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<br />, <br /> <br />Memorandum, TCAAP Review <br />Page Two <br />February 14,2000 <br /> <br />e <br /> <br />A follow up meeting was set for February 7, 2000 during which time all of the same participants, <br />including the EP A, would be involved. <br /> <br />Follow Up Meetin!!: <br />At the meeting on February 7th, the EPA claimed that, if the City removed any of the soil that <br />was considered to be contaminated, it would be remedial action, and a proper report, follow up <br />testing and disposal would need to be followed. The indication from those present at the meeting <br />was that a consultant would need to be hired by the City to follow the proper reporting and <br />testing procedures of the EP A. If the City chose to follow these procedures, this would satisfy <br />the EP A and they would sign off on the transfer of the title of the property to the City. The EP A <br />would place no restrictions on the property. The only note on the title to the property would be <br />the indication as noted above. <br /> <br />The downside to the process through the EP A is that it would require additional time, costs and <br />delays in obtaining fee title to the property. The EA and the EBS would not be able to be <br />processed until such time as the EP A had received all the necessary documents from the <br />consultants to satisfy them that there was no longer a problem on the property. Although, during <br />the course of conversation, the EP A thought that they may be able to process this within 2 - 4 <br />weeks of receipt, this did not include the timeframe in which a report would have to be put . <br />together, a testing plan developed and followed, and the analysis processed and then all of this <br />information turned over to the EPA. Based on the recent schedule of the State's testing <br />procedures, this could be a 2 - 3 month additional timeframe added to the 60 day EA and EBS <br />timeframe. <br /> <br />The other option that was discussed during the course of the meeting was eliminating that <br />portion of the property that contained the elevated lead levels. The City could try to cut out that <br />portion of the property, or actually have it legally described as two (2) separate parcels, one of <br />which could be immediately conveyed to the City. The other property would not be transferred <br />to the City of Arden Hills, and would remain in the possession of the DOA and would be their <br />responsibility for clean up. If the City chose to follow this option, it would have to deal with the <br />MPCA to gain concurrence on the transfer of the title of the property. Because MPCA would <br />have no reason to believe that there is further contamination on any of the other parts of the <br />property, full concurrence for transfer of title would be given. <br /> <br />The downside to this option is that there would be a piece of property that would be <br />differentiated in some fashion (i.e., fenced and/or legally described) that would be immediately <br />adjacent to the City property. From an appearance standpoint, it would be quite obvious that this <br />property was different than the rest of the property that the City obtained. This may cause <br />questions or concerns about why the City didn't take or want this piece. The DOA would at <br />some point want to transfer the title of this property to the City. <br /> <br />. <br />