CCP 06-14-2004 - Laserfiche WebLink

Home Browse Search

. . . Minnesota Pollution Control Agency June 3, 2004 RECEIVED JUN - 9 2004 Mr. Michael R. Fix Remedial Project Manager Twin Cities Army Ammunition Plant 4700 Highway 10- Suite A Arden Hills, MN 55112 - 3928 CITY OF ARDEN HILLS Dear Mr. Fix: As you requested at the meeting on Tuesday, May 18, 2004 at the Arden Hills City Hall, 1 am writing to document the Minnesota Pollution Control Agency's (MPCA) position regarding future environmental work that will be required on some portions of the Twin Cities Army Ammunition Plant (TCAAP) property that are being proposed by the Army for transfer. As you will recall, the discussion at the May 18, 2004 meeting focused largely on the Phase I and II Environmental Site Assessment (ESA) that has been conducted by the Army on the property proposed for transfer. It is the MPCA's position that contamination that has been identified at TCAAP as part of the Phase II ESA work needs to be addressed by Anny as delineated in MPCA staffs comments dated October 23, 2003 to the Phase I and II ESA. Absent the proposed early transfer, MPCA staff would require Anny to address any newly identified contamination under Section XVI ("Additional Work or Modification to Work") of the Federal Facility Agreement. Any additional work for newly identified sourcc areas at TCAAP would be addressed within the Superfund program, consistent with all applicable CERCLA/MERLA requirements. However, given Anny's stated intention to transfer the majority of the property addressed by the Phase I and II ESA as an early transfer under CERCLA Section 120(h)(3), Army has the option of a) perfonning any additional work for newly identified contaminated areas prior to the transfer; b) perfonning any additional work for newly identified contaminated areas after the transfer as long as the landholding federal agency demonstrates why such data and findings are not necessary before the transfer and that the property will remain protective of human health and the environment; or c) negotiating with the transferee the additional work that has been outlined in regulator comments and certifying as part of the early transfer process that all necessary investigative or other actions will be taken by the transferce after the transfer. Therefore, given the conditions of the early transfer process, there is flexibility regarding who perfonns any additional work that may be required and when such work is conducted. 520 Lafayette Rd. N.; Saint Paul, MN 55155A194; (651) 296-6300 (Voice); (651) 282.5332 (TTY); www.pca.stale.mn.us St. Paul- Brainerd. Detroit Lakes. Duluth. Mankato. Marshall- Rochester. Willmar Equal Opportunity Employer. Printed on recycled paper containing at least 20 percent fibers from paper recycled by consumers.