Bell Lumber and Pole Company (Bell Pole) is submitting this application as a formal request for a variance and authorization from the Minnesota Pollution Control Agency (MPCA). This application is being submitted according to the variance provisions of Minnesota Rules 7000.0700, 7050.0190 and 7060.0900. A variance is requested to Minnesota Rules 7060.0500, 7060.0600 and 7050.0220. This variance will allow the use of innovative technology as an interim response action (IRA) remedial cleanup at the Bell Pole site in New Brighton, Minnesota (Site). The technology to be applied was earlier presented to the MPCA in the work plan report titled "Interim Response Action Work Plan, CROW Process Source Remediation: prepared by Western Research Institute (WRI) and Conestoga-Rovers and Associates (CRA) dated August 1990. This report presented a work plan to implement the Contained Recovery of Oily Waste (CROW) process as an IRA at the Bell Pole Site. The CROW process was developed by WRI and provides an in-situ remedial technology for the Site process area using heated water flushing. This action is necessary to remove non-aqueous phase liquid (NAPL) that is an ongoing source of contamination to Site groundwater and is, therefore, an interim response. Bell Pole's representative met with MPCA on October 3 and November 29, 1990, to discuss the proposed CROW project and receive MPCA staff's initial comments. These meetings have resulted in the determination by MPCA staff-of the need for a variance application and the informational scope for that application.