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<br />e <br /> <br />e <br /> <br />e <br /> <br />Ms. Amy Hadiaris <br />Minnesota Pollution Control Agency <br />September 28, 1993 <br />Page 4 <br /> <br />a. Capture and treatment of groundwater which has the highest contaminant <br />concentration. <br /> <br />b. Hydraulic gradient control for the zone of high concentration contaminants <br />likely contributing to off-site migration and impacts. <br /> <br />c. Interim system performance monitoring will enable an enhanced degree of <br />understanding of site conditions which will be used in refining the final <br />design. Uncertainties regarding aquifer characteristics warrant an <br />"observational" approach to the final remedial design at this site. The <br />observational approach acknowledges that certainties exist and allows for <br />the development and implementation of contingency plans to accommodate <br />unexpected conditions. <br /> <br />d. <br /> <br />Reduction of the environmental impacts that will occur during the <br />preparation of the final remedial design. Considering previous schedule <br />adherence failures, BAL feels that a considerable time period may elapse <br />prior to implementation of the final remedial design. <br /> <br />e. By focusing on the area of highest groundwater contamination, the interim <br />remedial system should be able to be included as part of the final system <br />design. <br /> <br />It is the opinion of BAL that these interim corrective actions should be initiated <br />in the spring of 1994. This will provide ample time for design and construction <br />of the interim system. <br /> <br />o The County's consultant is of the opinion that, based on the presently available <br />data, implementation of interim corrective actions at this time is somewhat <br />premature. Although committed to rapid implementation of corrective actions, <br />EnecoTech suggests that resources associated with corrective actions be invested <br />in a remedial program which address both short term and long term remediation <br />requirements. Specifically, EnecoTech recommends that ERL be required to <br />develop a long term comprehensive remediation work plan and schedule prior to <br />implementing remedial actions at the site. The workplan and schedule should <br />encompass all environmental/engineering design programs including groundwater <br />remediation, landfill gas mitigation, landfill closure/capping, etc. <br />