Name Title Dale Phone no. Problems; suggestions; G Report attached __.__________.___.__.___..._________._ ..._._. _____ _

--_.. - ---------_._-------------­ .. '-'---"-"---"--'---

Agency ___________________ _

Contact ____________,____ ________. __

Name Title Dale Phunc no_ Problems; suggestIOns; G Report altached _____._._________ .._.._.. ____.. ________ .

4 Other interviews (optional) G Report attached.

1--------------------------------------. - -­ .--.-----~

D--8

- - -

-- - -- - -

-- --- -- --

OSWER No. 9355.7-03B·P

111- ON-SITE DOCUMli:NTS & RECORDS VERIFIED (Check aI/that apply)

I. O&M Documents G O&MmanuaJ G As-built drawings

~"diIYmil'hI, . eadily available

G Up to date G Up to date

G N/A G N/A

G Maintenance logs Readily available G Uptodate G N/A Remarks -.­

~

2. Site-Specific Health and Safety rlaa -§eadilyaVailable G Up to date G Contingency plan/emergency response plan eadily available G Up to date Rcmarks_________.__._____. __.._

G N/A G NfA

----- ­- -­ -

3_ O&M and OSHA Training Records G Readily ~t\ G Up to date (?JNfA Remark5 ':---.~ .---- ­

... I

4. Permits and Service Agreements I~~-G Air discharge pennit G Readily avai Q.le G Up to date G N/A G Effluent discharge G Readily available G Up to date G N/A G Waste disposal. POTW G Readily avail~bJc (9 Up to date G N/A G Other pennits ____. _________ .____ G Readilyavair'aQle G Up to date G N/A Remarks___________

~__A_.__ .",A ___,,_'..... -~ .. .. ·0 . - ~ . -...-............. -~- ..~-

5. Gas Generation Records Remarks --. - ..~.-

G Readily available G Up to date '~/AV

6_

- - -_ ... _. ..

Settlement Monument Records

-.0 -­ ..._..

G Readily available G ~--- FjUp to da~~· A

Remarks --­ -----.----.- ··_,,·A.· ..........-..~

._-­

7. Groundwater Monitoring Records t!!J Readily available G Up to dale G N/A Remarks .,.....- _._..._._,- _•..._.. ........___.A. ____.·_,,_.

~.~- .-..-~ ..-. 0_,-",_'.

8. Leachate Extraction Records G Readily available G Up to date E}/ARemarks

~--~.

.._-y...... ..-­9. Discharge Compliance Rtcords

G Air G Readily available G Up to date G Water (effluenl) G Readily available Up to dale ~~ ~

..------~.-~ Remarks-------.- - --"'---". ­._- .......-- . .- ._-_.- ..- -.

10. Daily Access/Security Logs G Readily available G Up 10 uate VIA Remarks·__ w_

o. .~ ....... _._ .............--_. -~ .•.•- .-.--.-~ .... ----.,... '--~ -!... _._-_ ..... .....__ ............-..... ­-- .-.. ~----..- .. _- .- _.- .__..--_..

0-9

----

OSWER No. 9355.7-0JB-P

IV. O&M COSTS

I. O&M Organization G State in-boLLse G Contractor for State G PRP in-house G Contractor for PRP G Federal FaciiilX jp-house G ConlJach~T for Federal Facility G Olller --..t:. f"Ii ~()>1 -r(C!.- cAor .f 0 f' Lo,,::} 1~ t ""'"

2. O&M Cost Records G Readily available /iltup 10 dale G Funding mecbanism! men! in place Original O&M cos! esti 1IIe_..._________G Breakdown attached

Total Jnnual cost by year for r~view period if available

From To G Breakdown attached------. ."._--" ----~-Date Dale Total cost

From To G Breakdown attached------- --.- ...----- ..._--------Date Date Total cost

From To G Breakdown attached Date Date Tut<J1 cost

From To G Breakdown attached---- ------.-Date Date Total C(lst

From To G Breakdown attached----.-.-- -- ..-. Dal~ DJlt· TOla) cost

J. lInanticipated or Vnusually High O''''M Costs Ouring Review Period Describe costs and rca~ons: --------.- ._---_.__._----_.__._---.

- ........... _...•. _._-_ ........"-_._..__............_..... _------_ ...._-_...._--

V. ACClSS AND INSTITUTIONAL CONTROLS G Applicable G N/A

A. Fencing

I. Fencing damaged G LocatIOn shown on site map G Gales secured 0 .. Remarks ...... _ ... __..._._....__.." ....... . ._._~.__._._............._......._ ........ _..........__

B. Other Access Restrictions

!.

f)-IO

-- -

---------

-------

OSWEll No. 9355.7-Q3B-P

C. Institutional Controls (IC!)

I. Implementatlon aDd enforcement Site conclitions imply ICs not properly implemented G Yes G No G N/A Site conditions imply les not being fully enforced G Yes G No G N~

Type of monitoring (e.g., self-reporting, drive by) Frequency _. * __ - __ 0'

Responsible party/agency Contact _.­

-~.~ ". -Name Tille Date Phone no.

Reporting is up-to-date G Yes G No G N/A Reports are verified by the lead agency G Yes G No G N/A

Specific requiremenl~ in deed or decision documents have been met G Yes G No G N/A Violations have been reported G Yes G No G N/A Other problems or suggestions: G Report attached

.- ..... .... - --.. --".... .­--~ .-.~--.--

------------_._-_ .. ---_.... ---..--.. --_._­

2. Adequacy G ICs arc adeqllate G ICs are inadequate G N/A Remarks .-.,..-.. . .,._ •... ,,- .. _...._._­---------.... -_._----_._...._------...- .. ...---. .. --- ..----.----------.--..-----.~--~ '

-,-~., --- ."'-,- ..-- - -.-

D. General

I. Vandalism/trespassing G L..ocation shown on si':,rap 13:)0 ~~()aJiSrn evident Remarks ~~ .--l t? f il

~--- - -_._ .. - - ..... - --­

2. Land use changes on siteG Nt.'\.) Remarks___:?<J (c ';"'. ., h,~.·< fL-<!lS:"_~/~~~."-:''.;.__.L?,:j!rz :!If..e~-v£~j<.>-t

(1-~ s...:' /. .Y:.... __._ ._. _ ____ ~.. -. -- _. - --v..~-q .... ~..-.--- ..-.-­

3. Land use cbanges oU siteG N/A .• J. (

Remarks :it t I~ ~1£4£ d.b!:'. CZ~ ~T, ~~I:,~/JJ¥~=t lti2. - ........... . .. - ?

VI. GENERAL SITE CONDITIONS

A. ROllds G Applicable G N/A

I. Roads damaged G L..ocation shown on sIte map G Roads adequate ®__.__..Remarks- ... -- •.... ---_.. ... .-- ..~.-~.~-.--.-....~~---~... -- .-.... --~ .. ------_._-- ~,,~- .........,.--.-- ­.._...-~. .~....--- ..-..--- .... -.------.-~- --- ..----­

D-Il

OSIfIER No. 9355.7-03B·P

B. Other Sill' Conditions

VII. LANDFILL COVERS G).pplicablc G N/A

A. Landfill Surface

1. Settlement (Low spots) G l.ocation shown on site map (§:Aettlcment not evident Areal extent Dcpth___.__ ._

Remarks -----_.._._-_ .. _---_......__.._-_._---------- ­

2. Cntcks G Location shown on site map /Q Cracking not evident Lcngths___... _ ..'_ Widths Dcpths__._. .. l/ Remark~

3. Erosion G Loc~rion ,hllvin Ull site map @rOSion not evident Areal extent ._._._. __... Depth__ . Remarks_.________,___

4. Holes G Location shown on site map @;Oles not evident Areal extent _"'. __.. ' Depth____.. Remarks .. ____ ..

5. Vq~etati\'e ('over QJrass @uvcr ,)ropcrly eqahlished G No signs of Slres~ G TreesiShrubs (indicate size and locatiuns on a dlagr3m) Remarks

6. Alterllative Cover (jlTmorct! rock, concrete, tic.) @N/A Remarks _._----_._.._....._-_._-_.---_. --_._--_._­'.'.- .....

7, Bulges C; I ,[)cation shown on site mHp @OlllgeS not evident Areal exter'l_______._ Ilf:!lgllt ......... ___. Remarks_____.........___ . __..___ .____............______._____................_. _____._

.-------..----------.... -".-.--....---~~------.-----.-----,----_.-------

D·IZ

OSWEN No. 935.5.7·03B-P

8. Wet Areas/Water Damage {fi)wet areas/water damage not evident G Wet areas G Location shuwn on site map Areal extent, _______

G POfilling G Lucation shown on site map Areal extent_.______ G Seeps G Location shown on site map Areal extent_._____ G Soft sub grade G Location shown on site map Areal extent_._____ Remarks_____.. _._____________________.__________________

9. Slope Instability G Slides G Location shown on site map 'Vo,cvidencc of slope instability Areal ex.tcllt.________ Remarks,______________________________________

8. Benches G Applicable (1iIN1A \1iurizontally constructed mounds\,/carth placed across a steep lamlfill side slope 10 interrupt the slope in order 10 slow down the velocity of surface runoff and intercept and convey the runoff to 3 lined

channel.)

1. Flows Rypass Bench G Location shown on site map \'G\N/A or okayRemarks,_______________________________.__~~___________

2.

3. Rench Overtopped G Location shown on site map ~ N/A or okay Rernarks_____._________________________________

C. L~tdown Channels G Applicable (9::NIA (Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side slope oft.lJe cover and will allow the runoff Water colh:cted by the benches to move ofT of the landfill cover without creating erosion gullies.)

I. Sell/filleR! G Lo(:a!ion shown UII sile map \.70 cviden.:t: uf seUiemcnl ,'rcal exte'll____.___ Depth. ___ , _____ . Remarks.____________._____________________.___

2_ Matedlll Degradation G Location shol><'TI on site map G No evidence of degradation Material type___.____.._______ Areal extelll_. ___ ,....._ .. ,.. Remarks_..______________________________._____________

3. Erosion G Location shown on site map G No evidence of erosion Areal exlenl_______ Depth __ Remarks.__.__._______.____.___________....__....___.____.._____.. ,"_

D-U

OSWER No. 9355.7-03B·P

4. Undercutting G Location shown on site map G No evidence of undercutting Areal extt:nt Depth_____ Remarks_____.___•. _ .. ___.__.__.____________.. ___.___

5. Obstructions Type.____._____ G No obstructions

G Location shown on site map Areal cxtent_______ Size______ Remarks_______~__.___________________.___ .. ____ _

6. Excessive Vegetative Growtb Type_.___ .____._. G No evidence of excessive growth G Vegetation in channels dues not obstruct !low G Location shown on site map Areal extent________ Rcmarks__________

D. COYer Penetrations G ApplicabJe NNIA

'" I. Gas Vents G Active G Passive

G Properly securedllockedG FUJlctioning G Routinely sampled G Good comJition G Evidence of leakage at penetration G Needs Maintenance G N/A Remarks__.__._________ .___.____.___.

-<- ..

2. Gas Monitoring Probes G PropeTly securedllockedG FunctiQning G Routinely saUlpled G Gvod condition G Evidence of leakage at peneuation G Needs Maintenanct: G Ni A Remarks _______ ... ______. __.___...._...

3. Monitoring Wells (within surface area oflandfill) G Properly secured/!ockedG Functioning G Routinely sampled G Good condition G I::viJenct! of ki1ko~t! ~t penetration G Needs Maintenance G NiA

Remarks . ---_._--------_.-._---_..... __ ... _-----­

4. Leachate F.:draction Wells (; Propt:rly securerlilockedG Functioning G Routinely sampled C Good conditIon G Evidence of leakage at (ll:metration G Needs Maimcnam;c G NiA Remarks._______.._________...._.__._.___._

'i. Settlement Monllmenl~ G Located G Routinely surveyed C NIA Remarks____ ---,----------_.._---------------_._-----­

0-14

---- - --- ---

OSWER No. 93j5.7·03P·P

Eo Gas Collection and Tnatment G Applicable (G)/A I. Cas Treatment "'acilitie!

G Flaring G Thennal destruction G Good condition G Needs Maintenance Remarks "--'---

G Collection for reuse

.-_._-----_...•_._-­- " -

2. Gas Collet!ion Wells, Manifolds and Piping G Good condition G Needs Maintenance Remarks---_._------_._-----­ _.. - ­

3. Gas Monitoring Facilities (e.g., gas monitoring ofadjacent homes or buildings) G Good condition G Needs Maintenance G N/A Remarks------­ .----._--_.­

- _..

F. Cover Drainage Layer G Applicable %)/A .......

l. Outlet Pipes Inspected G Functioning G N/A Remarks--- ­ - --.--.. -.... ­ ... -- ­ -----.---.-----.-~-. .---..... ..-- ..---...-----~ ...--~.... '--'- ­_. -

2. Outlet Rock Inspected G Functioning G N/A Remarks.-­ -- ­ - ~--- ........_­

-­ -.­ -G. Detention/Sedimentation Ponds G Applicable f')N/A

v I. Siltation Areal extent Depth G N!A -

G Siltation nol evident Remarks--- -._-_._...._.-......._-_.. ...­ .. ---~---------.--.----.---.-.--_..-.~ -

2. Erosion Areal extent Depth ____.-----.-G ErOSion not evident Remarks - -.-- -------------_.-........ .. -~......--. ­

-..­ - .

J. Outlet Works Remarks-­ --

G Functioning G N/A .--._.- ­ ....­ ._-------- ­ ------ .. ...._­

. -4. Dam G Functioning G N/A

Remarks - __._ •• __ • __._. __•••_ ....___• __ • __... ___~.___.....~__ • ________• _ ••• _____ ....A. _ •••___•• .. .- ....- -.........

_._.... _...- .. - .. - .. --- -­

0-15

OSWER No. 9.155.7-03B·P

H. Retaining Walls G Applicable (3 N/A

I. f)eformations G Location shown on site map G Dcfomlution not evillen! Horizontal displacemenl_.__.____ Vertical displaccment_____ Rotational displacemcnt_. __._...__ Remarks_._______

Degradation G Location shown on site map G Degradation not evident Remarks____.___.___..._.________.. ___....______.._

I. Perimeter DltchesIOrr......... ite Discharge G Applicable (G )i/A

I. Siltation G Location shown on sire map G Siltation not evident Areal exlen'_______ Depth._.... '_. __' ._ Remarks---_._----_..__._-_._---.-------_._------_._­

2. Vegetative Growth G Location shown on site map G N/A G Vegetation does not impede flow Areal extent Type______ Remarks

3. Erosion r; Location ,hown on site !TI~p '., Erosion nOI evident Areal extent Depth_ ..____

Remarks

4. Discharge Structure G Functioning C N/A Remarks__...___.. _ ......._._ ....__.. _...... _....._._......................... ____.__...____ .......... __..............._..._.

I--------------------------------~---.--- ...--.. --VIII. VERTJCAL BARRIER WALLS G APpJicable@NlA

I. Settlement G Location ~hown Of] site map G Settlement not ev:dcllt

Arc31 extent_______ Depth _._.___

Remarks

2. Perfurrnance MoniloringType of monttoring __. G Performance not monitored Frequency______..____________ G Evidence of breaching Head differentwl

D·16

----

OSWER NQ. 9355.7-03B-P

IX. GROUNDWATER/SURFACE WATER REMEDIES @Applicable G NlA

A. Groum.lwatn Edtllclion WeUs, Pumps, and Pipelines (G)AppJieabJe G N/A

I. Pumps, Wellhead Plumbing, and IHectrical G Good condition BAli required wells properly operating G Needs Maintenance G Nt.'\. Remarks____._____._______._____.__._____.________.____

_·____..__.. _,____ .~~A_.. ...-.­. ­

2. Etltlllction System Pipelines, Valves, Valve noxes, and Otber Appurtenances @Jood condition G Needs Maintenance

Remarks -----,_.._----- ­-•.. -- ~-. - .-. .. ­

3. @;.re Parts and EqUipment eadilyavailable G Good condilion G Requires upgrade G Needs to be provided

Remarks •••• __ • __••n ________._.---'_••___·_

-_. .. ,..-..- ---- - .-

B. Surface Water Collection Structures, Pump~, lind Piptlines G Applicable CS@ I Collection Structures, Pumps, and Electrical

G Good condition G Needs Mainlenance Remarks ----_.

-_._---_._---------- ......._. _.__ .._------------ - ­ -~---

2 Surface Water Collection System Pipelines, Valv('s, Valve Boxes, and Other Appurtenances G Good condition (; Needs M~iJ1lenance Rcmarks._______._...___.~____..__.~ ...__ . ..-........-----------.-.--.-.--~---y-----

....--------~---.~----

3. Spare Parts and Equipment G Readily available G Good condition G Requires upgrade G Needs to be provided Remarks

.~.--- ----- .---_... _-_._------­~--------.--.--.~.-- ".'. ..

- - .- -. - - - .- -­

D-t7

OSWER No. 9J55_7-03~P

C. Treatment System G Applicable G N/A

I.

2

1.

4.

5.

Treatment Train (Check compone ~

G Metals removal G Oil/waler separation l....':: Uioremediati.v G Air stripping G G Filters ..____________________..

rc;;Ad(iffiV"e)'e.g., chelation agent, flocculent) ___________._ ,,____________________ ~.

G Good c~~dition-------G-Needs Mai~te~~~~~---- -------.----...­....---...". -­ --­ ------

G Sampling porlS properly marked and functional G Sampling/maintenance log displayed and up to dale G Equipment properly identified G Quantity of groundwater treated annually G Quantity of surface water treated annually____________________ Remarks.. ___________________________ ._________ ---__

G Needs Maintenance

.~----------------" --­ --------_.. -.._--_._----­

I)ischarge Slructu Q rtenanccs G Nt.". G Good co~n Remarks_ ___ .__._____________

G Needs Maintenance

Treatment HuillttiJrMH..-t---_

G N/A esp. roof and doorways) G Needs repair G Chemicals and eqOni'II'l11~rt-omrJeerly stored Ren,3rk,..._____________. ____

6. ~rl!!.& Wells (pump ~d emedy __ ~ (G Properly secured/locked 'unclionin G oUlinely sall1~ '(;--rurnyulCcd WellS TIre eeds Malii~1! ---

Remllfks•• ____ .________..__.____~________ _

D. Monitoring Data

MonJlori -!;)uir"'--­ ____

G Is routinely submitted on tin

2. ~QIli!Orin~-.____-G Groundwater plume is effectively contained

----------------------------~

G NIA

Tanks, Vaults, c...r.:;;=""If1......I~

G N/A Remarks

G Proper secondary containment

0-\8

--

OSWER No. 9355.7-0i8-P

D. Monitored Natural Attenuation

I. ~ODIlOring Wells (natural attenuation rcm~ Properly sccuredllockedG Functioning G outinely sampled {j;JJOOd condition

G All requiTed c:~OC~d / G ,!'leeds Maintenance 1. 'ht NfA I

Remarks _._I.., ~:'L.c:id ,he? cq'Ls.~_ (Y t... 9. ...: AI $ (1.lJ.J.~.--_. .. ~.. -- - - _.--'"<----

X. OTHER REMEDIES

If there are remedies applied at the site which are not covered above. attach an in~pection sheet describing the physical nalUIe lind condition of any facility associated with the remedy. An example would be soil vapor extraction.

XI. OV~RALL OBSERVATIONS

A. Implementlltion o(lbe Remedy

Describe issues and observations relating to whether the remedy is effective and functioning as deSigned. Begin With a brief statement of what the remedy is to accomplish (i.c., to contain contaminant

plume, minimiu infiltration lind gas emission, elc.). ~i .£h '~~"-!:: ,-$ ..U?C ~}G' N~, t-~ ...,c? i(,:,

~~ /'f.~: +~t..!JId(J-.£ :J,{ ;<;==~C_4.Lt;cL__

tv t II zW - ~ X~l~d... ci cr--.l d t'S &d k:kL­.­ .. . _._-_ .. _------------. ­ ----.--~-.----

._--_.__.

----------- ­---. -- .. - ­ -- ..---. ­

..-B. Adequacy or O&M

Describe iSSlies ~nd observations rel.Hed 10 Ihe implemenlatlon ,\nd scope t,f O&M proc~dures. In particular, dis,uss their relationship to the curren! and long-Ierm prolecllvenCss or Ihe remedy.

_ 3:-;7; :2~i'·S iJ~:3}:;.,~~Z _'____o~-~l~_I Je. pPa S. z.--;-.z&uU~.~~Z~~_~ f~" --D

JAr~ ~ -__ ,-_. -.£:L 7 t, .- ....$-_ ;>._~.:._ "-~~ 9.~-.. e,.:JL_-y_.C '4.<..-..L _______

._-------_••_-------- .-.---..- ..,--~--- __ A" ----- .- . ----- --.---.- --..----- ­"0 •• ~ •• _____~ __•• _ •• _____ ." •••••••___ • ____• ~~ •• _. ______ ._• .-----.~-.- .. ". ~--.--~-... ,...... --~,--...•. -.. -. ' ..-..- .. ...-.-.. --.... --'-~

- --.... - -.... .. '-.- .. _.--'-- .. - --....•

D-19

OSWER No. 9JJJ.7-03B-P .

C. Early Jndicators Dr Potential Remedy Problems

Describe issues and obselV2tions such as unexpected changes in the cost or scope of O&M or a high frequency of unscheduled repairs, that suggest that the protectiveness of the remedy may be compromised in the future.

----- ----....---- -.____tv/IL_-________ _ --.------------------.~-------------------- --------.-­

---------------------_.- _..--_._ ..._-------

D. Opportunities for Optimization

Describe possible opportunities for optimization in monitoring tasks or the op:::ratioll of the remedy.

---._----. -------- ------­

D-20

APPENDIXD

---~----

EPAREVIEW8 MACGILLI9 AND GIBBS COJ BELL LUMBER'. POL! CO_

SUPERFUND SITE NEW BRIGHTON, MINNESOTA

The U.S. Environmental Prolection AV~'"CY (U.S. EPA). wtth assistance Irom !he Minnesota PolMlon Control f".'J9nf:oJ IMPCA), 18 conducting a five­year review 01 the MaeGlilie and Gibbs ·Co.. !: Bill! Lumblir " Pole ,Co: Supllrl~nd eite. Superfund IBW requires flva-¥ear reviews ats~e.!l. where the cleanup is either done or In progres., but hazardbu9 waate remains on site. These flve-year revieWs are done to ensure thai the oleanup remains effaotlv:e and protects human h88"h and Ihe envlronment. Thl8 18 the ihlrd five-year review lor thla elte. The flrat· and 9BOOnd Itva-year reVIews wera completed In 2001 and In

2006. The first Ilva- year tltVfew co'ncluded thaj the eleanup III prolectlng people and Ihe envlronment.,Thesecond,flye-yesr ravlew concluded thaI In 1118 'remedy Is considered protective of Ihe peopls snd the enVironment. Tha current..thlrd review will look at: . . .

• site informallon • how Ihll cleBnup was done/ls progrellSln\l • how well thiI cleanup I. working .

" • any future BC!l0na nee~~. . , S~e records can be viewed at ,the offices of the Mlnnesola Pollution

ContrOl Agency, 520 Lafayette Rd. N., St:' Paul, Minnesota. 'The MPCA 18 open Mond,ay throultl Friday from. 6:00AM to 4:09PM. .To rav1ew the records, plllBse contact Chris Malec, Records Manager at (651) 297-5177. S~a records can also be viewed al the Ramsey County Ubrary. Vernon Hilla Branth. 1941 West County Road e-a. QUII8Uona and concems regarding thl) review &hould be dlrll(lted \Q:

Nila FellOwa or' Stacey Yonce ' ProJecl Managar Remedial Project Managel MPCA US. EPA 520 Lafayette Road North n Wesl Jackson Blvd (S-6J) I;>L Paul, Mlnne80ta 55155 Chicilgo. Illinois 60604 651/757-2352 312-886-2263 NI'e£llllo.YIli!hllllunll..u.s :&iwe,Slllcey@epagov

I(Bulletin: Sept. 29. 2010)

Affidavit of Publication

State of Minnesota) SS

County of Ramsey (

____--:;.A,.;;;NN;..;.;:...;,.;;;E'-T;;.,;:H;,,:;IL=.;;L;;;,;;.E""N_____________, being duly sworn, on oath, says that

helshe is the publisher or authorized agent and employee of the publisher of the newspaper known

as____NE.u...L..LJWl.L.JBL.LR~IGu.J-HI...JT'--'O.LNJ..L.JBu.Il_<J"'-I...... ..... , and has full knowledge of the facts which are.I"""'.E,T1....Iu.N.L'____

stated below:

(A) The newspaper has complied with all of the requirements constituting qualification as a qualified

newspaper, as provided by Minnesota Statute 331 A.02, 331 A.O?, and other applicable laws, as amended.

(8) The printed EPA REVIEWS

which is attached was cut from the columns of said newspaper, and was printed and published once each TH

week, for 1 successive weeks; it was first published on WEDNESDAY ,the 29 day of

SEPTEMBER, 20~, and was thereafter printed and published on every to and

including , the day of , 20__; and printed below is a copy of

the lower case alphabet from A to Z, both inclusive, which is hereby acknowledged as being the size and

kind of type used in the composition and publication of the notice:

"ABCDEFGHIJKLMNOPQRSTUIJ\NXYZ "ABCDEFGHIJKLMNOPQRSTUVWXYZ "abcdefghijklmnopqrsluvwxyz

Subscribed and sworn to before me on TH TITLE LEGAL COORDINATOR

29 day of SEPTEMBER, 20 10.

*Alphabet should be in the same size and kind of type as the notice. 'VV\l'f;{'tl'~oN'i\N'ANVV\AN\lV'N\IV""'" '\

C(·,!.~TONYA R. WHITEHEAD~f~\";~t,;~~ Notary Public Mjnnoso!n ~ RATE INFORMATION ~ t,".I~/lMy COr:1H1h',!Oll E~plws .1,," :!1, ~:c,!, ~ fi;"V'IVV\N\N'''''NVV'N\lV'''rv~ '.'\/]

(1) Lowest classified rate paid by commercial users for comparable space ............................................................ $25.00 per col. inch

(2) Maximum rate allowed by law for the above matter ........................................... $25.00 per col. inch

(3) Rate actually charged for the above matter ....................................................... $ per col. inch

1/10

APPENDIXE

MacGiliis & Gibbs Site - October 19,2010, MW-112

MacGiliis & Gibbs Site - October 19,2010, Berm and EW-ll

MacGiliis & Gibbs Site - October 19, 2010, Berm

MacGillis & Gibbs Site - October 19, 2010, EW-1

MacGiliis & Gibbs Site - October 19, 2010, EW-3

MacGiliis & Gibbs Site - October 19, 2010, EW-3B

MacGiliis & Gibbs Site - October 19, 2010, EW-4, MW-14

MacGiliis & Gibbs Site - October 19, 2010, EW-S, MW-19 (W,B)

MacGiliis & Gibbs Site - October 19, 2010, EW-7

MacGiliis & Gibbs Site - October 19, 2010, EW-8a

MacGillis & Gibbs Site - October 19, 2010, EW-ge

MacGillis & Gibbs Site - October 19, 2010, EW-9d

MacGillis &Gibbs Site - October 19,2010, EW-10

MacGiliis & Gibbs Site - October 19, 2010, Groundwater treatment plant

MacGiliis &Gibbs Site - October 19, 2010, Groundwater treatment plant

APPENDIXF

-----------------------------------------------------------------------------

.. - . Minnesota Department of Health 121 East Seventh·Place P.O. Box 64975 8t. Paul, MN 55164-0975

MEMORANDUM

DATE: June 10, 1996

TO: Licensed and Registered Well Contractors

~=~~;:reeled Cities and Counties

FROM: P . /rJn, ~r --u-Division of Environmental Health

PHONE: 612/215-0731

SUBJECT: Notice ofDesignation ofSpecial Well Construction Area in the Vicinity of the Twin Cities Anny Ammunition Plant

The Minnesota Department of Health (MOH) is designating a SPECIAL WELL CONSTRUCTION AREA which includes the cities ofNew Brighton, St. Anthony, and portions of Fridley, Mounds View, Arden Hills, Shoreview, Colum~ia Heights, Minneapolis, Falcon Heights, Lauderdale, and Roseville, as shown on the attached map. The Special Well Construction Are.a designation becomes effective on July 1, 1996, and will remain in effect until further notice.

Groundwater in portions of the designated area has been contaminated with volatile organic compounds (VOCs) from solventS used and disposed at the Twin Cities Army Ammunition Plant (TCAAP) in Arden Hills. There are two areas of contamination. The largest area of contamination extends several miles to the south and west ofTCAAP, to depths of several hundred feet. Here, portions of tile buried sand formation (Hillside Sand formation) and the Prairie du Chien dolomite and Jordan sandstone bedrock formations have been contaminated with VOCs. A second, much smaller area of VOCs contamination exists in the surficial sand and silt deposits (Fridley formation) to the north and west ofTCAAP, to depths of approximately 45 feet.

The unconsoHdated hydroaeologic formations to the southwest of TCAAP consist ofa discontinuous layer of alluvium and lacustrine deposits (Fridley formation) over glacial till (Twin Cities ronnation) over the Hillside Sand formation. The combined thickness of these formations ranges from SO to more than 300 feet. The Fridley and Twin Cities formations to the southwest ofTCAAP are not contaminated by TCAAP contaminants; the Hillside Sand formation is contaminated at the TCAAP facility and to the southwest ofTCAAP. The unconsolidated formations immediately southwest of TCAAP are underlain by the contaminated Prairie du Chien and Jordan formations. Farther to the south and west, the Platteville limestone, Glenwood shale; and St. Peter sandstone occur above the Prairie du Chien formation. Contamination from the TCAAP facility has not been found in the . Platteville, Glenwood, or St. Peter formations.

TOO: (612) 623-5522 (Twin Cities) 1-800-627-3529 (Greater Minnesota)

An Equal Opportunity Employer

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-2- . e Efforts to contain and clean up the contamination at the TCAAP facility and to the south ofTCAAP have been Wldenvay for many years. For example, several wells are being used to contain and extract contaminated sroWldwater, which is then.treated to remove the VOCs. Steps have also been taken to remove from service and permanently seal other water-supply wells which have been contaminated in excess of the MDH's Health Risk Limits (HRLs) and present a public health threat.

The MDH, the Minnesota Pollution Control Agency (MPCA), and the u.s. Army are concemed about the public health effects that could result from the use of water-supply wells in the contaminated aquifers. The MDH and MPCA are also concerned that the construction of new wells or modification of existing wells within the Special Well Construction Area may interfere with cleanup efforts, or may cause further spread of the contamination.

BOUNDARIES OF THE SPECIAL WELL CONSTRUCTION AREA

The designated Special Well Construction Area is bounded on the west by State Highway 6S and on the south by Hennepin and Larpenteur Avenues. The east boundary follows Fairview Avenue north from Larpenteur Avenue to Lake Johanna Boulevard, then north and east on Lake Johanna Boulevard to County Road E, then east on County Road E to Lexington Avenue. then north on Lexington Avenue to County Road I. The north boundary extends due west of the intersection of Lexington Avenue and County Road I to Snelling Avenue North, then north on Snelling Avenue North to Lois Drive, then west on Lois Drive to Schutta Road, then west from the intersection ofLois Drive and Schutta Road to Rice Creek, then south on Rice Creek to County Road I. then west on County Road I to State Highway6S. This area includes portions of Anoka, Hennepin, and Ramsey Counties .

.~ -:-- ... . Wetl construction, morutOnng, and temedi&rae1lvitiei\Vfthin TCAAP's boundaries are subject to the

conditions of the Federal Facilities Agreement, which is overseen by the MPCA and the United States Environmental Protection Agency (U.S. EPA). Therefore, the TCAAP facility itself is not included in the Designated Special Well Construction Area.

REQUIREMENTS IN THE SPECIAL WELL CONSTRUCTION AREA

1. All wells regulated by the MDH are subject to the requirements of this Special Well Construction Area. 'This includes potable water-supply wells, irrigation wells, commercial and industrial water-supply wells, wells for heating and cooling, remedial wells, monitoring wells, and dewatering wells.

2. Construction of a new well or modification of the depth of an existing well may not take place until after the MDH has reviewed and approved plans for the proposed construction. In addition to the required permit application or notification, the plan must include the following information: street address; well depth; casing type, diameter, and depth; method of construction, including grout materials and grout method; pumping rate; and well use.

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3. If the proposeci construction or reconstruction of a potable water-supply well is approved, the MDH may require that one or more water samples be collected and analyzed for VOCs before the well is grouted and put into service. If contamination is present in excess of the HRLs, the well must be permanently sealed or reconstructed. The New Brighton and St. Anthony municipal water-supply wells, which are treated to remove VOCs, are exempt from this requirement.

4. The permanent sealing of a well completed in or below the Prairie du Chien formation may not take place until after the MDH has reviewed and approved plans for the proposed sealing. In addition to.the required wen sealing notification. the plan must include the folloWing information: street address; original well depth; current well depth; casing type(s), diameter(s) and depth(s); methods for identifying and sealing any open annular space; methods for identifying and removing any obstructions; and grout material and methods.

PERSONS TO CONTACT;. ,

For additional information regarding this Special Well Construction Area, contact Ed Schneider at the MDH at 612/215-0827.

Well construction and well sealing plans should submitted to:

Patrick Sarafolean Mirmesota Department of Health WeU.Management Unit 121 East Seventh Place, Suite 220 P.O. Box 64975 St. Paul, Minnesota 55164-0975

For additional information regarding plan review or water sampling, contact Patrick Sarafolean at the MDH at 6121215-0826. .

Plans for well construction and well sealing in the city of Minneapolis may be submitted to:

Tom Frame City of Minneapolis - Public Health Center 250 South Fourth Street, Room 300 Minneapolis, Minnesota 55415

Phone: 612/673-2170

For information regarding the investigation, monitoring, and remediation of the contamination associated with TCAAP, contact: .

Dagmar Romano at the MPCA at 6121296-7776

Tom Barounis at the U.S. EPA, Region V, at 312/353-5577

Martin McCleery at the U. S. Army at 612/633-2301, Extension 1651

PAB:ECS:mr Enclosure

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NMinnesota Department of Health JuIy1.1996Geographic lnfomwlion System tcalp.lpr