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<br />. <br /> <br />Ms. Amy Hadiaris <br />Minnesota Pollution Control Agency <br />September 28, 1993 <br />Page 3 <br /> <br />geologic cross sections depicting the waste fill in relation to till and outwash units must <br />be constructed. In construction of these cross sections, till and outwash contact points, <br />as presented in the CAIR, may have to be modified. Attached to this letter, as <br />Attachment A, are errors and inconsistencies that BAL determined were made while <br />interpreting monitoring well boring and gamma logs for construction of soil boring cross <br />sections. These errors were found on soil boring cross sections presented in the CAIR. <br />The errata information in Attachment A should be used in redrawing waste/fill cross <br />sections. <br /> <br />The hydrogeological discussion should more specifically define velocity direction and <br />magnitude in three dimensions over the area of study. These velocities would be <br />calculated using a sufficient variance of horizontal and vertical hydraulic conductivity <br />values to effectively characterize the heterogeneous hydraulic conditions found at the site. <br /> <br />e <br /> <br />The contaminant migration discussion should contain an analysis of the types of <br />contaminants detected at the site including their physical/chemical properties and their <br />degradational and migrational characteristics, i.e. dispersive, diffusive and sorptive <br />behaviors of individual chemicals. Using this information, as well as geological and <br />hydrogeological interpretations, potential contaminant migration scenarios should be <br />discussed as a precursor to identifying feasible remedial alternatives. <br /> <br />6. <br /> <br />The CAIR addendum should also propose a residential well monitoring program. <br />Included in this program should be those wells that have the potential of being impacted <br />by off-site migration of contaminated groundwater based upon contaminant migration <br />study. <br /> <br />7. <br /> <br />At this juncture two options are being considered for remedial approach. <br /> <br />o <br /> <br />The City's consultant BAL is of the opinion that some interim groundwater <br />corrective actions should be pursued within a short time frame. MPCA <br />groundwater intervention limits have been continually exceeded for the past five <br />years. Exceedance of intervention limits at this site warrants the timely <br />implementation of corrective action. This has not occurred. <br /> <br />e <br /> <br />BAL proposes that ERL implement a groundwater pump and treat system in the <br />area of highest contaminant concentration immediately adjacent to the waste fill <br />boundary. An interim groundwater withdrawal and treatment system will have the <br />following beneficial effects: <br />