fifth five year review report (signed) - 2015 · fifth five-year review report for waite park wells...

FIFTH FIVE-YEAR REVIEW REPORT FOR WAITE PARK WELLS SUPERFUND SITE

Including State Superfund Sites Electric Machinery Manufacturing Company, Waite Park Wells and Burlington Northern Car Shop

CITIES OF WAITE PARK AND ST. CLOUD, MINNESOTA STEARNS COUNTY

___ 1{~_:!_4_ Kathryn Sather, Director Remediaf n Division

Prepared by ,

Minnesota Pollution Control Agency Remediation Division

St. Paul, MN

and

U.S. Environmental Protection Agency Region 5

Superfund Division Chicago, IL

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L. Ric~~~~l, Director /~perfund Division

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U.S. Environmental Protection Agency

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TABLE OF CONTENTS

LIST OF AC.RONYMS ························•·······•·············································································· iii EXECUTIVE SUMMARY ··········································•·······e··········································--············ 1 FIVE-YEAR RE-VIEW SUMMARY FORM ................ ~ ....•........•.......•.............•.•..•••..•..•........... 5 I. INTRODUCTION .................................................................................................... ~ ....... 12 II. PROGRE-SS SINCE THE LAST RE-VIEW ...............•.....•................•......••.. ~ •..•...•.......• 13

Remedy Implementation Activities ...................................................... : ................................... 17 Operation.and Maiutenanc~ Activities ...................................................................................... 17 Institutional Controls ............. -........................................................................ 18 Redevelopment. .................. · ......................................................................... 21

I . III. FIVE-YEAR RE-VIEW PROCESS· .•.•.•.•..••...............•..•....•...•..•.............•....••.........•.•..•.• 21

Administrative Components ....... : ............................................................................................. 21 Community Notification and Involvement. .............................................................................. 21 Document Review ...................................................................................................................... 21 Data Review ....................................... ; ..................................................................................... 22 Site Inspection ................................................................................................................. : ........ 25 Interviews ................................................................................. : ................................................. 27

IV. TECHNICAL ASSESSMENT ...........................................•............................................ 28 Technical Assessment Summary ............................................................................................... 30

V. Issues/R.ecommendations and Followup Actions .••••.•.....•.....................•.•..•...• u ............ 31 VII. Protectiveness Statements .•......•...••..•..••••..............••.•....................•.••••.•.•.....................•..... 34

VII. Next Review .....•...........•..••....•..•..•.......•...........••...•.•.• ~ ... ~ ......•....•.......•......•.•...•....•.•....•....•• 3 6

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TABLE OF CONTENTS CONTINUED

Figures Figure· 1: Site Location Map

Electric Machinery Figur,es (referenced in text as OU1 Figure#) Figure 1: Shallow Groundwater Contour Elevation Map

Figure 2: Deep Groundwater Contour Elevation Map Figures 4-11: Trend Graphs of VOC Concentrations

Burlington Northern Figures (referenced in text as OU2 Figure#)

Figure 1: BNSF Waite Park Car Shop Site Location and Configuration Institutional Control Figures (referenced in text as IC Figure#)

Figure 1: Receptor Location Map Figure 2: Parcel Map

Tables Table 1: P.~;otectiveness Determinations/Statements from the 2010 FYR and Addendum Table 2: Status of Recommendations from the 2010 FYR and Addendum Table 3: Institutional Controls Summary

Table 4: MPCA Superfund and VIC Program Sites

Table 5: Well Receptor Summary Table 6: Documents Reviewed Table 7: Groundwater Cleanup Levels Table 8: Vapor Intrusion Standards

Table 9: Monitoring Well Inspection Results Table 10: Interview Summary Table 11: MPCA and EPA Issues and Recommendations for OU1 Table 12: MPCA Issues and Recommendations for OU2

Appendices A -Existing Site Information

B - Photograph Log from Site Inspections C - Interview Documentation

D- Public Notice

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LIST OF ACRONYMS

flg/L .. .......... micrograms per Liter ACM ........... Asbestos-Containing Material AMR ........... Annual Monitoring Report ARAR ......... Applicable or Relevant and

Appropriate Requirement BN .............. Burlington Northern Railway

Company . CERCLA .... Comprehensive Environmental

Response, Compensation, and Liability Act

CFR ............ Code of Federal Regulations Ch ............... Chapter City ............. City of Waite Park COC ............ Contaminant of Concern cVOC .......... Chlorinated Volatile Organic

Compound CW A .......... Clean Water Act DCA ........... 1,1-Dichloroethane DCE ............ 1,2-Dichloroethene DNR ........... Department of Natural Resources DWSMA ..... Drinking Water Supply

Management Area EM .............. Electric Machinery Manufacturing

Company EPA ............ United States Environmental

Protection Agency ESD ............ Explanation of Significant

Difference FS ............... Feasibility Study HBV ........... Health Based Value HRL ............ Health Risk Limit IC ................ Institutional Control IRIS ............ Integrated Risk Information System ISV ........... Intrusion Screening Value MCES ......... Metropolitan Council

Environmental Services MCL ........... Maximum Contaminant Level MCLG ........ Maximum Contaminant Level Goal MDH .......... Minnesota Department of Health MERLA ...... Minnesota Environmental

Response and Liability Act, state Superfund law

mg/kg .......... milligrams per kilogram Minn. Stat. . Minnesota Statute Minn. .. ....... Minnesota

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MPCA ........ Minnesota Pollution Control Agency

NCP ............ National Oil and Hazardous Substances Pollution Contingency Plan

NPDES ....... National Pollutant Discharge Elimination System

NPL ............ National Priorities List O&M .......... Operation and Maintenance OU .............. Operable Unit P AH ............ Polycyclic Aromatic Hydrocarbon PCB ............ Polychlorinated Biphenyl PCE ............ Tetrachloroethylene/

Perchloroethylene/ Tetrachloroethene

PLP ............. Permanent List of Priorities PVC ............ Polyvinyl Chloride RA .............. Remedial Action/Response Action RAGS ......... Risk Assessment Guidance for

Superfund RAL ............ Recommended Allowable Limit RAO ........... Remedial Action Objective RCRA ......... Resource Conservation and

Recovery Act RD ....... , ...... Remedial Design RDIRA ....... Remedial Design/Response Action RFRA ......... Request for Response Action RI/FS .......... Remedial Investigation/Feasibility

Study ROD ........... Record of Decision RP ............... Responsible Party SARA ......... Superfund Amendments and

Reauthorization Act of 1986 SEH ............ Short Elliot Hendrickson, Inc. SVE ............ Soil Vapor Extraction TBC ............ To Be Considered TCA. ........... 1,1, 1-Trichloroethane TCE ............ Trichloroethylene/Trichloroethene UU/UE ....... Unlimited Use and Unrestricted

Exposure VIC ............. Voluntary Investigation and

Cleanup VOC ........... Volatile Organic Compound WHPA ........ Wellhead Protection Area WPW .......... Waite Park Wells .

EXECUTIVE SUMMARY

The Minnesota Pollution Control Agency (MPCA), with the assistance of the United States Environmental Protection Agency (EPA), has conducted the fifth Five-Year Review (FYR) for the Waite Park Wells Site (Site) located in the Cities of Waite Park and St. Cloud, Steams County, Minnesota. The purpose of this FYR is to review information to determine whether the remedy is, and will continue to be, protective of human health and the environment. The triggering action for this FYR was the signing of the fourth FYR on May 27, 20IO. This review is a statutory review for Operable Unit (OU) I and is a discretionary review for OU2, for the reasons explained below.

In this review, EPA makes a protectiveness determination for QUI because EPA concurred with the OUI Record of Decision (ROD). At the time ofthe OU2 ROD, the Site was entered into the Enforcement Deferral Pilot Project agreement between EPA and MPCA. Under this agreement, EPA was not asked to concur with remedy decisions. Therefore, EPA took no position on the OU2 ROD and does not make a protectiveness determination for OU2 in this FYR, although EPA has done so in previous years because it is EPA's discretion to consider areas of a site where no remedial action has been selected by EPA. Instead, this FYR clarifies the difference between the two OUs and documents MPCA's recommendations and protectiveness determination for OU2 in a separate section of the FYR.

The Site consists of a contaminated groundwater plume that impacted the City of Waite Park municipal wells, and adjacent properties thought to be the source of that contamination formerly or presently owned by the Electric Machinery Manufacturing Company (EM) and the former Burlington Northern Railroad Company (BN). The Site was listed on the National Priorities List (NPL) in I986. Three parts of the Site were listed separately on the State of Minnesota's Permanent List ofPriorities (PLP) as the Waite Park Wells (WPW) site, the EM site, and the BN Car Shop site. The MPCA is the lead Agency for overseeing cleanup of the entire Site and manages the Site under the terms of the Enforcement Deferral Pilot Project agreement with EPA. The EPA tracks activities at the EM site as OUI of the Site and activities at the BN Car Shop site as OU2. The EPA's nomenclature is used in this FYR. The EPA has not assigned an OU designation to the WPW site because actions for this site were completed prior to a ROD. The source area for QUI is located in the City of St. Cloud and the OUI groundwater plume impacts both St. Cloud and the City of Waite Park. OU2 is located in the City of Waite Park, and is divided into eight areas, A through H. MPCA managed the BN Car Shop site (tracked by EPA as OU2), as three separate OUs; however, this FYR uses EPA's nomenclature.

Early Actions

In response to contamination in the City of Waite Park (City) wells, in I985 the MPCA installed an emergency drinking water connection between the City and the City of St. Cloud to provide clean drinking water. In I985 and I986, the MPCA issued three Requests for Response Action (RFRAs) to various responsible parties for contamination at OUI and OU2, citing these areas as sources of contamination found in the City's wells. Between I986 and I988, potentially responsible parties (PRPs) funded construction of an air stripper to remove contaminants from the City water supply and the City subsequently resumed use of their wells and assumed responsibility for operation and maintenance (O&M) of the treatment system. Since that time, the City has abandoned several older wells, added additional wells, and constructed a new higher capacity treatment system that remains in operation today.

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OUl

The MPCA signed a Record ofDecision (ROD) for OU1 on January 5, 1989, and the EPA concurred with the ROD on September 28, 1989. The remedial action objectives (RAOs) were to prevent migration of contaminants to the City wells and to restore the contaminated aquifer. The major components of the OU1 remedy are:

• Installing groundwater extraction wells in the contamination plumes;

• Treating contaminated groundwater via packed tower aeration; and

• Discharging treated groundwater from the packed tower aeration system to the Sauk River under a National Pollutant Discharge Elimination System (NPDES) permit.

The ROD also included a statement that the MPCA would require that a deed notice be placed on the property. The ROD stated that cleanup actions for soil were not necessary because precipitation would passively flush soil contaminants and the contamination would be captured by groundwater extraction wells.

PRPs constructed a groundwater pump and treat system at OUl. It operated from 1988 to 2001, when it was shut down after contaminant levels stopped declining, although groundwater concentrations remained above cleanup levels established in the ROD. In 1999, PRPs reinvestigated soil contamination at the property, and subsequently conducted a soil removal action and constructed a pilot-scale Soil Vapor Extraction (SVE) system to treat soil in one area. The SVE system operated from 2000 to 2002, when it was shut down after contaminant levels stopped declining. No soil or groundwater treatment is operating currently at OU1, and the municipal well system is capturing and treating all or most of the groundwater plume prior to distribution.

OU2 _

Beginning in 1988, the PRP implemented cleanup actions at OU2 under MPCA's Tanks and Spills program's oversight. Actions included removal of sandblast sands, removal of underground and above-ground storage tanks, and thermal treatment of contaminated soil. The MPCA signed a ROD to address contamination remaining at OU2 on July 14, 1994. The RAOs for the OU2 remedy are to prevent current or future exposure to the contaminated soils and to reduce contaminant migration into the groundwater. The major components of the remedy are as follows:

• Excavation of the lagoon waste, sandblast sands, and the dirt floor of the paint building, and incorporation of the consolidated sandblast sands;

• Solidification/stabilization of the waste to reduce the concentration of contaminants to below hazardous levels and to minimize the mobility of the contaminants in the waste material;

• Placement of the treated waste in a containment facility constructed on-site with a liner system, leachate collection and detection, cover system, groundwater monitoring, and gas collection;

• Restrictions placed on any area that is not remediated to unrestricted land use remediation levels and on property containing the containment facility;

• Groundwater monitoring network and groundwater monitoring plan; and

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• Area A remediation to unrestricted land use levels, and Areas B through H remediation to commercial/industrial land use levels.

Many components of the 002 remedy were completed by 1995, including excavation and stockpiling of contaminated soils from Areas A, B, C, and H.

The MPCA modified the OU2 ROD in an Explanation of Significant Differences (ESD) dated August 11, 1998. The ESD documented that an integrated remedy would be used to address the remaining areas of impacted soil at the site:

The Integrated Remedy will use a risk-based approach that may include a combination of any of the following remedial actions: excavation, treatment and hauling to an off-site landfill; evaluating risk of exposure to public health and the environment to determine if impacted material may remain in place; and use of engineering and institutional controls to ensure that the remedy remains protective of public health and the environment.

The ESD further specified that soil excavated from Areas A, B, C, and H would be stabilized and hauled to an off-site landfill, and stated the following regarding Institutional Controls (ICs):

IC language will reflect site conditions to assure that response actions remain · protective of public health ahd the environment by limiting uses or activities on

the property that could result in exposure to hazardous substances that remain on the property after response actions are completed. An example of this is Area A where ...... (i)mpacted soil and debris remain at a depth greater than four feet. IC language will be developed and filed with the property deed that place restrictions on excavation activities at depths greater than four feet. The language will also serve as a mechanism.to notify appropriate parties ofthe presence of residual contamination and accompanying controls and/or ensure long-term mitigation measures or monitoring requirements (e.g., engineering controls) are carried out and maintained.

Between 1999 and 2002, contaminated soils from various areas ofOU2, including the areas specified in the ESD, were excavated, stabilized, and disposed of at an off-site landfill. Following implementation ofiCs, Area A was deeded to the City and redeveloped into a City park, and certain other areas were redeveloped for commercial use. Groundwater monitoring, with the exception of monitoring related to the containment unit was discontinued prior to 2000 after contaminants were no longer detected or detected at very low levels. Monitoring wells were plugged after approval by the MPCA, and OU2 was delisted from the PLP in 2002.

Based on the current review of site activities and progress over the past five years, the MPCA and EPA find that a protectiveness determination for the Site cannot be made until further information regarding OU1 is obtained through taking the following action:

• Evaluate the vapor intrusion pathway for all buildings not yet assessed that overlie the plume, and conduct remedial actions as needed.

In addition, in order to ensure the Site-wide remedy is protective in the long-term, the following actions need to be taken: ·

• OU1: Define the extent and magnitude of contaminated groundwater in the shallow and deep aquifers north of the Site, and demonstrate its capture. Include an evaluation of any continuing flow to the Sauk River.

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• OUl: Re-start the on-site pump and treat system or modify the ROD to select an alternative remedy for groundwater.

• OUl: Assess the extent and magnitude of additional source areas, and evaluate whether source control actions are necessary to achieve groundwater cleanup goals.

• OUl: Review for presence of improperly abandoned wells, and take action as needed. • OUl: Develop and implement an IC work plan for OUl that ensures that effective ICs

are in place and includes long-term stewardship ofiCs. • OU2: Address issues identified by MPCA.

Long-term protectiveness requires compliance with effective ICs at both OUs. Compliance with effective ICs will be ensured through long-term stewardship by implementing, maintaining and monitoring the ICs as well as maintaining the Site remedy components.

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FIVE-YEAR REVIEW SUMMARY FORM

SITE IDENTIFICATION

Site Name: Waite Park Wells

EPA ID: MND981 002249

Region: 5 State: MN

SITE STATUS

NPL Status: Final

City/County: Waite Park and St. Cloud, Steams County

Multiple OUs?

Yes

Has the site achieved construction completion? Yes

REVIEW STATUS

Lead agency: State {If "Other Federal Agency", enter Agency name]: the MPCA

Author name (Federal or State Project Manager): Wayne Sarappo

Author affiliation: the MPCA

Review period: 5/27/2010 - 3/31/2015

Date of site inspection: 2/17/2015

Type of review: Statutory

Review number: 5

Triggering action date: May 27, 2010

Due date (five years after triggering action date): May 27, 2015

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MPCA and EPA have identified the following issues and recommendations for OUI. These issues will be tracked by MPCA and EPA because EPA concurred with the OUI ROD.

~~~~~~~,'~i~~l!~~~~m~[~~~t.~;~l~~~~~t~~:~~~~~~:~~~~!i~~~x:~~,f~,~~~~~)t;~':!il,~:~,~~itl~~·~· OV(s):OUJ Issue Category: Changed Site Conditions

Issue: Vapor intrusion risk has not been assessed for off-site buildings that may overlie the contaminated groundwater plume.

Recommendation: Evaluate the vapor intrusion pathway for all buildings not yet assessed that overlie the plume and conduct remedial actions as needed.

Affect Current Affect Future Protectiveness Protectiveness

Party Responsible

Oversight Party

Milestone Date

Unknown Yes OUI PRPs MPCA/EPA 3/30/2017

OU(s): OUJ Issue Category: Remedy Performance

Issue: The extent and magnitude of contaminated groundwater in the shallow and deep aquifers is unclear north of the site, and it is unclear whether the entire plume is being captured and treated by the City wells.

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Recommendation: Define the extent and magnitude of contaminated groundwater in the shallow and deep aquifers north of the site, and demonstrate its capture. Include an evaluation of any continuing flow to the Sauk River.

Affect Current Affect Future Party Oversight Milestone Date Protectiveness Protectiveness Responsible Party

No Yes OUI PRPs MPCAIEPA 5/30/2016


Issue: On-site groundwater remains above cleanup levels and the on-site pump and treat system is shut down.

Recommendation: Require re-start, ofthe on-site pump and treat system or modify the ROD to select an alternative remedy for groundwater.


No Yes MPCA EPA 12/30/2016

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Issue: Groundwater and soil gas data indicate the presence of additional source areas near or beneath the Former EM Building.

Recommendation: Assess the extent and magnitude of additional source areas and evaluate whether source control actions are necessary to achieve groundwater cleanup goals.


No Yes OUl PRPs MPCA/EPA 12/30/2016

OU(s): OUJ Issue Category: Operations and Maintenance

Issue: There are unmarked wells at the site that may not have been properly abandoned. J

Recommendation: Review for presence of improperly abandoned wells and take action as needed.



OU(s): OUJ Issue Category: Institutional Controls

Issue: Implementation of ICs is incomplete and there are no measures in place for long-term stewardship ofiCs.

Recommendation: Develop and implement an IC work plan for QUI that ensures that effective ICs are in place and includes long-term stewardship ofiCs.



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MPCA and EPA make the following protectiveness statement for OUl because EPA concurred with the OUl ROD ..

Protectiveness Statement(s)

Operable Unit: OU1

Protectiveness Statement:

Protectiveness Determination:· Protectiveness Deferred

Addendum Due Date: 5/30/2017

A protectiveness determination for the OU1 remedy cannot be made until further information is obtained by taking the following action:

• Evaluate the vapor intrusion pathway for all buildings not yet assessed that overlie the plume, and conduct remedial actions as needed. ·

It is expected that it will take approximately 10 months to complete the investigation and an additional 12 months to complete the remedial actions that may be needed. When remedial actions are completed, a protectivene,ss determination will be made. In addition, in order for the remedy to be protective in the long-term, the following actions need tobe taken to ensure protectiveness:

• Define the extent and magnitude of contaminated groundwater in the shallow and deep aquifers north of the Site, and demonstrate its capture. Include an evaluation of any continuing flow to the Sauk River.

• Re-start the on-site pump and treat system or modify the ROD to select an alternative remedy for groundwater. ·

• Assess the extent and magnitude of additional source areas, and evalpate whether source control actions are necessary to achieve groundwater cleanup goals.

• Review for presence of improperly abandoned wells and take action as needed.

• Develop and implement an IC work plan that ensures that effective ICs are in place and includes long-term stewardship of ICs.

Long-term protectiveness also requires compliance with effective ICs. Compliance with effective ICs will be ensured through long-term stewardship. by implementing, maintaining and monitoring the ICs as well as maintaining the Site remedy components.

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MPCA has identified the following issues and recommendations for OU2. These issues will be tracked by MPCA because EPA did not take a position on the OU2 ROD.

OU(s): OU2 Issue Category: Changed Site Conditions

Issue: Standards for commercial/ industrial use have changed since the time of the ROD.

Recommendation: Confirm that undeveloped parcels remain within the acceptable risk range for commercial/ industrial use.


No Yes OU2PRP MPCA 5/30/2016

OU(s): OU2 Issue Category: Changed Site Conditions

Issue: Groundwater exceeded the current .Health Risk Limit for PCBs in one monitoring well at the time monitoring was discontinued in 1998.

Recommendation: Confirm that groundwater downgradient of former monitoring well MPCA -14S meets the current Health Risk Limits for PCBs.


No Yes OU2PRP MPCA 7/30/2015

OU(s): OU2 Issue Category: Operations and Maintenance

Issue: It is unclear ,whether former monitoring wells MPCA-13D, MPCA-3D and ERT-26D have been properly abandoned.

Recommendation: Ensure that monitoring wells MPCA-13D, MPCA-3D and ERT-26D, if not needed, are properly abandoned.

·Affect Current Affect Future Party Oversight Milestone Date Protectiveness Protectiveness Responsible Party

No Yes City MPCA 5/30/2016

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OU(s): OU2 Issue Category: Institutional Controls

Issue: Implementation ofiCs is incomplete and there are no measures in place for long-term stewardship ofiCs.

Recommendation: Develop and implement an IC work plan for each OU that ensures that effective ICs are in place and includes long-term stewardship of ICs.


No Yes OU2PRPs MPCA 5/30/2017

MPCA makes the following protectiveness statement for OU2. EPA did not take a position on the OU2 ROD so does not make a protectiveness statement for OU2.


Operable Unit: OU2


Protectiveness Determination:. Short-term Protective

The OU2 remedy currently protects human health and the environment due to completed response activities, including removal of sandblast sands, contaminated soils, and storage tanks, and on-site containment of thermally t~eated wastes; however, in order for the remedy to be protective 1n the longterm, the following a9tions need to be taken to ensure protectiveness:

• Confirm that undeveloped parcels remain within the acceptable risk range for commercial/ industrial use.

• Confirm that groundwater downgradient offormer monitoring well MPCA-14S meets current Health Risk Limits for PCBs.

• Ensure that monitoring wells MPCA-13D, MPCA-3D and ERT-26D, if not needed, are properly abandoned.


Long-term protectiveness also requires maintenance ofthe remedy and compliance with effective ICs. Compliance with effective ICs will be ensured through long-term stewardship by implementing, maintaining and monitoring the ICs as well as maintaining the Site remedy components.

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EPA and MPCA make the following Site-wide protectiveness statement.

Site-Wide Pt·otectiveness Statement

Operable Unit: Protectiveness Determination: Addendum Due Date: 5/30/2017 NA Protectiveness Deferred


A protectiveness determination for the Site cannot be made until further information is obtained at OUI by taking the following action:


In addition, in order for the Site-wide remedy to be protective in the long-term, the following actions need to be taken to ensure protectiveness:

• OUI: Define the extent and magnitude of contaminated groundwater in the shallow and deep aquifers north ofthe Site, and demonstrate its capture. Include an evaluation of any continuing flow to the Sauk River.

• OUI: Re-start the on-site pump and treat system or modify the ROD to select an altern~tive remedy for groundwater.

• OUI: Assess the extent and magnitude of additional source areas, and evaluate whether source control actions are necessary to achieve groundwater cleanup goals.

• OUI: Review for presence of improperly abandoned wells and take action as needed. • OUI: Develop and implement an IC work plan for OUI that ensures that effective ICs are in

place and includes long-term stewardship of ICs. • OU2: Address issues identified by MPCA. ·

Long-term protectiveness also requires compliance with effective ICs. Compliance with effective ICs will be ensured through long-term stewardship by implementing, maintaining and monitoring the ICs as well as maintaining the Site remedy components.

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I. INTRODUCTION

The purpose of a FYR is to evaluate a remedy's implementation and performance remedy in order to determine whether the remedy will continue to protect human health and the environment. The methods, findings, and conclusions of reviews are documented in FYR reports. In addition, FYR reports identify issues found during the review, if any, and document recommendations to address them.

The EPA prepares FYRs pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 121 and the National Contingency Plan (NCP). CERCLA 121 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 each five years after the initiation of such 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 [I 04] or [I 06], the President shall take or require such action. The President shall report to the Congress a list of facilities for which such review is required, the results of all such reviews, and any actions taken as a result of such reviews. "

The EPA interpreted this requirement further in the NCP; 40 Code ofFederal Regulations (CFR) Section 300.430(f)( 4)(ii), which states:

"If a 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 actions no less often than every five years after the initiation of the selected remedial action."

The MPCA conducted a FYR on the remedy implemented at the Site located in the Cities of Waite Park and St. Cloud, Stearns County, Minnesota, following EPA guidance. This report documents the review's results, including whether the remedial actions contillue to protect public health, welfare, and the environment. Bay West LLC (Bay West), under the Superfund, Petroleum, and Agriculture Professional Environmental MultiSite Contract, assisted MPCA in completing this review. The EPA also assisted with the review.

In this review, EPA makes a protectiveness determination for OU1 because EPA concurred with the OU1 ROD. At the time of the OU2 ROD, the Site was entered into the Enforcement Deferral Pilot Project agreement between EPA and MPCA. Under this agreement, EPA was not asked to concur with remedy decisions. Therefore, EPA took no position on the OU2 ROD and does not make a protectiveness determination for OU2 in this FYR, although EPA has done so in previous years because it is within EPA's. discretion to consider areas of a site where no remedial action has been selected by EPA. Instead, this FYR clarifies the difference between the two OUs and documents MPCA's recommendations and protective~ess determination for OU2 in a separate section of the FYR.

This is the fifth FYR for the Site. It is required due to the fact that hazardous substances, pollutants, or contaminants remain at the Site above levels that allow for unlimited use and unrestricted exposure (UU/UE). The triggering action for this review is the signing of the previous FYR on May 27,2010. The review of OU1 is a statutory review because the EPA concurred with the OU1 ROD. The review of OU2 is a discretionary review because the EPA did not take a position on the OU2 ROD.

The Site consists of a contaminated groundwater plume that impacted City of Waite Park (City) municipal wells and adjacent properties owned at the time of the RODs by the Electric Machinery Manufacturing Company and the former Burlington Northern Railroad Company that were suspected to be the source of that contamination. The Site was listed on the NPL in 1986. Three parts of the Site were listed separately on

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the State of Minnesota's PLP as the WPW site, the EM site, and the BN site. The Site is included in the MPCA Enforcement Deferral Pilot Project the MPCA is the lead Agency for overseeing cleanup of the Site. The EPA tracks the EM site as OU1 (hereafter "OU1 ") and the BN site as OU2 ("OU2"). EPA has not designated the WPW site a separate OU because actions for this site were completed prior to a ROD.

II. PROGRESS SINCE THE LAST REVIEW

In the 2010 FYR, MPCA and EPA deferred protectiveness determinations for OU1 and for the Site as a whole, and made a protectiveness determination for OU2. A FYR Addendum addressed the deferred protectiveness determinations; EPA signed the Addendum on November 27, 2012, and MPCA signed it on December 5, 2012. Table 1 reflects the most recent determination for each area, quoted from the 201 0 and 2012 documents.

Table 1: Protectiveness Determinations/Statements from 2010 FYR and 2012 Addendum

OU1, as determined in the 2012 FYR Addendum

rij~i~~m\~~i Short-term Protective

OU2, as Short-term determined Protective in the 2010 FYR

The remedy for OU1 currently protects human health and the environment in the short term because groundwater contaminant concentrations have declined below levels of concern for vapor intrusion and the contaminants are being captured and treated by the municipal water supply treatment system, use of groundwater is controlled by State statute and City management plans, and the Former EM Building is being operated with an effective air-exchange system. In order for the remedy to be protective in the long-term, the following actions need to be taken:

• Develop and implement an rc work plan that ensures that effective res are in place, includes long-term stewardship ofiCs, and considers residual soil contamination that may remain beneath the building;

• Develop a contingency plan to require the PRPs to contain and treat the groundwater plume in lieu of municipally-provided treatment;

• Conduct an investigation and feasibility study to determine whether additional remedial actions are necessary to achieve groundwater cleanup goals.

Long-term protectiveness also requires compliance with effective res. Compliance with effective res will be ensured through long-term stewardship by implementing, maintaining, and monitoring the res, as well as maintaining the Site remedy components.

The containment cell remedy is functi~ning as intended and is currently protective of human health and the environment in the short term. Long-term protectiveness requires maintenance of the remedy and compliance with the res. Compliance with res will be accomplished by ensuring effective res are in-place and by planning for long-term stewardship that includes maintaining, monitoring, and enforcing effective res as well as maintaining Site remedy components.

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Site-Wide, Short-term Because the remedial actions at all OUs are protective in the short term, the determined Protective Site is protective of human health and the environment in the short term. Long-in the 2012 term protectiveness for the Site will be achieved when the remaining ICs are in FYR place and groundwater cleanup goals are met. Addendum

Recommendations made in the last review are shown in Table 2. In the 20 I 0 FYR, MPCA and EPA made recommendations for QUI and QU2. In the 20I2 FYRAddendum, MPCA and EPA updated the recommendations for QUI and added several recommendations. Table 2 shows the most recent recommendations for each OU.

(see table on next page)

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Table 2: Status of Recommendations from the 2010 FYR and 2012 Addendum

Site- I Implementation ofiCs is Develop and implement an IC work wide incomplete and there are no plan for each OU that ensures effective

measures in place to monitor ICs are in place, includes long-term the effectiveness ofiCs stewardship ofiCs, and considers

I I I Implement

including restrictive covenants residual soil contamination that may by 05/27/15 and long-term stewardship of remain beneath buildings the Lack of contingency plan for Develop a contingency plan to require MPCA 05/27/15 Considered But Not NA

OU1 I plume containment the PRPs to contain and treat and EPA Implemented groundwater plume in lieu of municipally provided treatment

Uncertainty regarding ability Conduct additional investigation and MPCA 05/27/15 Addressed in Next INA OU1 I to reach groundwater cleanup feasibility study to determine whether and EPA FYR

goals additional remedial actions are necessary to achieve groundwater

)

OU2 I Residual soil contamination I Determine and implement a protective, PRP MPCA 12/2010 Considered But Not INA remains on the BN OU2 site long-term response action for site Implemented

contaminated soils including consideration ofiCs

OU2 I There are no measures in place I Develop and implement an IC Plan (see I PRP I MPCA 112/2011 I Ongoing INA to monitor the effectiveness of also Recommendation 8 from 3rd FYR) existing ICs including restrictive covenants as well as the long-term stewardship of the

The current status of each previous recommendation is described below.

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Recommendation 1: MPCA and EPA have conducted internal discussions regarding IC implementation and long-term stewardship, but additional work is needed. This is included.as a recommendation in Section V of the current FYR report.

Recommendation 2: MPCA has confirmed that the City of Waite Park does not foresee changing to a different source of drinking water. Furthermore, it is unclear whether the City wells' pumping is containing the plume, and reliance on them does not clearly satisfy the ROD's requirements. Both issues are included as recommendations in Section V of the current FYR report.

Recommendation 3: The issue regarding potential inability to meet groundwater cleanup goals is discussed in Section V of the current FYR report, along with a related issue regarding the presence of additional source materials at the Site.

Recommendation 4: The issue regarding residual soil contamination at OU2 was re-evaluated during the current FYR and is discussed further in Section III (Data Review) and Section IV (Question B) of this FYR report. The risk-based method for determining what soils to remediate remains protective. However, additional evaluation is needed to confirm that undeveloped parcels remain within the acceptable risk range for commercial/industrial use. A new recommendation regarding the reframed issue is included in. Section V of the current FYR report.

Recommendation 5: This recommendation regarding long-term ICs stewardship is included along with a broader recommendation concerning ICs in Section V of the current FYR report.

The 2010 FYR made additional recommendations related to O&M that were not considered to affect protectiveness. These additional recommendations and their current status are shown below:

• For the Waite Park water supply wells, three monitoring wells were reportedly transferred from BN to the City. Only one well was found during the Site inspection. The City has no records of transfer or abandonment. These wells should be found and properly abandoned.

Current Status: On October 10, 2011, a signed copy ofthe Transfer of Ownership letter documenting the transfer of monitoring wells MPCA-13D, MPCA-3D and ERT-26D from BN to the City was submitted to the MPCA. However, City staff remain unaware of these wells' current status, and MDH has no records for them. This issue is unlikely to affect current protectiveness, but may affect future protectiveness if the wells are not maintained or plugged. Therefore, this issue is included as a recommendation for OU2 in Section V of the current FYR report.

• Discrepancies exist in the OU1 Annual Monitoring Reports (AMRs) reporting of existing wells, abandoned wells, and well locations. These discrepancies should be resolved. In addition, the Site inspection revealed the presence of unmarked wells, including wells that were sheared off or otherwise improperly abandoned. These wells should be properly abandoned.

Current status: Monitoring wells were inspected for this FYR and found to be generally in good condition. However, the issue of unmarked or not properly abandoned wells remains an issue at OU1 and.is included as a recommendation in Section V of the current FYR report.

• There are minor containment cell maintenance issues in OU2, including: ruts from maintenance vehicles, small animal burrow holes, damage to fence poles from city stockpiling of tree and yard waste activities adjacent to the cell, potential for damage to monitoring well MW-28 form adjacent landowner activities, and no protective posts on monitoring well MW-33 that is adjacent to a roadway outside of containment cell fence. Related improvements should be made.

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Current status: O&M issues for the containment cell have been satisfactorily addressed.

The 2010 FYR also noted several unidentified stockpiles in River Bend Park (Area A of OU2). This area was inspected as part of this FYR, and the piles were addressed.

Remedy Implementation Activities

Remedy implementation activities during the period of the FYR consisted of continued cap maintenance of the on-site containment unit groundwater monitoring. In addition, the City has continued operating the City well system that is treating groundwater captured by the City well system. These activities are discussed further below.

Operation and Maintenance Activities

City Wells

The City follows an O&M plan for the water treatment plant. The City continues to collect quarterly water samples at three points in their treatment system (influent, after the air stripper, and after discharge to the distribution system [sample ports S-1, S-2, and S-3]). The quarterly analytical results are included in the OUl AMRs.

OUl

Routine groundwater monitoring is performed at select monitoring wells based on a schedule approved by MPCA staff. OUl Figures 1-2 identify the location of the monitoring points. Current monitoring includes:

• Collect groundwater elevation measurements from 12 groundwater monitoring wells (EM-4S, EM-8S, EM-9S, EM-lOS, EM-22D, EM-24D, EM-40S, EM-40D, NW-2D, and PW-1).

• Collect stabilization tests and groundwater samples from eight groundwater monitoring wells (EM-4S, EM-8S, EM-8D, EM-9S, EM-9M, EM-22D, EM-24D, and NW-2D). Analyze groundwater samples for VOCs.

OU2

O&M at the containment cell is performed in accordance with the January 1997 Contingency Action Plan and Post-Closure Monitoring Plan, and the MPCA approved modifications as specified in the AMRs. OU2 Figure 1 identifies the location of the containment cell and monitoring points.

Containment cell monitoring includes:

• Collect groundwater elevation measurements from groundwater monitoring wells MW-28, MW-33, MW-34, and NW-3S. Analyze groundwater samples for VOCs and total arsenic, cadmium, and lead (metals).

• Physical monitoring and maintenance of the ·containment cell. The physical condition of the containment cell, the fence, and the monitoring wells are checked quarterly, and the vegetative cover is mowed annually.

• Leachate discharge monitoring: The lysimeter is checked quarterly for the presence of leachate, and pumped quarterly for disposal. Annual grab sampling, per the Metropolitan Council Environmental Services (MCES) reissued Permit No. 2220, includes total metals, total mercury,

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TSS, COD, pH, and PFCs. Additional analysis for annual Containment Cell parameters includes Alkalinity, Ammonia as N, Chloride, Nitrate+Nitrite, and Sulfate.

Institutional Controls

ICs are required to restrict property use, maintain the integrity of the remedy, and assure the long-term protectiveness for areas that do not allow for UU/UE. A summary of the implemented and. planned ICs for the Site are discussed below.

The OU1 ROD did not require soil cleanup, but did require a deed notice to be placed on the property pursuant to Chapter 1158.16, Subd.2 of MERLA. This regulation requires recording of an affidavit regarding the location of hazardous substances at the property and that the use of the property may be restricted. The use of the property at the time of the ROD, and currently, is industrial.

The OU2 ROD selected cleanup levels based on residential use for one area (Area A, located west of 1oth A venue), and selected cleanup levels based on commercial/industrial uses for remaining areas (Areas B through H, located east of 1oth A venue). These areas are shown in Burlington Northern Figure 1. The current use of Area A is recreational. The current uses of the remaining areas include industrial, commercial, municipal water supply and treatment system uses, an on-site containment unit, and unused property. Currently, the Site is made up of 30 parcels (IC Figure 2). OU1 includes Parcels 23, 24, and 27 through 30. OU2 incudes Parcels 1 through 22, 25, and 26. Area A is one portion of Parcell.

ICs for the Site were evaluated by the MPCA in 2010 in a report entitled Institutional Controls Evaluation. The report identified ICs found when conducting title searches for the parcels of the Site, and makes recommendations concerning additional ICs and IC stewardship needs. The report is an attachment to the 2010 FYR for the Site and is available on the EPA's FYR website.

During this FYR, additional information regarding municipal water supply ordinances was obtained from the Cities of Waite Park and St. Cloud. The City of Waite Park Ordinance Code Section 43-Municipal Water System requires the owner of any building occupied within the City, except for singlefamily residential dwellings, shall connect the building to the City's public water system. The City of St. Cloud Ordinance Code Section 245 - Public Utilities Department requires all properties within the city limits connect to municipal utilities (sewer, water, stormwater, and electrical are treated as single utility); however, private wells that exist on the property are allowed for irrigation purposes but under no circumstances shall be cross-connected to the City system. Table 3 summarizes the ICs in place for the Site.

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fable 3: Institutional Controls Summary

Site-wide- Groundwater area that exceeds UU/UE (on-site and off-site)

OU1 (parcels 23, 24, 27-30) - Soils that exceed UU/UE

OU2 (parcels 1-22, 25, 26) - Soils that exceed UU/UE

None

Deed notice to be placed on the property pursuant to Ch. 115B.16, Subd.2 ofMERLA

Restrictions to be placed on any area that is not remediated to unrestricted land use remediation levels and on property containing the containment

The City of St. Cloud Ordinance Code Section 245 -Public Utilities Department requires all properties within the city limits to connect to municipal utilities (sewer, water, storm-water, and electrical are treated as a single utility); however, private wells that exist on the property are allowed for irrigation purposes, but under no circumstances shall be cross-connected to the City system. The City of Waite Park Ordinance Code Section 43-Municipal Water System requires the owner of any building occupied within the City, except for single family residential dwellings, to connect the building to the City's public water system.

Documents No.*: 669547 669548 669550 803666 813568 878751 1016329

review of all documents

Documents No.*: 602757 602758 685222 848214 848215 848216 845329 (Additional review of all documents planned)

*As identified in·the 2010 IC Evaluation, which includes copies of all documents and filing dates.

Current Compliance: No Site uses that are inconsistent with the remedy or IC objectives have been noted during the Site inspection.

Status ofiCs and Follow-Up Actions Required: IC evaluation activities conducted in the previous FYR indicated that additional review and updating is needed for many parcels. This continues to be the case. Many of the documents identified during title searches conducted for the 2010 IC review do not meet the requirements ofthe ROD. Additional review and implementation of additional ICs are needed.

Long-Term Stewardship: Long-term stewardship procedures need to be formally incorporated into Annual Report or O&M requirements to assure effective ICs, when they are in place, are properly

19

maintained, monitored, and enforced over the long-term. Long-term protectiveness requires compliance with effective ICs.

An Annual Report or O&M Report should be submitted to the MPCA to demonstrate that the Site was inspected to ensure no inconsistent uses have occurred; that ICs remain in place and are effective; and that any necessary contingency actions have been executed.

Redevelopment

MPCA manages redevelopment of the Site through the MPCA Superfund and Voluntary Investigation and Cleanup (VIC) Program. The following nine VIC sites are currently tracked by the MPCA. Table 4 summarizes information abounhe sites.

Table 4: MPCA VIC Program Sites

BN Car Shop Waite Park 21 SF Site- SR62 (OU2)

Waite Park Wells SF Site 23, 24, 27, 28, 29 & - SR35 30

Electric Machinery SF 1 & 21 Site- SR136 (OU1) .

BN- Waite Park Site #4 13 - VP6393

BN- Waite Park Site #3 20 - VP6392

BN- Waite Park Site #2. To be determined - VP6391

BN- Waite Park Site - 1 VP6390

River's Edge Park ID 1 - bike trail VP24840

Rejuv Medical VP30220 13

See IC Evaluation.

See IC Evaluation.

See IC Evaluation.

No-association lettera issued 7/26/05. Site closedb on 7/26/05.

No-association letter issued 2/23/05. Site closed on 3/3/07.

No-association letter issued 2/23/05. Site closed on 3/3/07.

No-association letters issued 5/12/97, 5/19/97 and 5/29/98. Off-site source letterc on 5/29/98. Certificate ofCompletiond issued 11/1/99, 9/28/02, and 12/21101. ·

Site closed on 3/3/07.

Construction Contingency Plane approval on 4/6/09.

Construction Contingency Plan approval on 6/4/13.

a No-association letter-- indicates MPCA's determination that the current user of the property is not a source of the historic contamination at the property. b Site closure-- indicates MPCA's determination that any additional remediation required to ensure safe use of the property has been completed. c Off-site source letter-- indicates MPCA's determination that groundwater contamination at the site is from an off-site source. ·

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d Certificate of Completion -- indicates MPCA' s determination that a phase of the required work has been completed.

Receptor Well Survey: A limited well receptor survey was performed for this FYR to check for groundwater wells near the Site. The survey identified three wells located within or near the Site (IC Figure 1 ). It'is not known whether these wells are in active use. Although the plume boundary is not entirely defined, Unique Well400535, an industrial use well, is almost certainly located outside the existing groundwater plume for the Site. Unique Well215297 is located on OU2, where groundwater is not significantly contaminated. Unique Well409988, a domestic use well, is located far south ofOU2, well outside the plume boundary. Table 5 shows information about the identified wells.

Table 5: Well Receptor Summary

400535 Schmidt Labs Industrial 55 ~ 900 feet northeast of OU1 monitoring Inc. wells NW2S&D

215297 Great Industrial 78 Located within OU2 Area B Northern R.R.

409988 Park Suites Domestic 25 ~2000 feet south of the OU2 on Second containment cell

III. FIVE-YEAR REVIEW PROCESS

Administrative Components

The Five-Year Review was initiated on January 28,2015, and led by Wayne Sarappo ofthe MPCA, Project Manager for the Site. The EM, BN, and City representatives were notified ofthe initiation of the Five-Year review during February 2015. The review consisted of the following components:

• Community involvement;

• Document review;

• Data review;

• ICs evaluation;

• Site inspection; and

• Five-Year Review Report development and review

Community Notification and Involvement

On February 11, 2015, a notice was published in the St. Cloud Times newspaper announcing that a FiveYear Review was being conducted for the Site. A copy ofthe public notice is presented in Attachment D. No comments or concerns were relayed to MPCA or EPA in response to the notice.

Document Review

This FYR consisted of a review of relevant documents, including O&M records and monitoring data. Documents reviewed are presented in Table 6:

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Table 6: Documents Reviewed

November 2008

3117/2010

2008 - Investigation and Groundwater Monitoring Report

2009 Annual Groundwater Monitoring Report -Addendum

Field investigation activities and annual groundwater monitoring at EM site (Barr 2008)

2009 City of Waite Park pumping and water quality data

1/2112011 2010 Annual Groundwater Monitoring Report Annual groundwater monitoring at EM r---~-----r-------------------------=--~----~

2117/2012 2011 Annual Groundwater Monitoring Report site and City of Waite Park pumping r-4/-3-0/_2_0_13 __ ----lr-2-0_1_2_A_n_n_u_a_l G--ro_u_n_d_w-at_e_r_M_o_n-it-o-ri-n=g-R-e"-p-ort----~ and water quality data

4116/2014 2013 Annual Groundwater Monitoring Report

April 2011 2010 Annual Containment Cell Monitoring Report Annual post-closure monitoring results r-~-------r----------------------------~~--~

March 2012 2011 Annual Containment Cell Monitoring Report -annual groundwater monitoring event, 1--A--p-ri-1 2_0_1_3---r2-0_1_3_A_n_n_u_a_l C--on_t_m_· n_m_e_n_t -C-el_l_M_o_n_it-o-ri-n=g-R-e"--p-ort----1 quarterly leachate discharge monitoring r-~-------r----------------------------~~--~ events, and Containment Cell inspection

January 2014 2013 Annual Containment Cell Monitoring Report and maintenance activities

,1989 ROD- Target cleanup levels listed in Table 4 were also reviewed. OU1

1994RODOU2

Data Review

Soil Remediation Levels listed in Table 1; Groundwater Monitoring Requirements listed in Table 2; and Treated Soil Remediation Levels listed in Table 4 were also reviewed.

As part of the data review process, reports prepared since the last FYR were reviewed by MPCA and EPA regarding the following topics.

City Wells

Review of OUI AMRs indicates that water samples collected from City well sampling port S-2, after the air stripping treatment, had no VOC detections above laboratory reporting limits. Trichloroethene (TCE) concentrations are below the reporting limit following treatment. The reporting limit for the TCE analysis method used is I.O flg/L, which is below the Maximum Contaminant Level (MCL) of 5 ug/L but slightly above the Health Based Value (HBV) of0.40 flg/L.

QUI - Groundwater

Groundwater monitoring well sampling is conducted annually at QUI. Contaminants currently detected in QUI groundwater include I,I-Dichloroethane, I,I-Dichlorothene, cis-I,2-Dichloroethene, tetrachloroethene (PCE), TCE, and trans-I,2-Dichloroethene. Of these, PCE and TCE exceed current MCLs or Health Risk Limits (HRLs). Although COC concentrations have decreased since the time of the ROD, PCE concentrations in the suspected source area (EM-9M) remain more than IOO times the MDH HRL of 5 flg/L. PCE and TCE concentrations in the downgradient wells EM-22D and NW-2D remain five times the MCLIHRL. TCE concentrations in EM-24, which is located north of the Site, remain I2 times the MCLIHRL. QUI Figures 4-II show contaminant trends in selected wells.

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In 2008, Barr completed additional groundwater sampling north of the Site to determine the extent of the chlorinated VOC plume in the lower aquifer. However, results were insufficient to fully define the plume in this area, rendering capture by City wells unascertainable.

Current groundwater cleanup standards, as of March 2015, and current maximum concentrations in groundwater are shown in Table 7 below:

Table 7: Groundwater Cleanup Levels

Trichloroehene (TCE) 5 (MCL)

1,1,1-Trichloroethane (1,1,1-TCA) 200 (MCL, RAL)

1,2-Dichloroethene (1,2-DCE) 70 (RAL)

1,2-Dichloroethane

Bold text indicates concentration exceeds current groundwater cleanup standards. * MDH reduced the HBV for TCE in 2013. **Listed on Table 1 of ROD, bu(not included on Table 4 of the ROD; no site target cleanup level listed.

OU1- Vapor

In 2008, Barr completed a soil vapor assessment near the former SVE well EM-9S, which is the suspected worst case area. PCE and TCE concentrations exceeded 100 times the MPCA Industrial Intrusion Screening Value (ISV) in nearly all samples and, in some cases, the Acute ISV s were exceeded. In 2012, the MPCA obtained additional information concerning the air exchange operations in the Former EM Building. MPCA and EPA's review for the 2012 FYR Addendum indicated that the air exchange system, when operating, is sufficient and protective of workers at the facility. The risk these soil-gas concentrations pose to receptors surrounding the Former EM Building, especially a CentraCare medical facility directly north of this building, needs to be evaluated in accordance with current MPCA vapor intrusion guidance.

Additional investigation consisting of soil-gas sampling, sub-slab sampling, and other lines of evidence following the MPCA September 2008 Risk-Based Guidance for the Vapor Intrusion Pathway, the MPCA 2015 Vapor Intrusion Mitigation Best Management Practices, and the EPA November 2002 OSWER Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils should be conducted to adequately evaluate the vapor intrusion risk to potential receptors.

23

Current MPCA vapor intrusion standards, as of March 2015, are shown in Table 8 below.

Table 8: Vapor Intrusion Standards

OU1- Soils

The OU1 ROD did not require action for soils. In 1999, the PRP re-investigated soil contamination at the property and subsequently conducted a soil removal action and operated a pilot-scale SVE system to treat soil in one area for two years. These historical activities are summarized in Appendix A of this FYR. The 2010 FYR recommended further investigation, which did not occur, and this issue is also addressed in the recommendations section of this FYR.

As part of the data review process, reports prepared since the last FYR were reviewed by MPCA regarding the following topics.

OU2- Containment Cell

The containment cell groundwater and leachate monitoring program is functioning as designed, and leachate from, the containment cell is not impacting the underlying groundwater. VOCs were not detected in groundwater monitoring, and the analysis method used is adequate to detect any contaminants that exceed current drinking water standards. Leachate monitoring did not exceed discharge permit limits for disposal. Quarterly site inspections indicated no significant concerns with the physical integrity of the containment cell.

OU2- Groundwater

The OU2 ROD selected groundwater monitoring. Monitoring continued until approximately 1998, when MPCA approved discontinuation of monitoring and sealing of the wells. The 1998 AMR included groundwater results for VOCs, PARs, PCBs, and select metals (arsenic, cadmium, and lead). Significant attenuation of any remaining groundwater contaminants is very likely to have occurred in the 17 years since that time; however, for this FYR, these 1998 results are compared to current drinking water standards to ensure that the groundwater remedy remains protective:

• P AHs: In 1998, P AHs were detected in one well at a concentration far below current drinking water standards (a comparison was made to MCLs, HRLs, and HBVs).

• Arsenic: In 1998, arsenic at concentrations up to 9 ug/L were found in several wells. The maximum concentration is below the current MCL of 10 ug/L. (MDH has not established a separate drinking water standard for arsenic and recommends use of the federal level.)

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• Cadmium: In 1998, cadmium was detected at a concentration of0.3 ug/L in one well. This is below current drinking water standards (MCL is 5 ug/L; HRL, 4 ug/L; HBV, 0.5 ug/L)

• Lead: In.1998, lead was detected in two wells at concentrations up to 10 ug/L. This is below current drinking water standards (EPA action level and MDH guideline are both 15 ug/L).

• PCBs: In 1998, PCBs were detected in several wells. All but one were below current drinking water standards. At one well (Well MPCA-14S, located on the northern edge of Area B) the concentration of 0.13 ug/L was below the current M CL of 0.5 ug/L but above the HRL of 0.04 ug/L.

• VOCs: In 1998, VOCs were detected at levels that exceeded drinking water standards in three wells. A comparison to current drinking water standards was not made for this FYR because these wells are all located downgradient of the known source ofVOCs in OUl. However, it is noted that in 1998, groundwater flow 'was to the north, not eastward toward the City wells as it is today.

As a result of this review, this FYR adds the recommendation that the PRP ~ample OU2 groundwater near or downgradient of former monitoring well MPCA-14S to confirm that it meets current HRLs for PCBs. It is possible that the existing monitoring wells of the down-gradient containment facility could be used for this purpose. Groundwater is very likely to meet current HRLs due to attenuation since the 1998 sampling, but should be confirmed.

OU2- Soils

Table 1 of the OU2 ROD established cleanup levels for metals and polycyclic aromatic hydrocarbons (PAHs) in soil. These levels were superseded when the remedy was modified in the ESD. The ESD specified use of a risk-based methodology for establishing soil cleanup levels. This risk-based method remains protective; however, the PRP should confirm that undeveloped parcels remain within the acceptable ris!.<: range for commercial/industrial use, as specified in the ROD. This issue is discussed further under Part IV (Question B) of this FYR.

Site Inspection

The Site inspection was conducted on February 17, 2015. In attendance were WayneSarappo (MPCA), Leah Evison (EPA), Laura Salmonson, Ryan Riley, and Donovan Hannu (Bay West), Kurt Geiser (AECOM), Sandra Moore (BNSF), and Mark Ciampone (Braun). Photographs taken during Site Inspections that highlight the issues noted below are located in Appendix B.

OU1

The Site inspection included a walk-through of the Site, a visual inspection ofthe monitoring wells and surrounding properties, and a visual inspection of current soil excavation activities associated with an on-site building expansion project. According to the AMR figures, 17 monitoring wells are located on the Site and adjacent properties. Bay West located 16 ofthe 17 monitoring wells; a summary ofthe wells is provided in Table 9 below.

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Table 9. Monitoring Well Inspection Results

Good condition, listed as active but not

EM20S NA NA Not Located, listed on as active well.

EM20D y y

EM40D Y Y Good condition, listed as active but not

NA: Not Applicable. Gray shading indicates that wells are currently sampled on an annual basis.

Other inspection observations include the following:

• The aerial photographs'used in the AMRs are not representative of current property uses. These figures shouldbe updated.

This issue does not affect protectiveness but has been added to Section V of this FYR.

• Several buildings were identified in the area surrounding the Former EM Building, including a CentraCare medical facility directly north of the Former EM Building. These buildings represent potential vapor intrusion receptors.

This issue may affect protectiveness and is included in Section V of this FYR.

• A fire station is now located approximately 0.16 miles north of the Site. An apparently unused well was noted on the property. This well did not show up on the limited receptor survey conducted for this FYR and it is not known whether it has been properly abandoned.

This issue is included in Section V of this FYR.

• A water tower for the City of St. Cloud was observed 0.45 miles northwest of the Site. The City of St. Cloud obtains its public water supply from the Mississippi River. The potential risk of contaminated groundwater being discharged into the Sauk River, whicli is a tributary to the Mississippi River, should be assessed.

This issue is not likely to affect current protectiveness because of the high flows in the river in comparison to the low gradients of potential groundwater flow to the river. However, it should be evaluated and is included in Section V of this FYR.

26

• Soil removal activities were in process during the Site visit.

This issue was resolved during the FYR, as explained below.

In a letter dated 11/19/2014, the MPCA approved the excavation of soils for strip footings as part of a building expansion project and agreed that the excavated soils did not need to be sampled because they have similar soil characteristics previously detected in a 1997 soil excavation. The proposed plan included keeping the soils excavated from the footings on-site, and either thin spreading them in the southern portion of the site or stockpiling them. During the Site visit, a stockpile that likely exceeded 800 cubic yards (yd3

) was observed and the excavation appeared to have been undertaken for purposes beyond the placement of footings (see Appendix B Photo #4). The MPCA requested that Grede submit a letter stating the intent for soil testing and disposal. Grede submitted a letter dated February 19, 2015, requesting approval to reuse the soil on the north side of the property by building a berm three to 6 feet high and planting trees. They also stated that during the deeper excavation activities, Braun Engineering was on-site to assist with judgment and structural soil testing, and no visual soil contamination was observed. The MPCA approval letter dated April 15, 2015, approved the soil removal and relocation. The MPCA staff agreed that the excavated/stockpiled soils removed could be placed on the north side of the property as a berm, and that upon completion of the berm construction, a map of the berm area, as well as the total number of cubic yards of soil placed in the berm, should be submitted to the MPCA.

OU2 The Site inspection included a walk-through of the containment cell, a review of the monitoring well locations, and a visual review of the remainder of OU2.

Containment Cell (Area F)- The containment cell is fenced with a locked gate on the west side of 4th A venue North. The fencing and gate were in good condition and "Danger Keep Out" signage was placed by the gate. The sump, lysimeter, passive vents, and four monitoring wells were all in good condition. Protective poles have been installed around MW-33, and the previous yard waste stockpiles encroaching MW -28 have been removed. The only action item identified was the need to hand trim the tall grass in the rip rap drainage areas (see Appendix B Photo# 13 and 15).

Area E- The City of Waite Park utilizes this parcel for a compost collection site, and it also contains a· soil containment cell that was formed during the construction of Waite Ave North and the new driveway to the current treatment facility (see Appendix B Photo #18 and 19). The containment cell inside the fenced area was identified during the 2008 Site visit. The vegetation appeared to be overgrown and sucker trees were observed. This cell was a result of work performed under the MPCA VIC activities. A second containment cell, previously identified outside the fence on the east side of Waite Ave North, was not identified during the Site visit.

River Bend Park (Area A)- The unidentified stockpiles observed during the Site visit in 2008 have been removed. No debris (such as roofing material, broken concrete, railroad basalt, trash, scrap metal, or other debris) was observed. Some grass sod waste was identified in this area (see Appendix B Photo #23 and 24).

Interviews

During the FYR process, interviews were conducted with interested parties impacted by the Site and regulatory agencies involved, in Site activities or aware ofthe Site. The purpose of these interviews was to document any perceived problems or successes with the remedy that has been implemented to date.

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Interviews were conducted between March 1, 2015, and March 5, 2015. Interviews are summarized in Table 1 0; documentation of the complete interviews is included in Appendix C.

Table 10: Interview Summary

:~lfnt~~J~W~~·;~1:~;~:~ Kim Larsen

Bill Schluenz

District Engineer, . MDH

Public Works Director, City of Waite Park

3/3/2015

3/4/2015

IV. TECHNICAL ASSESSMENT

• General sentiment: From her perspective, the project has been successful thus far. The treatment plant performs as expected, and all water sample results from the plant effluent from the last 10 years are absent of all detection ofEPA-regulated VOCs.

• Ms. Larsen maintains a good working relationship with all staff members.

• General sentiment: From his perspective, the project and Site have been well run, with no issues thus far.

• Mr. Schluenz was well-informed about the Site's activities and progress.

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

OU1 Assessment by MPCA and EPA

No.

The OU1 ROD required an on-site groundwater pump and treat remedy to be operated for the shallow and deep aquifers until cleanup levels were reached, and required that contaminants outside the zone of remediation of the Site would be treated by the municipal water supply system air stripper. On-site groundwater pumping was performed for over 10 years from two wells in the shallow aquifer (PW -1 and PW-2). A third well (PW-3) was installed in the deep aquifer, but never used. The 2000 FYR conducted for the Site indicated that the deep aquifer well was not used because City wells were capturing and treating the deep aquifer plume. Groundwater pumping from the shallow aquifer was discontinued in April 2001 as part of a test shutdown and has not been restarted, despite exceeding cleanup levels. The City municipal well treatment system captures and treats groundwater from the Site, but the horizontal and vertical extent of the shallow and deep groundwater plumes, which previously would have flowed to the north under non-pumping conditions, are inadequately defined north of OU1. Therefore, it cannot be determined whether the municipal well pumping system is capturing the entire plumes. Also, the on-site groundwater pump and treat system's performance while it was operating indicates that it was unlikely to achieve the cleanup standards in the ROD, as documented in the previous FYR.

Soil-gas sampling conducted in 2008 indicates that additional soil contamination may exist either near or beneath the Former EM Building. Additional investigation and/or feasibility study activities are necessary to determine if the remedy selected in the ROD or the remedy as currently implemented will achieve groundwater cleanup goals.

Property uses appear consistent with the ROD, but review of ICs indicates that the deed restrictions required in the ROD are not in place at all parcels.

28

OU2 Assessment by MPCA

Yes.

The on-site containment cell, leachate collection system, and containment cell groundwater monitoring system are functioning as intended.

Land use is consistent with the ROD, but deed restrictions were to be placed on any area that was not remediated to unrestricted land use remediation levels, and review of ICs indicates that has not occurred for all parcels. In addition, long-term stewardship· procedures are not in' place for those ICs that are in place. ·

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

OU1 Assessment by MPCA and EPA

Yes.

Exposure assumptions and RAOs are still valid. The OU1 ROD required groundwater to be cleaned up to MCLs and RALs. Currently, promulgated HRLs have replaced most RALs. Many drinking water standards have changed since the time of the ROD, but in the AMRs, groundwater concentrations are qompared to current drinking water standards. Results are discussed in the Data Review section of this FYR.


Yes.

Exposure assumptions and RAOs are still valid. Table 1 of the OU2 ROD established cleanup levels for metals and PAHs in soil. These levels were superseded when the remedy was modified in the ESD. The ESD specified vse of a risk-based methodology for establishing soil cleanup levels. Since the time of the ROD, some parcels have been redeveloped in coordination with MPCA. However, for undeveloped properties it is unclear whether the risk-based standards for industrial/commercial exposure used at the time of remedy implementation remain protective, i.e., remain within or below the 1 o-4 to 1 o-6 cancer risk range and remain below a Hazard Index of 1 for non-cancer risk. These undeveloped properties are not currently used and are unlikely to present a current risk to trespassers or occasional passers-by. However, the OU2 PRP should review existing data or collect new data if needed to confirm that undeveloped parcels remain within the acceptable risk range for commercial/industrial use as specified in the ROD.

The OU2 ROD required monitoring of groundwater for a variety of contaminants. With the exception of monitoring related to the containment unit, MPCA approved discontinuation of monitoring in approximately 1998. Those data demonstrate that groundwater was below current drinking water standards with the exception ofVOCs at locations east ofOU1 (a known source ofVOCs) and PCBs at one location. Attenuation since 1998 is very likely to have lowered the PCB concentration below current . drinking water standards; however, this should be confirmed.

29

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

OUl Assessment by MPCA and EPA

Yes.

The potential risks posed by the intrusion of vapors from contaminated soil or groundwater into buildings were not being evaluated at the time the ROD was implemented. The vapor intrusion pathway was evaluated for the Former EM Building in the 2012 FYR Addendum; however, the risk to other surrounding buildings has not been fully evaluated, including buildings that overlie areas where the plume is not fully defined. Additional vapor risk evaluation should be performed. At a minimum, additional soil-gas or sub-slab vapor sampling in each direction, along with Indoor Air Building Surveys, are required to further evaluate the risk to the surrounding potential receptors. First priority should be placed on buildings related to sensitive individuals such as those in ill health, the elderly or children.


No. No other information has come to light that could call into question the protectiveness of the remedy.

Technical Assessment Summary

At QUI, the treatment of groundwater for the City drinking water wells, and monitoring of groundwater and treated water are functioning as intended in the ROD; however, the groundwater pump and treat system at the source area is not in operation as the ROD requires. The MPCA approved a temporary shut-down in 2001 when contaminant concentrations stabilized above the cleanup standards, and the system remains shut down. Since that time, it is likely that most of the contaminant plume is being captured by pumping at the City wells and is being treated prior to use. The location of plume remnants north of the source area remain insufficiently defined. In addition, the vapor intrusion pathway has not been evaluated for occupied buildings overlying the plume other than the Former EM Building, and should be completed as soon as possible. Land uses appear consistent with the ROD; however, sufficient ICs are not in place and long.-stewardship ofiCs is not assured.

At OU2, contaihment of materials in the on-site cell and monitoring of leachate and groundwater associated with the cell are functioning as intended. Land uses appear consistent with the ROD, but the ICs currently in place are insufficient to ensure long-term protectiveness, and long-stewardship of the existing ICs is not assured. It is unclear whether risk-based standards used for some parcels used at the time of remedy implementation remain protective for undeveloped properties, however these undeveloped properties are not currently used and are unlikely to present a current risk to trespassers or occasional passers-by. In addition, the concentration ofPCBs in groundwater at one location should be confirmed, however it is very likely that attenuation has been occurring and PCB levels will be below current drinking water standards.

30

V. Issues/Recommendations and Follow-Up Actions

Table 11: MPCA and EPA Issues and Recommendations for OU1

Vapor intrusion Complete evaluation

risk has not been Evaluate the vapor 3/30/2016 assessed for off- intrusion pathway for

OU1 site buildings that all buildings that OUl PRPs

MPCAand Complete Unknown y may overlie the overlie the plume EPA remedial contaminated and conduct remedial actions if groundwater actions as needed. needed plume. 3/30/2017

The extent and magnitude of Define the extent and contaminated magnitude of groundwater in the contaminated shallow and deep groundwater in the aquifers is unclear shallow and deep

MPCAand OU1 north of the site, aquifers north of the OU1 PRPs

EPA 5/30/2016 N y

and it is unclear site, and demonstrate whether the entire its capture. Include plume is being an evaluation of any captured and continuing flow to treated by the City the Sauk River. wells.

On-site Re-start the on-site

groundwater pump and treat

remains above OU1 cleanup levels, and

system or modify the MPCA EPA 12/30/2016 N y

ROD to select an the on-site pump

alternative remedy and treat system is

for groundwater. shutdown.

31

Table 11: MPCA and EPA Issues and Recommendations for OUl

Groundwater and soil gas data indicate the Assess the extent and presence of magnitude of additional source additional source areas near or areas and evaluate

MPCAand OU1 beneath the Former whether source OU1 PRPs 12/30/2016 N y EM Building that control actions are

EPA

may prevent necessary to achieve groundwater from groundwater cleanup reaching goals. groundwater cleanup goals.

There are Review for presence unmarked wells at

the site that may of improperly MPCAand OU1

not have been abandoned wells and OU1 PRPs EPA

5/30/2016 N y

properly take action as

abandoned. needed.

Develop and Implementation of implement an IC ICs is incomplete, work plan for OUl

OU1 and there are no that ensures that OUl PRPs

MPCAand 5/30/2017 N y measures in place effective ICs are in EPA for long-term place and includes stewardship of ICs. long-term

stewardship of ICs.

An additional recommendation that does not affect protectiveness is noted below:

• The aerial photographs used in the OUl AMRs are not representative of current property uses. The OUl PRP should update the figures in the next AMR.

32

The following table lists issues and recommendations made by MPCA following review of OU2:

Table 12: MPCA Issues and Recommendations for OU2

Standards for Confirm that

commercial/ undeveloped parcels

OU2 industrial use have remain within the

OU2PRP MPCA 5/30/2016 N y

changed since the acceptable risk range for commercial/

time of the ROD. industrial use.

Groundwater Confirm that

exceeded drinking groundwater

water standards for PCBs in one

downgradient of

OU2 monitoring well at former monitoring

OU2PRP MPCA 7/30/2015 N y well MPCA-148

the time meets current Health

monitoring was Risk Limits for

discontinued and PCBs.

wells were sealed.

It is unclear whether former

Ensure that monitoring wells

monitoring wells MPCA-13D,

OU2 MPCA-3D and MPCA-13D, MPCA-

City MPCA 5/30/2016 N y 3D and ERT -26D, if

ERT-26D, that are not needed, are

owned by the City, properly abandoned.

have been properly abandoned.

Develop and Implementation of implement an IC ICs is incomplete, work plan for OU2

OU2 and there are no that ensures that OU2PRP MPCA 5/30/2017 N y

measures in place effective ICs are in for long-term place and includes stewardship of ICs. long-term

stewardship of ICs.

33

VI. Protectiveness Statements

MPCA and EPA make the following protectiveness statement for OUl:


Protectiveness Determination: Protectiveness Deferred

Operable Unit: OU1

Addendum Due Date: 5/30/2017


A protectiveness determination for the OU1 remedy cannot be made until further information is obtained by taking the following action:


It is expected that it will take approximately 10 months to complete the investigation and an additional12 months to complete the remedial actions that may be needed. When remedial actions are completed, a protectiveness determination will be made. In addition, in order for the remedy to be protective in the longterm, the following actions need to be taken to ensure protectiveness:

• Define the extent and magnitude of contaminated groundwater in the shallow and deep aquifers north of the site, and demonstrate its capture. Include an evaluation of any continuing flow to the Sauk River.

· • Require re-start of the on-site pump and treat system or modify the ROD to select an alternative remedy for groundwater.

• Assess the extent and magnitude of additional source areas and evaluate whether source control actions are necessary to achieve groundwater cleanup goals.

• Review for presence of improperly abandoned wells and take action as needed.


Long-term protectiveness also requires compliance with effective ICs. Compliance with effective ICs will be ensured through long-term stewardship by implementing, maintaining and monitoring the ICs as well as maintaining the Site remedy components.

34

MPCA makes the following protectiveness statement for OU2:


Operable Unit: Protectiveness Determination: OU2 Short-term Protective


The· OU2 remedy currently protects human health and the environment due to completed response activities, including removal of sandblast sands, contaminated soils, and storage tanks, and on-site containment of thermally treated wastes; however, in order for the remedy to be protective in the long-term, the following actions need to be taken to ensure protectiveness:

• Confirm that undeveloped parcels remain within the acceptable risk range for commercial/ industrial use.

• Confirm that groundwater downgradient of former monitoring well MPCA-14S meets current Health Risk Limits for PCBs.


Long-term protectiveness also requires maintenance of the remedy and compliance with effective ICs. Compliance with effective ICs will be ensured through long-term stewardship by implementing, maintaining and monitoring the ICs as well as maintaining the Site remedy components.

MPCA and EPA make the following joint Site-wide protectiveness statement:

35

Site-Wide Protectiveness Statement

Operable Unit: Protectiveness Determination: Addendum Due Date: 5/30/2017

NA Protectiveness Deferred


A protectiveness determination for the Site cannot be made until further information is obtained at OUl. Further information will be obtained by taking the following action:

• Evaluate the vapor intrusion pathway for all buildings not yet assessed that overlie the plume and conduct remedial actions as needed.

In addition, in order for the Site-wide remedy to be protective in the long-term, the following actions need to be taken to ensure protectiveness:

• Define the extent and magnitude of contaminated groundwater in the shallow and deep aquifers north of OUl, and demonstrate its capture. Include an evaluation of any continuing flow to the Sauk River.

• Require re-start of the on-site pump and treat system or modify the OUl ROD to select an alternative remedy for groundwater.

• Assess the extent and magnitude of additional source areas and evaluate whether source control actions are necessary to achieve groundwater cleanup goals at OUl.

• Review OUl for presence of improperly abandoned wells and take action as needed .

• • Develop and implement an re work plan for OUl that ensures that effective res are in place and

includes long-term stewardship of res; and

• Implement additional recommendations developed by MPeA for OU2.

Long-term protectiveness also requires compliance with effective res. Compliance with effective res will be ensured through long-term stewardship by implementing, maintaining and monitoring the res as well as maintaining the Site remedy components.

VII. Next Review

A FYR Addendum will be prepared for this Site by 5/30/2017. The next FYR report for the Site is required five years fromthe completion date of this review.

36

Figure 1

Site Location Map

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A

Appendix A

Existing Site Information

APPENDIX A- EXISTING SITE INFORMATION

A. SITE CHRONOLOGY

9/30/1986

2119/1988

1

;/ra;Bl~7)iJ:fehA:~1()Iof!tlftisite~~~fi~?,+·;I·•·• .~t··ii~l!~;;;·:" .. ~t~l;;f~tf..Si'· >il!fl~ ,~r~;·v~· ~ ,~:cr;;r•'> .•. \1!lif:'t' 1999 Soil contaminated with cosmo line and VOCs excavated near location of monitoring

well EM-35S at OU1 1111999- Dewatering sump installed at OU1soil excavation location with discharge to air 4/2001 stripg_er; operated until the shutdown of groundwater remediation system 1999-2002 Lead-contaminated soil from OU2 excavated, stabilized and disposed of at an off-site

landfill 2/2000 Second FYR completed 2000-2002 Pilot SVE system installed and operated near monitoring well EM-9S at OU1 2001 City prepared and implemented a Wellhead Protection Plan 5/2002 Municipal Well #5 and the new City water supply treatment building were brought into

service 2002 OU1 SVE system shut down after the system reached asymptotic levels of contaminant

withdrawal 7/2/2002 OU2 delisted from the PLP with all RA completed 6/112005 Third FYR completed 11/2008 OU1 PRP conducted soil-gas sampling near the Grede Foundries building and

conducted off-site groundwater investigation northeast of the site 2110/2010 Site-wide IC Evaluation completed 5/27/2010 Fourth FYR completed 11/7/2012 MPCA and EPA conducted site visit to confirm air exchange system at the Grede

Foundries building 12/5/12 MPCA and EPA completed FYR Addendum Ongoing OU2 containment cell O&M, including groundwater monitoring and submittal of

AMR.s Ongoing OU1 groundwater monitoring and submittal of AMR.s Ongoing City of Waite Park municipal well pumping, treatment, monitoring, and submittal of

results for reporting in the OU1AMR.s

B. BACKGROUND

General

The Site is listed on the NPL and consists of the City of Waite Park (City) well field area and two adjacent properties thought to be the source of groundwater contamination in City wells: Electric Machinery Co., located in the adjacent City of St. Cloud, and Burlington Northern Car Shop, located in the City. These two potential source areas are tracked by the EPA as OU1 and OU2 of the Site. MPCA lists the Site as three separate sites on the PLP. The PRPs for OU1 are the Electric Machinery Manufacturing Company, Cooper Industries. Inc., Brown Boveri & Company Ltd. and Dresser Industries, Inc. BNSF Railway Company is the PRP for the OU2. EPA has deferred enforcement for the Site to the MPCA under the Enforcement Deferral Pilot Project.

The Waite Park Wells (WPW) State Superfund site consists of the City municipal drinking water wells. The EM State Superfund site (OU1 of the Site), a 45-acre parcel ofland, is directly north ofOU2 and is within the City of St. Cloud. The BN State Superfund site (OU2 ofthe Site), a 202-acre parcel ofland, is within the City of Waite Park. The City of Waite Park has a population of 6,664 (20 13 ). The City of St. Cloud has a population of 66,297 (20 13 ).

2

Site Geology

The general geology in the vicinity of the Site consists of surficial outwash and alluvial deposits underlain by fine-grained glaciolacustrine sediment, till and buried outwash. Up to 135 feet of these sediments have been found to be deposited on top of Precambrian granite bedrock in the vicinity of the Site. The surficial outwash forms a shallow water table aquifer beneath most of the Site and the surrounding area. The shallow aquifer is generally separated from a deeper buried outwash aquifer by fine-grained glaciolacustrine and till units. The deeper aquifer beneath the Site rests on a fine-grained, sandy clay till. The till may rest directly on the bedrock in places, although a thin zone of sand may separate the lower till from bedrock. The granite bedrock is not considered an aquifer. Both the surficial and buried outwash aquifers appear to discharge to the Sauk River. Groundwater flow is generally to the north under non-pumping conditions in the shallow and deep aquifers.

Land and Resource Use

At the time of discovery of contamination, two City water supply wells were located on OU2, and both OU1 and OU2 properties were used for industrial purposes. Except for the park on the west, most of the Site has vegetation typical of commercial areas. The Sauk River is on the western boundary and is the most environmentally sensitive feature of the Site. Additional details on the land use of each area are summarized below.

Waite Park Wells

The best groundwater production area in the City is located at the eastern end of OU2 and this ~~t well field continues to be developed over time. Currently, the City well field consists of four

water supply wells (Wells 1, 3, 4, and 5). The City well field and water treatment building are located within the boundaries of OU2 and approximately 1/3 mile to the southeast of OU1. In 2002, the City completed the construction of a new water treatment plant. In addition, in 2009, the City completed the construction of Waite Avenue North, connecting 3rd Street North to 8th Street North. The access road to the water treatment plant is now off of Waite Avenue North. As part of the construction of the new treatment plant and Waite Avenue North, several containment cells/berms were also constructed to contain impacted or potentially impacted soil from former BN operations.

In 2001, a "Wellhead Protection Area and Drinking Water Supply Management Area Delineations and Vulnerability Assessments" report was prepared by Short Elliott Hendrickson, Inc. (SEH) for the City. In the report, Wellhead Protection Areas (WHPAs) and Drinking Water Supply Management Areas (DWSMAs) were delineated by SEH for all four existing municipal wells. The Minnesota Department of Health (MDH) defines the WHPA and the capture zone for a well. Using groundwater modeling software, SEH calculated 1-year, 5-year and 10-year WHPAs for the Waite Park municipal wells. Data from the report indicates that OU1 is located within the 1-year, 5-year, and 10-year WHPAs for Waite Park municipal wells 1, 3, 4, and 5. OU1 is also situated within the DWSMA for the one-year WHPA. These studies indicate that the contaminant plume at the EM site is being captured by the current Waite Park municipal wells.

3

The 1989 OU1 ROD indicated that the use ofthe land surrounding the OU was light industrial and warehousing. Currently OU1 is used for industrial purposes and is surrounded primarily by industrial and commercial properties.

In 1986, BN deeded a majority of the land to the City, including the land with the municipal wells and treatment building. The 1995 OU2 ROD stated that the area in and around BN included a mixture of light industrial, commercial, water utility, recreational, and residential uses. The easternmost portion ofthe City property is vacant land, with Waite Avenue North and a highway overpass further to the east. The City developed a ball park on the portion of the BN site located betweenlOth Avenue and the Sauk River. The City has sold some of the property, which is used for industrial and commercial purposes. A portion of the property sold was developed as the West River Business Park. BN currently owns 44 acres located toward the eastern half of the site.

The property currently owned by BN is located east of 5th Street and includes the soil containment cell, several buildings that are leased to a third party, and vacant land. There are commercial properties and residences to the south of OU2, along the south side of 3rd Street, and residential areas located north and south of the ball park.

History of Contamination

The original City wells were drilled in 1963 and 1974. In 1984, the MDH began requiring cities to analyze water supplies and, in December 1984, VOCs were detected in the City well water.

From 1969 to 1977, EM owned and operated a gas turbine and electric generator manufacturing facility in St. Cloud. Waste solvents generated at the facility were discharged into the soil and groundwater from a paint booth sump in the building at the EM site. Waste solvent was also released at an unregulated pit in the southwest portion of the EM site.

BN began operations in Waite Park in 1894. The operation included construction and repair of railroad freight, tank, and hopper cars in a car shop. From 1950 to 1970, approximately 10,000 gallons annually of waste oil, paint waste, and solvents were disposed of at the railroad yard by landfilling and/or evaporation.

Initial Response Pre-Record of Decision

Waite Park Wells

In December 1984, VOCs including TCE, PCE and DCA were detected in the City water supply wells. On January 28, 1985, the MDH informed the MPCA staff that the City was being advised to discontinue use of its water supply as soon as possible due to unacceptable levels of hazardous substances in the drinking water. On the same day, the MPCA issued a Determination of Emergency, allowing access to State Superfund funding under MERLA, Minn. Stat. ch. 115B, to provide City residents with a short-term safe drinking water supply and to undertake an RifFS to determine the appropriate long-term drinking water alternative. Nearby St. Cloud businesses were provided safe drinking water until an emergency connection between the Waite Park and the St. Cloud water systems was completed on February 4, 1985. Safe drinking water was

4

provided until the long-term water supply system was constructed in Waite Park. An FS was completed in March 1986 to determine the appropriate long-term drinking water alternative and a remedy was selected. During September 1986, the MPCA approved an RA that consisted of installation of a packed tower aeration system (air stripper) to remove the VOC contaminants from the water supply prior to consumption. BN and EM site RPs jointly funded and implemented the water treatment system. The City water supply wells were placed back into seryice in February 1988. The City took over O&M of the treatment system after construction.

On June 10, 1986, the Site was placed on the EPA's NPL. In 1986, the WPW, BN and EM sites were listed separately on the state ofMinnesota's PLP, each with a score of38. The EPA tracks the EM site as OU1 and the BN site as OU2 of the Site. This nomenclature is used in the remainder of this Appendix.

On October 22, 1985, the MPCA issued a RFRA to BN for OU2, citing the BN site as a source of contamination to the City's water wells. On March 25, 1986, and September 26, 1986, the MPCA issued RFRAs to Brown Boveri & Company Ltd., Cooper Industries, Inc., Dresser Industries, Inc., and Electric Machinery Manufacturing for OUl. The RFRAs also cited EM as a source of contamination to the City's wells. The RFRAs requested both BN and the RPs for OU1 to conduct a RI/FS and implement a RD/RA plan for a long-term water supply treatment system for the City. The RFRAs also req11ested that OU1 and OU2 RPs conduct an RI/FS and implement an RD/RA to address the contamination in their respective areas.

The initial groundwater assessment determined a layer of glacial till separates an upper sand and · gravel unit from a lower sand and gravel unit across portions ofOUI. Both units are waterbearing aquifers. The glacial till forms the base of the upper aquifer and generally acts as an aquitard, which limits flow of groundwater and contaminants into the underlying aquifer. In the southeast part of 0 U 1, the glacial till is absent and the upper and lower aquifers are in contact (a window). This allows contaminants that were released to the upper aquifer to migrate from the upper to the lower aquifer. Pumping of the municipal wells influences groundwater flow in both the upper and the lower aquifers due to the connection between the two aquifers, resulting in flow from OU1 to the south and east towards the window, and then flow is east in the lower aquifer toward the municipal wells. On the southern side of OUl, groundwater in the upper aquifer generally flows north under non-pumping conditions, towards OU1 and the area where the glacial till is absent. Under non-pumping conditions groundwater flows toward the northwest, north, and northeast, to the Sauk River.

Laboratory analysis detected several VOCs in water samples collected from the City water supply system during the initial assessment, including TCE, PCE, and DCA. Analysis of the groundwater samples collected during the remedial investigation for OU1 identified several VOCs in the shallow and deep aquifers both on and off OU1. The contaminant with the highest on-site concentration, as presented in the ROD for OU1, was PCE, although TCE, TCA and DCE were also present at significant concentrations. PCE was detected on-site in the shallow aquifer at concentrations as high as 34,000 !J.g/L. The deeper aquifer was less contaminated with PCE concentrations of approximately 600 !J.g/L in both on- and off-site wells.

An ROD was issued for OU1 on January 5, 1989, which presented the selected remedy: groundwater pumping, treatment and discharge to the storm sewer. RAs for the City water

5

supply wells were identified under the ROD for OUl, thus, a separate ROD was not executed for the City water supply wells. The OU1 ROD and the subsequent ROD for OU2 both called the Site "Waite Park Groundwater Contamination Site" rather than the site name used by the EPA's Superfund Enterprise Management System "Waite Park Wells Site." Both names refer to the Site.

OU2

The EPA tracks the entire BN site as OU2 ofthe Site; however, the MPCA manages the BN site as three OUs. BN site OU1 consisted of the waste disposal lagoons, BN site OU2 consisted of the impacted sandblast soil and BN site OU3 addressed the shallow groundwater contamination. The site was further divided into eight sections, lettered A through H. The MPCA issued a ROD for the BN site on July 14, 1994, which presented the selected remedy for the three BN OUs. The initial assessment findings and RAs for each OU are described below. The final RAs are described in Section IV. To avoid confusion in the information below, the EPA's OU nomenclature is used.

Waste Disposal Lagoons: Three lagoons containing approximately 17,500 cubic yards of lubrication oil and grease, oils containing PCBs, cooking oil, solvents and paints existed in Area A. Maximum concentrations of substances detected in samples collected from the lagoons include 570 mg/kg ofPCBs, 42 mg/kg of arsenic, 4.9 mg/kg of cadmium and 120,000 mg/kg of lead.

Impacted Sandblast Soil: Paint containing high concentrations of lead was stripped from railroad cars at a sandblasting station located in Area H. Waste sandblast sand was spread throughout the site. In 1992, BN initiated RAs based on a concern for children playing on the site. Approximately 7,000 cubic yards of sandblast sands were excavated in Area H. The soil was stockpiled on-site, covered with plastic and fenced. A fence was also placed around additional sandblast sands in Area A. Analysis of the sandblast sands showed maximum concentrations of 17,000 mg/kg of lead, 18 mg/kg of arsenic and 2.8 mg/kg of cadmium.

Shallow Groundwater: Shallow groundwater contamination including chlorinated VOCs, acetone, methylene chloride, benzene, toluene, xylenes, oil and grease and methyl ethyl ketone, was noted at several areas, resulting in continued groundwater monitoring.

Basis for Taking Action

Hazardous substances have been detected at the Site above levels indicating excess risk of exposure in the soil and groundwater. These substances include:

• PCE • Arsenic

• TCE • Cadmium

• TCA • Lead

• DCE • PAHs

• DCA • PCBs

6

C. REMEDY DECISIONS

OUt

The MPCA signed an ROD for OU1 on January 5, 1989 and the EPA concurred with the ROD on September 28, 1989. The RAOs were to prevent migration of contaminants to the City wells and to restore the contaminated aquifer. Section VIII of the ROD states "the primary objective is to abate or minimize the continued migration ofVOCs from the Site through the groundwater system." Section X (Selected Alternative) of the ROD states the selected remedy was Alternative IIIB, which consists of:

• Installation of groundwater pumpout wells in both the shallow and deep aquifers; • Treatment of contaminated water with a packed tower aeration system (air stripper); and • Discharge treated groundwater from the air stripper to the Sauk River.

Section X of the ROD describes detailed cleanup requirements as follows:

Groundwater at the site will require two separate but related actions: [1] satisfactory capture of shallow and deep plumes moving north of the site and [2] removal of sufficient quantities of groundwater to reduce the concentration of the remaining groundwater to the required level. Capture will be achieved by the proper design, placement and operation of shallow and deep pumpout systems. Groundwater risk reduction will be achieved by continuing to operate the pumpout system until the more restrictive of Maximum Contaminant Levels (MCLs) or Recommended Allowable Limits (RALs) for VOCs in both the shallow and deep aquifers is met. The cumulative

'""'"' excess carcinogenic risk of the two carcinogens, PCE and TCE, at the stated cleanup , ,;, levels is approximately 1.2 X 1 o-s. This level of protection is deemed adequate since no

one at the site is actually drinking the groundwater or is likely to, since the entire area is served by municipal water. The target cleanup level for the other three contaminants of concern at the site (TCA, DCE, and DCA) is set at the MCL or RAL where no MCL is available. Upon consultation with MDH, it was determined that analysis of cumulative effects of these non-carcinogens was not needed, since the systemic effects of each of these contaminants are different.

Table 4 of the ROD lists each contaminant, its MCL, RAL and target cleanup level. Contaminants outside the zone of remediation at the Site that are currently being transported to the Waite Park Municipal Water Supply will be treated by the stripper at that location.

The target cleanup levels for on-site VOC contaminants listed in Table 4 may not be achievable by the selected RA. If that becomes the case, alternate concentration levels may need to be considered.

[Paragraph regarding on-site air stripper omitted here]

Effluent from the air stripper will be discharged to the Sauk River. The Sauk River is not classified as a drinking water source, therefore, only the lower of fish consumption and aquatic life chronic toxicity criteria will be applied to water in the Sauk River at the discharge point allowing for 7Q 1 0 dilution (additional detail not copied here)

7

OU2

The MPCA staff will require that a deed notice be placed on the property pursuant to Chapter 115B.16, Subd.2 of MERLA.

The MPCA signed a ROD for contamination remaining at OU2 on July 14, 1994. The RAOs for OU2 are: "to prevent current or future exposure to the contaminated soils and to reduce contaminant migration into the groundwater" through the stated objective of "source removal and [meeting] remediation levels." The selected remedy is Alternative C: Solidification/Stabilization and On-Site Containment. The selected remedy included the following actions:

• Excavation of the lagoon waste, sandblast sands, and the dirt floor of the paint building on the property now owned by Waite Park Manufacturing, Inc., incorporation of the [previously] consolidated sandblast sands [with the waste]; excavation of the contaminated waste until ali visible oily soils and sandblast sands are removed; sampling from the sidewalls and bottom of the excavation to meet the remediation levels; removal and treatment of any visible oil floating on the groundwater; backfilling with clean soil, compaction, topsoil, and seed.

• Solidification/stabilization of the waste to reduce the concentration of contaminants to below hazardous levels and to minimize the mobility of the contaminants in the waste material; treatability studies to determine the most appropriate method.

• Placement of the treated waste in a containment facility constructed on-site pursuant to Minn. Rules Ch. 7035 pt. 2815, with a liner system, leachate collection and detection, cover system, groundwater monitoring and gas collection; contingency action plan and post closure requirements conducted pursuant to Minn. Rules Ch. 7035 pt. 2615 and 2645.

• Restrictions would be placed on any area that is not remediated to unrestricted land use remediation levels and on property containing the containment facility.

• Groundwater monitoring network installed or upgraded in the vicinity of the lagoons and monitoring well MPCA 14-S; groundwater monitoring plan.

• Area A was to be remediated to unrestricted land use levels. Areas B through H were to be remediated to commercial/industrial land use levels.

After the containment cell was constructed, a subsequent assessment documented the presence of additional contaminated soil that was excavated and stockpiled on-site.

On August 11, 1998, the MPCA modified the ROD in an ESD. The ESD presented an Integrated Remedy that allows a risk-based approach to address known and potentially impacted soil at the site with a combination of any of the following RAs: excavation, treatment, and hauling to an off-site landfill; evaluating risk of exposure to public health and the environment to determine if impacted material may remain in place; and use of engineering and institutional controls to ensure that the remedy remains protective.

The ESD indicated that stockpiled soil [from post-containment cell excavations] would be stabilized and transported to an off-site landfill for disposal with solidification as an option. Treated soil must meet the soil cleanup levels in Table 4 of the ROD and off-site landfill waste acceptance criteria. A risk-based approach would be used to determine whether contamination may remain in place as a part of an integrated remedy, with the use of engineering and institutional controls as necessary to ensure that the remedy remains protective of public health and the environment. The integrated remedy must be developed in accordance with the needs of all affected parties. The MPCA approval or conditional

8

approval of proposed actions or contingency plans is required. Institutional control language must include site conditions, use or activity restrictions, and notification of the presence of residual contamination and accompanying controls, and/or assurance that long-term mitigation measures or monitoring requirements (e.g., engineering controls) are carried out and maintained. An example is that Area A requires restrictions on excavation activities due to remaining impacted soil and debris at a depth greater than 4 feet.

D. REMEDYIMPLEMENTATION

City Wells

In response to contamination in the City wells, in 1985 the MPCA installed an emergency drinking water connection between the City and the City of St. Cloud to provide clean drinking water. In 1985 and 1986, the MPCA issued three RFRAs to various PRPs for OUl and OU2, citing these areas as sources of contamination found in the City's wells. During September 1986, the MPCA approved an RA that consisted of installing a packed tower aeration system to remove the contaminants from the water prior to consumption. PRPs for OUl and OU2 jointly funded and implemented the water treatment system, and the City water supply wells were placed back into service in February 1988. The City took over operation and maintenance of the treatment system after it was constructed.

The City has since installed additional water supply wells and built a new treatment facility with a design for better iron control and the ability to meet the additional demand for potable water. The original treatment plant has been decommissioned. Municipal Well 5 and the new treatment building were brought into service in May 2002. The current system influent comprises water pumped from municipal Well #4 and #5 at varying flow rates. Municipal Well #2 has been shut down since the early 1990s; Well # 1 has not operated since 2010 and Well #3 was only operated part time.

OUl

Remedial actions included the installation of three pump-out wells PW-1, PW-2, and PW-3 (see locations on figure). Wells PW-1 and PW-3 were installed on the eastern portion of the EM site, south of the main building and east of the thermolastics wing. Well PW -1 was completed in the shallow aquifer and PW-3 was completed in the deeper aquifer. Pumpout well PW-2 was installed in the shallow aquifer, along the western portion of the site and south of the main building.

Beginning in September 1988, groundwater was pumped from PW-1 and PW-2 to an on-site remediation building for treatment using a packed aeration tower prior to discharge to the Sauk River. Well PW-3 was not used for groundwater extraction. Well PW-2 was abandoned in 1998. Groundwater pumping from PW -1 continued through April 2001. At that time asymptotic levels had been reached in the extraction wells, and the MPCA approved a test shut-down of the wells. PRPs had obtained a water appropriations permit from the Department of Natural Resources (DNR) for the shallow (permit no. 893231) and the deeper aquifer (permit no. 893230) extraction wells. The permits were terminated in June of2003. Currently, all three wells designed for pumping have been sealed.

The soil investigation performed during the initial remedial investigation for the EM site identified some localized areas oflimited contamination, and soil remediation was not required by the ROD. After 10 years of pumpout, EM site RPs looked at ways to reduce costs and time of operation. To determine whether excavation of contaminated soil was a feasible means, an additional soil investigation was conducted during the fall of 1999. The additional investigation identified Source

9

Area 1; 2,656 tons of soil were excavated from the former unregulated disposal pit in the southwest portion of the site and disposed of at an industrial landfill. Two other areas of contaminated soil were identified south of the building and east of the thermolastics wing, loyated near PW -1 and near the former paint booth.

PRPs installed a pilot-sized SVE system at monitoring well EM-9S, near the former paint booth source area. The SVE system operated from October 2000 through July 2002 and had a radius of influence of approximately 70 feet. The SVE system was shut down when it reached asymptotic levels. It is unknown whether there is significant source material beneath the building or adjacent to footings and foundations that may not have been adequately influenced by the pilot SVE system.

In 2008, Barr Engineering Company (Barr) completed additional field activities in conjunction with the annual groundwater monitoring. The investigation activities included the following activities:

• Soil vapor assessment south of the Grede Foundries building, near former SVE well EM-9S; • Soil sampling in a historical source area near the former pumpout well PW -1 to verify whether

significant targeted source material remain on the Site; and • Groundwater sampling north of the site to delineate the extent ofthe chlorinated VOCs plume

in the lower aquifer.

Seven soil-gas samples were collected as part of the soil vapor assessment. PCE concentrations ranged from 517 micrograms per cubic meter (!lg/m3

) to 74,100 11g/m3, while TCE concentrations ranged

from 8.2 11g/m3 to 4,920 11g/m3. All ofthese PCE concentrations exceeded 10 times (lOx) the MPCA's

ISV at that time, and in some cases, the acute ISV s were exceeded. A building-specific evaluation was recommended.

Three soil borings were advanced near the former pumpout well PW -1. Although PID headspace readings indicated elevated organic vapors in the field, the laboratory confirmation sample reported concentrations less than reporting limits for ROD COCs.

Four soil borings were also advanced north of the site to determine if migration ofVOCs had occurred beyond EM-24D. TCE was detected in PB-3 at similar concentrations as those detected in EM-24D. Water samples collected from the remaining borings to the north and northeast did not report contamination levels above reporting limits; however, limited screened intervals were sampled and uncertainties remain concerning the extent of the plume to the north.

Between 2010 and 2012, the MPCA obtained additional information concerning air exchange operations in the building that exists on OU1, occupied by Grede Foundries, Inc. The existing pollution control system operating at the foundry discharges approximately 644,300 ft3 of air per minute from the building, and the building encompasses approximately 11,487,000 ft3

; therefore, the system results in 3.36 air exchanges per hour. On November 7, 2012, EPA and MPCA staff conducted a site visit that included the Grede Foundries building and found the air exchange system operating. Review by an EPA Region 5 risk assessor indicated that if these prior data were extrapolated to depths of concern, indoor air concentrations would be well below the State of Minnesota's time-weighted average (TWA) limits for air contaminants, which are protective for workers at the facility. Based upon this information, the Fourth FYR was amended to state that the vapor intrusion pathway was unlikely to cause unacceptable risk at the Site.

10

OU2

Beginning in 1988, the PRP implemented cleanup actions at OU2 under the oversight of the MPCA's Tanks and Spills program. Actions included removal of sandblast sands, removal of underground and above-ground storage tanks, and thermal treatment of contaminated soil. Actions continued pursuant to the ROD, including placemet?-t of excavated sandblast sands into an on-site containment cell and groundwater monitoring.

The ESDs allowed an Interim Remedy to address the lead-impacted soil on the BN site. Several iterations of assessment and RAs were performed since 1998. The assessment and RAs are summarized below:

• BN excavated approximately 105,000 tons oflead-contaminated soil from Areas A, B, and C that was stockpiled on-site. Between May and August 1999, the stockpiled soil was stabilized on-site using EnviroBlend, a commercial stabilizing product, and transported to Superior FCR Landfill located in Buffalo, Minnesota, for disposal.

• Approximately 60 acres of OU2 remained to be investigated on all or parts of Areas B, C, D, E, F, G, and H. The additional investigation to delineate the lead-impacted areas was completed in 2000. The assessment also detected several areas with elevated arsenic concentrations. The arsenic-impacted areas coincided with lead-impacted areas.

• The additional assessment included the adjacent Park Press property, located at 355 6th Avenue North, which is part ofthe BN site. The assessment detected lead, cadmium, and arsenic concentrations that are below the cleanup levels established for OU2. The MPCA stated in an April10, 2002, letter that "no further RA is required at tllis property."

• RAs were conducted at OU2 during September and October 2000 along the northern portion of Areas G and H. The RAs included the excavation, treatment, and off-site disposal of leadimpacted soil, and also included the excavation and off-site disposal of asbestos-containing material (ACM) that was discovered intermixed with the lead-impacted soil. An estimated 7,884 cubic yards of impacted soil was excavated, stabilized using EnviroBlend, and transported to Superior FCR Landfill for disposal.

• RAs were conducted at OU2 during August through November 2000, and June through August 2001 at Area F, and the southern portion of Areas G and H. TheRA included the excavation, treatment, and off-site disposal of lead-impacted soil, and also included the excavation and offsite disposal of ACM that was discovered intermixed with the lead-impacted soil. An estimated 24,000 cubic yards of impacted soil was excavated, stabilized using EnviroBlend, and transported to Superior FCR Landfill for disposal.

• Approximately 17,400 tons oflead-impacted soil was excavated from Lots 1, 2, and 3 of Block 2 in the West River Business Park in 2000. Based on the analytical data, these soils did not require treatment prior to disposal at the Elk River Landfill in Elk River, Minnesota.

• Contaminated soil was excavated in 2001 from Areas F, G, and H; from the West River Business Park Partnership, L.L.P. property in Lots 2, 3, 4, and 5 of Block 1located in Area B; and from the Waite Park Manufacturing, Inc. property located in Areas Band D. TheRA also included the excavation and off-site disposal of ACM that was discovered intermixed with the

11

lead-impacted soil at select areas of the site. A total of 31,968 tons of impacted soil was stabilized using EnviroBlend and transported to Superior FCR Landfill for disposal.

• On April30, 2001, an additional40 cubic yards oflead-impacted soil was excavated from areas MM-60, MM-61, and MM-62 on Lot 2 of Block 2 on the West River Business Park portion of OU2.

In 2002, groundwater monitoring (with the exception of monitoring the containment cell) was discontinued because contaminants were no longer detected. The PRP abandoned six monitoring wells and transferred ownership ofthree monitoring wells to the City. The abandoned monitoring wells include MPCA14S, ERT25D, MPCA4D, MPCA11D, Railroad Well #1, and Railroad Well #2. The three wells were transferred to the City were MPCA13D, MPCA3D, and ERT26D. The only remaining monitoring wells used by BN are MW28, MW33, MW34, andNW3S. These wells are used for monitoring around the containment cell.

OU2 was delisted from the PLP on July 2, 2002, with all RAs completed.

12

Appendix B

Photograph Log from Site Inspections

Photo No.:

Location:

Photo Direction:

EM Site

2-17-15

North

Description: Former suspected source area. The area is located near the southeast corner of the building. Monitoring wells EM9S, EM9M and EM1 OS are pictured in the photograph.

Photo No.: 2

Location: EM Site

Date: 2-17-15

Photo North Direction:

Description: Soil Excavation in process at the south wall bump out of the Grede building.

Electric Machinery Site

Photo No.: 3

Location: EM Site

Date: 2-17-15

Photo East Direction:

Description: Soil excavation in process at the bump out of the south wall for the Grede building.

Photo 4 No.:

Location: EM Site

Date: 2-17-15

Photo South Direction:

Description: Excavated soil pile located west of the storage shed on the southern edge of the property. The soil pile is located between the abandoned wells EM7S and EM41S.


Photo No. : 5

Location: EM Site

2-17-15

North Direction:

Description: St. Cloud Hospital CentraCare Recovery Plus is located directly north of the Grede Building on the Former Electric Machinery Site.

Photo No.: 6

Location : EM Site

Date: 2-17-15


Description: Monitoring Well , EM3D with missing expandable cover and well cover.


Photo No.: 7

Location : EM Site

Date: 2-17-15

Photo East Direction :

Description: View of Monitoring Well, EM20D Monitoring Well EM20S not located.

Photo No. : 8

Location : EM Site

Date: 2-17-15

Photo sw Direction:

Description: Water treatment building with air strippers.


Containment Cell (Area F of Burlington Northern Site)

Photo No.: 9

Location: BN Site

Date: 02/17/15


Description: Leachate Collection Sump located inside the fence on the western edge of the Containment Cell.

Photo No.: 10

Location: BN Site

Date: 02/17/15


Description: View of the southern edge of the Containment Cell.


Photo No.: 11

Location: BN Site

Date: 02/17/15


Description: View of the middle western edge of the containment cell.

Photo No.: 12

Location: BN Site

Date: 02/17/15


Description: View of the northern edge of the containment cell.


Photo No.: 13

Location: BN Site

Date: 02/17/15


Description: Drainage area located on the northeast corner of the containment area. Tall grass in rip rap needs to be hand trimmed.

Photo No.: 14

Location : BN Site

Date: 02/17/15


Description: Clumps of soil on the side on the north side of the containment cell near the first vent on the east side. (Arrow marks the location of the clumps of soil)


Photo No. : 15

Location: BN Site

Date: 02/17/15


Description: Rip Rap drainage area located near the northeastern corner of the containment cell. Tall grass in rip rap needs to be hand trimmed.

Photo No.: 16

Location: BN Site

Date: 02/17/15

Photo sw Direction:

Description: Additional clumps of soi l located near the eastern most vent location on the containment cel l. (Arrow marks the location of the soil clumps)

Photo No.: 17

Location: BN Site

Date: 02/17/15


Description: New fence constructed on the eastern edge of the containment cell.

Photo No.: 18

Location: BN Site

Date: 02/17/15


Description: Compost pile located between the containment cell and the fenced soil pile.

(Area E of Burlington Northern Site)

Photo No.: 19

Location: BN Site

Date: 02/17/15


Description: Looking at the fenced soil containment cell in the foreground and the water t reatment building in the background.

Photo No.: 20

Location: BN Site

Date: 02/17/15


Description : Looking at the western side of the City Water Treatment Plant and Air Strippers.

(Area E of Burlington Northern Site)


Photo No.: 21

Location: BN Site

Date: 02/17/15


Description: Looking at southern side of the containment cell.

Photo No.: 22

Location: BN Site

Date: 02/17/15

Photo Northeast Direction:

Description: Looking at the southern side of the containment cell

Rivers Edge Park (Area A of Burlington Northern Site)

Photo No.: 23

Location: BN Site

Date: 02/17/15


Description: Looking at the previously unidentified stock pile location in River Bend Park. Waste sod rolls were observed. A stock pile of baseball field soil and the park maintenance building are in the background.

Photo No.: 24

Location: BN Site

Date: 02/17/15

Photo West Direction:

Description: Looking at the formerly unidentified stock pile location in River Bend Park in the foreground. The train tracks and mobile home properties are in the back ground.

Appendix C

Interview Documentation

INTERVIEW RECORD

Site Name: Waite Park Wells EPA ID Number: MND981002249

Subject: 51h Five-Year Review Date: Ma,rch 3, 2015 \

Type: Email [email protected]

Contact Made By:

Name: Laura Salmonson Organization: Bay West

5 Empire Drive

St Paul, MN 55103

Title: Senior Staff Professional Phone/Email: 651-291-3488 I lsolmonson@ l:>aywest.com

Individual Contacted:

Name: Bill Schluenz Organization: City of Waite Park

Title: Public Works Director

Telephone Number: 320-252-6822 Street Address:

E-Ma,il Address: 602 3rd St S [email protected] Waite Park, MN 56387

General Summary of Conversation:

t. What is your overall impression of the project? (general sentiment) The project and site has been well run, with no issues.

2. What effects have site operations had on the surrounding community? TIJe community has n_othad any ill effects in the operations of the site.

3. Are you aware of any community concerns regarding the site or its operation and administration? If so, please give details? I am not aware of. any concerns.

4. Are you aware of any events, incidents, or activities at the site such as vandalism, trespassing, or emergency responses from local authorities? If so, please give details. There have no incidents/activities on the site. If there have been, I have not. been contacted.

5. Do you feel well informed about the site's activities and progress? Absolutely!

6. Do you have any comments, suggestions, or recommendations regarding the site's management or operation? None at this time.

7. Do you have any other concerns or comments about the site? I do not.

Prepared by William Schluenz on March 4, 2015

INTERVIEW RECORD '

Site Name: Waite Park Wells EPA ID Number: MND981002249

Subject: 51h Five-Year Review Date: March 3, 2015

Type: Email [email protected]

Contact Made By:

Name: Laura Salmonson Organization: Bay West

5 Empire Drive

St Paul, MN 55103

Title: Senior Staff Professional Phone/E.mail: 651-291-3488/lsolmonson@baywestcom

Individual Contacted:

Name: Kim Larsen Organization: MDH

Title: District Engineer

Telephone Number: 320.223-7300 Street Address: MDH - Midtown Square

E-Mail Address: 333 W Division St, Suite 212 [email protected] St. Cloud, MN 56301

General Summary of Conversation:

1. What is your overall impression of the project? (general sentiment) The project has been successful. The treatment plant performs as expected and all water sample results from the plant effluent from the last 1 0 years are absent of all detection of volatile contaminants regulated by the EPA.

2, What effects have site operations had on the surrounding community? None.

3. Are you aware of any community concerns regarding the site or its operation and administration? If so, please give details? No.

4. Are you aware of any events, incidents, or activities at the site such as vandalism, trespassing, or emergency responses from local authorities? If so, please give details. None that I know of. The site is fenced and has cameras.

5. Do you feel well informed about the site's activities and progress? Yes. I maintain a good working relationship with all staff members.

6. Do you have any comments, suggestions, or recommendations regarding the site's management or operation? No.

7. Do you have any other concerns or comments about the site? No.

Appendix D

Public Notice

Printers Affidavit of Publication

STATE OF MINNESOTA COUNTY OF STEARNS

JoAnne Tennison, being duly sworn on oath, says that she is the publisher or authorized agent and employee of the newspaper known as the St. Cloud Times, and has full knowledge of the facts which are stated below:

(a) The St. Cloud Times has complied with all of the requirements constituting a qualified newspaper, as defined by Minnesota Statutes 331A.01 to 331A.11 and other applicable laws, as amended.

(b) She further states that the printed Public Notice: Bay West LLC -P140753 hereto attac;:hed as a part hereof was cut from the columns of the St. Cloud Times, and was printed and published therein in the English language, that it was so puplished on: Sat., Feb. 7, 2015. The following is a printed copy of the lower case alphabet from 'a' to 'z', both inclusive, and is hereby acknowledged as being the size and kind of type used in the composition and publication of said notice, to-wit:

~-ali c de f g hi J k 1m ~ p q r stu v·w·t y-; _ _

. b (;\ \.J v-'-_ _____ _ JoAnne Tennison

Rate Information

1 Lowest dassified rate paid by commercial users for comparable space: 0.99/1.31 daily/Sunday per agate line

2. Maximum rate allowed by law for the above matter: 0.99/1.31 daily/Sunday per agate line

3. Rate actuallY cllargeo for 6plline: 0.99/1.31 daily/Sunday

4. Rate actually cllarged for bold incll: 17.85/22.05 daily/Sunday

5, The rates above will carry a 10% surcllaige for Thanksgiving and Christmas Day.