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-2- <br /> <br />~en it was suggested that on the basis of the Agency's evaluation of past <br />samples, one could conclude that the landfill is improving the quality of <br />ground water, your representatives agreed that there could have been flaws <br />in the agency's reliance on Well #$ as a control well. <br /> <br />;~en your representatives were asked if your Agency had any guidelines or <br />criteria for determining the levels at which changes in water quality are <br />sufficiently serious to precipitate more extensive sampling or remeSial <br />measures, their response was that the agency has no such guidelines or <br />criteria. When it was suggested that PH determinations should be made in <br />the field at the time of sampling rather than in the laboratory, your rep- <br />resentatives agreed. <br /> <br />When representatives'of the City pointed to numerous samples from the re- <br />maining monitoring wells that show abnormally high levels of several of <br />the "indicator" constituents and suggested that-laboratorydocuments show- <br />ing such results should either include an explanation, if there was one, <br />or precipitate resampling if there was no explanation, your representatives <br />agreed. <br /> <br />When representatives of the City suggested that the monitoring program <br />should place more emphasis on detection of complex organics, your repre- <br />sentatives appeared to agree. <br /> <br />Also in the course of the November 9 meeting, your representatives re- <br />quested suggestions for improving the ground water monitoring program. <br />With the belief that the request was offered in good faith, the City's en- <br />gineering consultants, in a letter dated November 29, 1978, offered some <br />sound and positive suggestions. <br /> <br />Mr. Clark's failure to even acknowledge that letter can only be interpreted <br />as his rejection of those suggestions without discussion of their merits. <br /> <br />It is against this background that Mr. Clark now concludes that your Agency <br />has conducted an adequate ground water monitoring program and that no change <br />is justified at present. <br /> <br />It would be simple to dismiss the December 8 letter as bureaucratic arrogance <br />or even to believe that in the month that elapsed between the meeting and <br />the 1.etter, the details of the meeting could have been forgotten. <br /> <br />It is also possible that your staff is insensitive to public health consider- <br />ations and thus fails to grasp the far reaching impact of ground water pol- <br />lution from a potential source as massive and complex as this landfill. <br />If that is the case, the Minnesota Department of Health should be invited <br />to play a role in upgrading your monitoring program. <br /> <br />Finally, we are fully aware of the fact that our City is asking for a pro- <br />gram that will undoubtedly have a financial impact on the landfill operator <br />and,-if ground water contamination is proven, it may result in public <br />pressure to shut down the operation. <br /> <br /> <br />