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AECOM <br />Mr. Jankowski <br />December 8, 2008 <br />Response action plans for R-Area 1 (R-Area 1 RAP) and for R-Area 2 (R-Area 2 RAP) were prepared <br />by BNSF and submitted to the MPCA for review. Both plans received approval from the MPCA with <br />modifications. As part of the approved plans, arsenic-impacted soil present within R-Area 1 and R-Area <br />2 will be excavated and transported off-site for disposal at a licensed landfill facility. <br />The approximate excavation areas are illustrated on Figure 2 and will result in the removal. of <br />approximately 5,700 cubic yards of arsenic-impacted materials (i.e., source area removal). As indicated <br />on Figure 2, the base of a storm water retention pond on Dolphin property (pond base) is included in the <br />source area removal program. No specialized permits have been obtained to excavate the pond base <br />as it is our understanding that this storm water retention pond is not considered a designated wetland. <br />The R-Area 2 RAP includes plans to restore the pond base for continued use as a storm. water retention <br />pond. <br />To facilitate implementation of the RAPs, certain water management controls need to be established at <br />the Site. The following sections discuss the water. management activities proposed to support response <br />actions at the Site. <br />Water Management <br />Water from three potential sources will require management during response actions to address <br />arsenic-impacted pond base materials. The three potential sources are: <br />• Pond Water -Approximately 1 to 3 feet of standing surface water (Pond Water) has been <br />observed in the pond since it was constructed in 1999, which equates to approximately 100,000 to <br />300,000 gallons of standing water. <br />• Storm Water Runoff- Paved parking areas on the Dolphin property and a paved parking area on <br />the Anoka West Pet Hospital property drain into the pond at three inlets. During excavatian <br />activities, storm water runoff will need to be intercepted and managed before it enters the pond. <br />• Excavated Soil Dewatering -Some of the pond base materials may need to be dewatered before <br />transport for off-site disposal. Arsenic-impacted water resulting from these activities may require <br />management. <br />Pond Water <br />Laboratory analytical results for Pond Water samples collected annually indicate the Pond Water <br />contains arsenic at very low concentrations. Table 1 presents the arsenic concentrations detected in <br />the Pond Water over time. <br />The Pond Water will be removed from the pond prior to initiating excavation activities to facilitate soil <br />removal, loading, and transport activities. The water will be removed in a manner that minimizes <br />disturbance of sediments and minimizes the concentration of suspended solids in the discharge. Figure <br />3 provides a generalized depiction of the facilities that will be used to support the Pond Water <br />management activities at the Site. <br />The Pond Water will be removed from the pond using electric powered pumps, or equivalent pumping <br />methods, and discharged to a discharge area on BNSF R.O.W. north of the railroad tracks (see Figure <br />3). BNSF proposes to remove the Pond Water through implementation of the following steps: <br />• Excavate a shallow sump (i.e., less than two feet deep) in the western portion of the pond, at the <br />deepest point, and install a pump with protective screening to keep debris and suspended solids <br />from fouling pumping operations. <br />N:ProjectW/BNSF/2000/2983 Ramsey/Correspondence/Other/09 Dec <br />City Ltr <br />