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UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGIONS

77 WEST JACKSON BOULEVARDCHICAGO. IL 60604-3590

REPLY TO THE ATTENTION OF

June 15, 1993

Certified MailReturn Receipt RequestedReturn Receipt Number P 664 393 952

Mr. Thomas PendergastDirector SuperfundEnvironmental Quality2001 Market Street 3CPhiladelphia, PA 19101-1403

Re: Conrail Kailyard, Elkhart IN, U.S. EPA Disapproval of30% Design Documents and Comments.

Dear Mr. Pendergast:

The United States Environmental Protection Agency (U.S. EPA) hascompleted its review of the 30% Design Phase Engineering ReportFor Municipal Watermain Extension, dated March 1993, and theDesign Basis Report And 30% Design For The GroundwaterExtraction/Treatment System, dated April 21, 1993, for theConrail Railyard Superfund Site (Site) in Elkhart Indiana. TheU.S. EPA received the two documents on April 21, 1993. Conrailis conducting the Remedial Design/ Remedial Action (RD/RA) at theSite under an Unilateral Administrative Order (Order). The Orderbears U.S. EPA Docket Number VW-92-C-157 and is datedJuly 7, 1992.

This letter is to provide Consolidated Rail Corporation (Conrail)notice that the U.S. EPA disapproves, in whole, both documents assubmitted. Enclosed with this letter is a list and discussion ofthe deficiencies of both documents.

In accordance with Section IX of the Order, Conrail shall correctthe deficiencies and resubmit the documents for U.S. EPA reviewwithin 14 days of your receipt of this letter.

If either one or both of the resubmitted documents aredisapproved or modified by U.S. EPA, because the subject documentis either inadequate or not timely, Conrail shall be deemed to bein noncompliance with the Order. The U.S. EPA will deem theresubmitted documents inadequate if Conrail does notsatisfactorily address all deficiencies described by theenclosure to this letter.

Each copy of the resubmitted documents shall include an itemizednarrative briefly stating how each deficiency has been addressedand the location of all revisions to the text of the subjectdocument. The U.S. EPA will deem the resubmitted documentsinadequate if Conrail does not include the itemized narratives asspecified above.

Conrail shall submit; (a) 7 complete copies of both reviseddocuments to U.S. EPA, and (b) 3 complete copies of both reviseddocuments to Ms Krista Eskilson, Indiana Department ofEnvironmental Management (IDEM), Superfund Section, P.O. Box6015, Indianapolis, IN, 46206-6015.

If you have any questions concerning this letter, pleasetelephone me at (312) 353-1331.

Sincerely,

Charles WilkRemedial Project Manager

enclosure

cc: David Demko, GTIKrista Eskilson, IDEMSteve Mason, ORCKerry Street, RRBEric White, E & E

CONRAIL RAILYARD SITE

Deficiencies of the 30% Design Phase Engineering Report ForMunicipal Watermain Extension, dated March 1993.

General Comments

1. The submitted 30% Design Phase Engineering Report forMunicipal Watermain Extension (30% Watermain Design) isdeficient in that it does not include all of the pre-designinformation specified in the U.S.EPA-approved RD/RA WorkPlan (Section 2, pages 1 through 12). The 30% WatermainDesign document should have included a design basis reportproviding all information needed to design the watermainextension system. Noted deficiencies are discussed belowunder Specific Technical Comments.

2. The SOW (p.12, A.I) requires that the scope of the 30%design document shall be outlined in a manner reflecting thefinal specifications. The preliminary projectspecifications are contained in Appendix C and are verybrief in scope. It was anticipated that the specificationswould be the body of the design document and would have beenof expanded scope.

3. The 30% design phase engineering report provided variousdesign scenarios and concludes that decisions need to bearrived at before the design can continue. The ROD directsthe respondent to provide a water supply to the residentsand businesses which presently have contaminated water as aresult of past practices by the Conrail facility. The exactrouting shall be determined and recommended by therespondent. Upon that recommendation, EPA will approve ordisapprove the design at various stages of completeness.The present design submittal does not recommend any suchdesign and therefore is deficient. It appears that furtherdiscussions between the respondent and the localgovernmental entities are required. According to theStatement of Work (SOW) (Attachment 2 of the Order), theRespondents (Conrail) shall obtain all permits and approvalfrom the State of Indiana, Elkhart and St. Joseph Countiesand City officials necessary to design and construct thewater distribution system.

If Conrail has information on residential well contamination(as a result of the required residential well monitoring),such information shall be considered to determine ifadditional areas should be serviced by the water supplyextension. The SOW, page 5, states that the respondent mustsupply potable water to other residences and businessesexisting at the time of construction with well watercontamination exceeding MCLs.

An Application for Construction Permit, IDEM, Drinking WaterBranch, Public Water System, is enclosed. Conrail shallsubmit the completed application to IDEM with the finaldesign. IDEM shall act on the completed application within60 days. The application includes a checklist of itemsreviewed by the IDEM before issuing a permit, this may behelpful.

Specific Technical Comments

6. Section 2.1, p. 4, 2nd paragraph, the Charles Street andVistula Road areas are east of Baugo Bay, not Baugo Creek.

7. Section 2.2.2, p. 4, states that the Indiana Avenue Routehas been suggested and is preferred by the City of Elkhart.However, a suggestion or preference is different from arequirement. Throughout the 30% Watermain Design, differentterms are used. The design document shall clarify whetheror not the City of Elkhart will accept the route describedin the ROD, regardless of their preference or long-rangeplans.

8. Section 2.2.2, p. 5, describes the location of the possibleIndiana Avenue Route extension, but Figure 3 is notconsistent with this description. If the text is accurate,the figure should be revised to show the Indiana Avenueroute extending east to the corner of Nappanee Street andIndiana Avenue.

9. Sections 2.3.1, 2.3.2, and 2.3.3 (pp. 6,10) state thatservice taps will be provided to all homes in the affectedarea. Service shall actually be provided to all users,including residential, commercial, and business users. Thedescriptions in the text shall be revised to reflect this.

10. The Larue Street service area outlined in Figure 4 shall beextended southward to include the area between Larue Streetand U.S. 33.

11. Section 3.1.1, p. 13, 3rd paragraph, shall be revised tostate that Crawford ditch is west of County Road 3 or eastof County Road 1, not east of County Road 3.

12. Section 3.1.5, p. 15, 2nd paragraph, shall describe thezoning for the Elkhart County area directly adjacent toState Route 219 from Indiana Avenue to a point 1557 feetsouth (the area not zoned R-l).

13. Section 3.2, p. 15, and Section 4.1, p. 17, describe thelocation of existing water mains, but not the depth. TheRD/RA Work Plan, Section 2.1, page 2, second paragraph,states that Conrail will verify the depths of existing linesas part of the Pre-Design Study. The depths shall beprovided for design purposes.

14. Section 4.1, p. 17, describes the existing Elkhartdistribution system and states that the system is shown onFigure 8. The written description of the present mainlocations (U.S. 33 W. to Best Ave., N. to Larue St., W. toCR 3) is not consistent with the approximate existing watermain locations shown on Figures 8, 9, 10, 11, 12, 13, 14,15, 16, 17, and 18. These inconsistencies must be resolved.

15. Sections 4.2 and 4.3 provide information on the pump andstorage capacity of the existing Elkhart system. There isno discussion of how these capacities impact the currentdesign for the extension. If the capacity is sufficient tosupply needed water for the proposed extension, then thisshall be stated in the design document.

16. Section 5.1: The design assumptions were documented in thePhased Feasibility Study document. The assumptions wereused to calculate the estimated costs of remedialalternatives described in the ROD. As a result of theremedial design, more accurate cost estimates can becalculated. The design shall comply with current State andlocal requirements.

17. Section 5.2.3, page 23, last paragraph: The term "standalone system" warrants additional explanation.

18. Section 5.2.4, page 23: There appear to be severalconflicting pressure specifications shown here and in theprevious section. Minimum pressures of 20, 30 and 35 psiare stated for various situations. Clarification isrequired on these points and the minimum design pressureshall be stated.

19. Section 5.3, p. 24, 1st paragraph, discusses the desire ofSt. Joseph County and the City of Mishawaka to providemunicipal water from the City of Mishawaka system to theaffected areas in St. Joseph County. Any specificsregarding this approach shall be included in Section 2.Without any specifics, it is premature for U.S. EPA tocomment on this approach. It is Conrail's responsibility todesign an acceptable system that provides a viable andreliable water supply in a timely manner.

20. Section 5.4, p. 25, lists permit requirements for watermaininstallation. The RD/RA Work Plan, Section 6.3, p. 3,describes the information that is required in the 30% designdocuments. Section 5.4 does not describe what informationis required for each permit, what actions Conrail has takento secure those permits and approvals (including contactnames and results) , and what actions Conrail plans to taketo secure the permits and approvals during the next designphase. The design documents shall be revised to includethis information .The RD/RA Work Plan, Section 6.3, p. 3, requires Conrail toreport in monthly progress reports the status of each of theapprovals and permits necessary to implement the remedialaction. None of the monthly progress reports received todate have reported the status of each of these approvals andpermits. Conrail shall revise its monthly progress reportformat to ensure that the required information is includedin each monthly progress report.

One of the purposes of the monthly and design phasereporting of Conrail's efforts and plans to secure allnecessary permits and approvals, is to provide U.S. EPA witha written record and basis to determine if Conrail is;(a) taking all actions necessary to obtain all city, county,state and federal approvals and permits necessary for theRD/RA, and (b) using its best efforts to secure theapprovals from private property owners necessary toimplement the remedial action (see RD/RA Work Plan Section6.0, p. 1).

The 30% design documents and monthly progress reportssubmitted do not include the required information concerningConrail's efforts and plans to secure all necessary permitsand approvals. Therefore, U.S. EPA does not haveinformation that Conrail is in fact; (a) taking all actionsnecessary to obtain all city, county, state and federalapprovals and permits necessary for the RD/RA, and (b) usingits best efforts to secure the approvals from privateproperty owners necessary to implement the remedial action.

21. Section 5.4, p. 25, "A", the review period is for a maximumof 60 days.

22. Section 6.1. A discussion shall be included as toassumptions and design parameters used in modelling with theKentucky pipe model. The discussion shall also include theformulae or other basis for the design model and theaccuracy of this model to real time situations.

23. Section 6.2.2, item 3, page 35. If a pump station isinstalled to boost line pressure in the design pipingscenario developed on this page, it is likely that systempressure will be reduced upstream of the boost station.This will negatively impact system pressure of upstreamresidential areas. The design document shall discuss theseimpacts.

24. Section 6.3, page 41, makes reference to a long dead-endmain. This was not readily apparent from the figurespresented. Additional explanation is required.

25. Section 7. It appears that cost estimates initiated as partof the 30% design report were not complete at the time ofthis submittal. These cost estimates shall be completed.Also, the tables shall be uniquely numbered for reference,and shall be referenced within the text. The explanation atthe top of page 51 does not sufficiently describe whichalternative the estimates are for.

26. Section 8 discusses the difficulties that Conrail has comeagainst in designing the watermain extension, but does notprovide recommendations or describe the future course ofaction that Conrail will take to facilitate design of anacceptable system. This section shall suggest viablesolutions and/or compromises.

27. Drawing X-169-3 does not show all of the County Road 1 areaThe area shown shall be extended southward to include thearea between Tower Hill Road and U.S. 33.

28. Drawings X-169-4 and X-169-5 should show all users betweenthe two areas (Vistula Road and Charles Street areas) , sincethe service areas connect. Either X-169-4 should beextended southward or X-169-5 should be extended northward.Future design drawings shall be such that all users alongthe roadways (East View Drive and Ash Road) in the serviceareas are shown.

29. Appendix C, Specification 12.0, references Figures 16through 19. The reference shall be changed to Figures 19through 22.

30. Appendix B, Correspondence #2, states that the City ofElkhart should not be looking at less than 8" diametermains. The design drawings and material estimates presentedin this 30% Watermain Design document include 6" watermains. This discrepancy must be resolved. If the City ofElkhart requires 8" diameter mains or greater, than thedesign shall be consistent with this requirement.

Editor* *""

31. In text and figures within the document the titles VistulaRoad and Vistula Street are both used; street names shall beconsistent.

32. Section 1.2, p. 3, 2nd paragraph, 4th sentence shallreference Section 6, not Section 5.

Deficiencies of the Design Basis Report And 30% Design For TheGroundwater Extraction/Treatment System, dated April 21, 1993

Genera]

The Statement of Work (SOW) attached to the UnilateralAdministrative Order (Order), on page 4, states that theinterim action ground water extraction/treatment systemshall be designed, constructed, operated, and maintained toprevent horizontal and vertical migration of contaminationand ensure that TCE and CC14 concentrations do not exceed 5ppb outside and downgradient of the area of contamination.The SOW goes on to state that the ground water extractionsystem shall be designed to ensure that the number andplacement of extraction wells will be sufficient tohydraulically contain the contaminant plume. The 30% Designis deficient in that it does not discuss how verticalmigration of contaminants will be prevented. Moresignificantly, the extraction scenarios evaluated do notachieve hydraulic control of the contaminant plume and donot ensure that contaminant concentrations will not migrateoutside or downgradient from the present plume boundaries.The ground water extraction scenarios evaluated within thedesign document must be expanded to include scenarios inwhich sufficient capture is achieved over the designatedareas. Such scenarios shall also take into account morerecent ground water data which provides more accurateinformation on the extent of contamination.

2. The treatability studies conducted for ground watertreatment are of limited use in designing an air strippingsystem. The dynamics of air sparging are different from airstripping, and the results of the sparging tests are notapplicable for stripping tower design. A basis for designneeds -to be provided, including rationale for the number andsize of stripping towers included in the design.

Specific Technical comments

3. Section 1, page 1, 1st paragraph - the rail yard location isdescribed as extending eastward to State Route 19. Therailcar receiving yard actually extends approximately 3000feet east of Route 19.

4. Section 1, page 3, item 4 - this item shall be changed tostate which areas will be restricted to future development.

5. Section 1, page 3, last paragraph - the revised RD/RA workplan was submitted on December 8, 1992, but EPA'sconditional approval was not granted until the January 14,1993 letter.

Section 2, page 4, 1st paragraph - the SOW requires theground water extraction system to ensure thattrichloroethylene and carbon tetrachloride don not exceed5ppb outside and down gradient of the area of ground watercontamination, not at the point of discharge to the St.Joseph River. The limitations for the St. Joseph River willbe determined by the National Pollutant DischargeElimination System (NPDES) permit issued by IDEM.

General Comment 1 above describes the objectives listed inthe SOW; the design document shall be revised to beconsistent with the SOW.

7. Section 2, page 4, last paragraph - states that thepredesign study was conducted according the RD/RA Work Plan.This statement is incorrect. During field oversight,several deviations from the Work Plan were noted, includingdischarge of collected ground water to Crawford Ditch andthe fact that the majority of the annular space surroundingthe pump test well is filled with natural cave, instead ofthe sand filter pack, because of unavoidable caving afterscreen placement. The Design Basis Report shall discuss alldeviations from the U.S.EPA-approved RD/RA Work Plan (otherthan the non-compliant discharge of pump test water, whichhas already been documented by U.S. EPA), provide arationale for why these deviations took place, and discusshow these deviations affect the results of the predesignstudy.

8. Section 3.1, page 6 - identifies the pumping test well asPDPW-1. However, subsequent references in the document arenot consistent, sometimes referring to PDW-1 (e.g., inAppendix A). All references to wells within the designdocument must be made consistent.

9. Section 3.1, page 6, last paragraph - states that a sandpack was placed around the screen of the pumping well.During field oversight, U.S. EPA's oversight contractor,Ecology and Environment Inc. (E&E), noted that significantnatural caving occurred during well installation, and thatpossibly less than 20% of the annular space was actuallyfilled with the sand pack. The report shall be revised tostate this and discuss how this may have impacted the pump

test results.

10. Section 3.1, page 8, third paragraph, and Section 3.2,p. 11, 4th paragraph - discuss discharge of collected groundwater to-Crawford Ditch as approved by IDEM. However,IDEM's letter (which did not "approve" the discharge, butrather stated that the IDEM Office of Water Management didnot object to the discharge) recommended collection of threegrab samples daily for TCE and CC14 analysis. Further, thedischarge was not in compliance with the Order.

The Design Basis Report shall describe how and where thesesamples were collected and shall present analytical results.The only VOC results presented are the daily samplescollected for treatability study purposes.

11. Section 3.2, p. 10 - lists time intervals for water levelmeasurements and references Appendix C. The data providedindicates that measurements were not collected after 20minutes and 15 minutes, respectively, for each step test.Rationale shall be provided explaining why the tests werehalted earlier than anticipated.

12. section 3.2, p. 11, 1st paragraph - lists time intervals forwater level measurements to be recorded by pressuretransducers. Figure 4 (p. 13) does not show measurements atthese intervals. If the figure only shows a representativenumber of measurements, rather than all measurements, thenthis shall be explained. If measurements were not collectedat the intervals originally intended, then an explanationshall be provided as to why this was the case.

13. section 3.3, p. 12, 2nd paragraph - the reference shall bechanged to Appendix C, not D. A revised ground watercontour map, showing how contours had changed duringpumping, shall be included in the revised document.

14. Table 1, p. 14 - shall provide explanation for why data fromPDMW-1-late was not usable.

15. section 3, where appropriate, shall reference analyticaldata presented in Appendix D.

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16. Section 4, p. 17, 1st paragraph - the reference to AppendixE shall be revised to state that the appendix containsprocedures for the treatability testing, and that theseprocedures had been revised as of March 9, 1993, afterapproval of the RD/RA Work Plan. Appendix E does notcontain section 2.3 of the Work Plan.

17. Section 4, p.17, 1st two paragraphs - the terms air spargingand air stripping are not consistently applied in thisdocument. The unit operation for treatment of ground water,as described in the Order and ROD, is air stripping, whichconsists of countercurrent flow of water and air in a packedcolumn. The testing performed in the treatability study wasair sparging: air was bubbled into a flask containingwater. Any reference to full-scale treatment equipmentshall use the term air stripping, while reference to thelaboratory-scale study shall use the term air sparging.

18. Section 4.1.1, p. 17 - as mentioned above, air sparging (ordiffused aeration) and air stripping are differentprocesses. Air sparging is not often used for removal ofVOCs from ground water. Packed tower air stripping iscommonly used for this purpose. Air sparging is lesseffective and more expensive than air stripping. Theresults of the laboratory-scale treatability study using airsparging cannot be used to guide the system design forpacked tower air stripping.

19. Section 4.1.1, p. 17, first bulleted item - incorrectlystates that reduction in pH would result in reduced affinityof site volatile contaminants towards the aqueous matrix.CC14 is a typical non-polar compound, and TCE is onlyslightly polar. Only TCE contains a hydrogen atom, and itdoes not dissociate. For these reasons, pH adjustment wouldnot be expected to alter volatilization of these compounds.

20. Section 4.1.1, p. 17, last paragraph - states that mineralswere analyzed to determine to what extent mineral speciescome out of solution as a function of pH. However,analyzing solubilized minerals will not necessarily provideinformation on the amount of minerals that haveprecipitated. If the evaluation was based on visualobservations of accumulated solids, then this shall bestated.

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21. Section 4.1.2, p. 18 - the discussion of samples isconfusing and unclear. The second sentence shall specifythe wells from which the samples were collected. The fourthsentence shall specify the wells from which these additionalsamples were collected. The fifth sentence shall statewhich samples were composites. The third from last sentenceshall state what parameters were visually noted, and howthese observations were quantified. All samples which werefiltered or unfiltered shall be identified as such.

22. Section 4.1.2, p. 18 - discusses the thorough mixing ofcomposite samples. Mixing most likely resulted in thevolatilization of VOCs from the samples prior to analysis.Therefore, composite sample results are not valid indicatorsof site ground water VOC concentrations.

23. Section 4.1.2, p. 18, last sentence - incorrectly statesthat EPA's oversight contractor (E&E) was present during theentire testing program. It shall be revised to state thatoversight was provided for one day at the analytical testingfacility, and for one day at the treatability testingfacility, to observe and evaluate laboratory procedures.E&E oversight personnel were present during six of thesparging tests.

24. Section 4.1.3, p. 18, last sentence - shall clarify whichsample the second composite was.

25. Table 3, p. 19 - does not list BOD or COD, although theseanalyses are listed in Table 2.3 of Appendix E.

26. Table 4, p. 20 - states that pH was adjusted using 1-10normal 1*2804. The text (p. 22, 1st paragraph) states thateither 1 N or 6 N sulfuric acid was used. The more accuratedescription shall be used consistently in the report.

27. Section 4.1.4, p. 22 - since the procedures for microbialenumeration were not provided in the Work Plan, they shallbe provided in the report for review and comment. Also, thepotential use of bioreclamation at the site has not beendiscussed before, and there is no basis for itsconsideration. Site contaminants are not readily degradedby microorganisms, and field-scale in situ bioremediationhas not been successfully demonstrated at other sites with

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the same contaminants.

28. Section 4.2.2, p. 22 - if samples were open to theatmosphere during pH adjustment, VOCs may have beenreleased, lowering the concentrations. VOC results listedin Table 10 seem to indicate that this occurred. Discussionshall be provided regarding this possibility and its impacton the results of the sparging study.

29. Table 6, p. 23 - is not consistent with analytical resultspresented in Appendix D. Results for TOC, Mg, Na, K,sulfate, chloride, Fe, fluoride, bicarbonate, totalalkalinity, zinc, Mn, copper, total hardness, and TDS differfrom the results in the appendix, and some parameters onTable 6 were not listed in the appendix. The presentationof results shall be consistent.

30. Section 4.2.3, p. 27, 2nd paragraph - the Table referenceshall be changed to Table 11.

31. Section 4.3, p. 34, 1st paragraph - the composite sampleused for the sparging test contained relatively lowconcentrations of VOCs. VOC results from individual wellswere considerably higher (e.g., 89 to 820 ppb for CC14), andother data from the site for wells not discussed in thisreport contained much higher concentrations, many in the ppmrange. The sparging tests were performed on ground watersamples that were not really representative of VOCconcentrations in much of the ground water at the site.

32. Section 4.3, p. 34, fourth paragraph - although pHadjustment may have been time consuming in the laboratory,pH is routinely adjusted in large scale applications withproper mixing and pH measurement. Implementation would notbe difficult on a large scale basis, especially with steady-state conditions of a continuous stream.

33. Section 4.3, p. 35, 2nd paragraph - the first sentence isincorrect. Ground water results collected during the RIindicate significant contamination throughout the site. Thecomposite samples used for the laboratory sparging test arenot indicative of site contamination, for reasons previouslynoted. In fact, the pumping well used for the pump test wasnot located within a portion of the aquifer containing moresignificant contamination, but rather at the edge of

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contamination. Because of the well location, significantamounts of clean ground water were likely extracted,although CC14 concentrations remained relatively stableduring the pump test.

34. Section 4.3, p. 35, 3rd paragraph - the air:water ratiostested in the laboratory will have no bearing on theair:water ratios effective in the field for several reasons

The experimental data showing two conditionswhere contaminants were not reduced to belowdetection limits allows for no conclusions tobe drawn. While the lowest ratio (20:1 intest 6) did show residual contaminants, sodid test 10 at 70:1. Five other 70:1 testsat higher, the same, and lower pH than test10 removed contaminants to below detectionlimits. Furthermore, the residualconcentrations in test 6 were significantlylower than test 10. Thus, no specificconclusions about the 20:1 ratio can be made.

If a simple batch air sparging system is tobe used full scale, the results from thelaboratory scale are not directly scaleable,since mass transfer rates can varytremendously with size. Generally, masstransfer is much more difficult (i.e.,stripping is less) with larger scale systems.

The full scale system would likely be acontinuous system, such as a packed tower.These batch data do not directly apply tocontinuous systems.

35. Section 4.3, p. 35, 4th paragraph - the increase indissolved CO2 with decreasing pH indicates that carbonateswere being dissolved from the sediment. This would accountfor the "buffering" observed. Less buffering would beobserved if the ground water was prefiltered.

36. Section 4.4; p. 35 - again, the claim that VOCconcentrations were very low is inaccurate, for reasonsstated above. The lowest results available were used, andthe representativeness of these results is highlyquestionable.

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37. Section 4.4, p. 36, 3rd paragraph - the next to lastsentence is incorrect. The minimum solubility of thesemetals occurs at different pHs; usually the higher the pH,the lower the solubility. For the test runs performed, theminimum solubility of the metals would be at 7.74 pH, butnot necessarily in general.

38. Section 4.4, p. 36, 4th paragraph - bioreclamation for thesecompounds would be difficult to achieve without acosubstrate. Addition of a cosubstrate (e.g., methane,phenol, or an aromatic) for in situ treatment for suchwidespread contamination would be extremely difficult toimplement.

39. Section 5.1, p. 38, 1st paragraph - the reference to Table12 is incorrect; the table does not provide the statedinformation.

40. Section 5.1, p. 38, 2nd paragraph - the decrease in VOCconcentrations was not significant for CC14, nor was it asteady trend during the pump test. Dynamic results are notnecessarily indicative of site contaminant responses topumping, due in part to the location of the pump test well.

41. Section 5.1, p. 38, 3rd paragraph - see above comment.Boring logs prepared during installation of the pump testwell and the observation well indicate that significantvapor readings were detected at the observation welllocation at the water table. Significant readings were notdetected at the pump test well location. Ground water datacollected by E & E during the RI indicates significantcontamination northeast of the pump test well location. Thelower VOC concentrations seen in samples from the pump testwell, compared with other ground water results at the site,support the contention that the pump test well was notlocated within the most contaminated portion of the aquiferbeneath the site.

The text is not clear about what VOC concentrations wereused for design, and to which values 20% was added. Thetext must be made much more explicit as to which maximumconcentrations the treatment system is being designed forand why those values are being used. Even using the limiteddata provided in table 15 (p. 39), the values listed inFigure 5 (presumably the design criteria) are significantlylow. In summary, the values currently considered for designpurposes are not at all conservative, even with the 20%

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contingency added to the concentrations. Other ground-waterdata must be considered for design purposes.

42. Section 5.1, p. 38, last paragraph - no TSS values arepresented in the text or in table 16. It is unclear how TSSvalues from residential well samples will be used to confirmthe design approach for inorganic compounds.

The samples collected for TSS analysis shall be from wellsor spigots without carbon filters or prefilters.

43. Table 15, p. 39 - the percent reduction, based on PDW-72results vs. other well results is a meaningless andmisleading calculation. These results shall not be used fordiscussing the decrease in contaminant concentrations due topumping.

44. Table 16, p. 40 - the PDW-72 sample shall be noted as towhether it is filtered or unfiltered.

45. Section 5.2, p. 41, last paragraph - provides no discussionof the impact of significant discharge to Crawford Ditch.The design document shall discuss how the discharge willimpact the ditch, what the capacity of the ditch is, how theditch would respond to storm events simultaneous with groundwater discharge, how discharge may impact ground water flowin the vicinity of the ditch, and what actions, if any, willbe needed to mitigate any negative impacts of the discharge.(Note that in the ROD, Appendix B, Responsiveness SummaryComment 7, a resident was concerned about water backed up inhis basement from Crawford Ditch. Such impacts must beconsidered.)

The negative impacts of discharge to Crawford Ditch may besignificant. Therefore, the revised 30% design documentsshall include a contingency plan that is 30% complete forlocating the water treatment facility near the St. JosephRiver to discharge treated water directly to the St. JosephRiver.

46. Table 17, p. 42 - the anticipated discharge limits forchloroform and CC14 seem high. Actual discharge limits willbe established by the State of Indiana.

Inorganics shall be included on Table 17, since they are adesign criteria in the following Figure 5.

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47. Sections 5.3, 5.4, p. 43 - discuss flow rates for treatment.These flow rates are not evaluated until Section 6. Itmight be more appropriate to position the current Section 6before the current Section 5.

48. Section 5.4.2, p. 45 - the stripping of CC>2 is not themechanism of iron removal. Iron is removed because theaeration oxidizes the ferrous iron dissolved in the groundwater to ferric iron. Ferric iron will precipitate out evenat neutral pHs. Thus, pH increase through C(>2 removal (anexpected negligible increase) does not accelerate ironremoval. Most likely, ferrous sulfate will notsignificantly precipitate as aeration is very effective inconverting all ferrous iron to ferric iron. There isinsufficient data or discussion of results to determine ifdissolved iron must be removed with a pre-aeration step,rather than simply removing the suspended material in orderto avoid fouling a packed column.

49. Section 5.4.2, p. 45, last paragraph - the cleaning processshall be described; if this alludes to periodic washing ofthe packed column to remove scaling then this -shall bestated.

50. Table 18, p. 46 - the chemical additions column shallexplain what "most" indicates for cartridge filters andcyclones (vs. yes or no for other types).

51. Section 5.4.3, p. 48 - provides no discussion of the needfor air emission control. The design basis influent VOCconcentrations (ones that are more indicative of siteconditions than provide in this document) shall be used todetermine the need for air emission control. An estimate ofthe pounds of Volatile Organic Compounds (VOCs) shall bemade. The revised 30% design documents shall includecontrol equipment specifications and costs.

52. Section 6 - shall consider the impacts of the Suburban wellfield on ground water extraction scenarios, and shall alsoconsider the impact that discharging treated ground water toCrawford Ditch will have upon ground water extractionscenarios. Even if these impacts are determined not to besignificant, this shall be stated in the design basisreport .

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53. Section 6.1.1, p. 49, 2nd paragraph - the text shall specifywhether the 0.3 "aquifer porosity" is actually the effectiveporosity. The value listed 0.30, would be consistent withthe 30% storage calculated from the pump test data;comparison of these values would be appropriate here.

54. Section 6.2.1, p. 51 - states that "good agreement" wasobserved between the model and field-determined elevations.In fact, field elevations shown are consistently high(approximately 2 feet); the model could have been adjustedto more accurately reflect contours.

55. Section 6.1.3, p. 51 - the description of the objective ofthe extraction system shall be revised, based on GeneralComment 1 above.

56. Section 6.1.3, p. 51, 3rd paragraph - significant gaps inthe capture zones are observed for all scenarios presented.The extraction scenarios shall be reevaluated, usingadditional wells and/or higher extraction rates, ifnecessary, to obtain capture over the entire zone outlinedin the ROD.

57. Figures 8 through 12 shall indicate flow rates at eachextraction well.

58. Section 6.1,3, p. 54, last paragraph - these scenarios donot meet the ROD-specified objectives. The revised 30%design documents shall include scenarios that do achievethese objectives.

Recent sampling of a residential well located at 10186Charles Avenue had a detection of Trichloroethylene at25ppb. the resident stated that the well was 120 feet deepThis area shall be included in the capture area.

59. Section 6.2, p. 59, 1st sentence - because of the verticalhydraulic connection of the aquifer, extraction from athinner zone may not significantly affect overall plumecapture, vs. extraction from the entire thickness of theaquifer. The 60% design shall include three-dimensionalmodeling to evaluate selective screen length scenarios.

19

60. Section 6.2, p. 59, 2nd paragraph - any future modelingshall be conducted with better boundary conditions,particularly to the west of the site, in the vicinity ofBaugo Bay. The location of constant head nodes and adiscussion of how they were established shall also beprovided. Also, the impact, if any, of the Suburban wellfield or significant discharge to Crawford ditch shall beincorporated into modeling.

61. Section 6.3, p. 60 - Drawing Y3 shall be referenced as beinglocated in Appendix J.

62. Section 6.3, p. 60, 2nd paragraph - the discussion of theuse of right-of-ways for pipeline placement shall berevised, as described on p. 62.

63. Figures 13 and 14 - the locations shown for existing watermains are not consistent with the descriptions of thesemains provided in the 30% Watermain Design document. Actuallocations shall be indicated on the Figures.

64. Section 6.3, p. 63, last sentence - reference to the detailsof the extraction piping was not made in the alternativewater system preliminary design document, as stated here.

65. Section 7.1, p. 65, - The revised 30% design documents shallinclude a contingency plan that is 30% complete for locatingthe water treatment facility near the St. Joseph River todischarge treated water directly to the St. Joseph River(see #45).

66. Section 7.1, p. 69, Site 5 - the restrictive covenants shallbe described and discussed.

67. Section 7.1, p. 69, Site 6 - Table 20 listed a requirementof a special use permit for this site. The disadvantagesection for Site 6 shall be corrected to include thisinformation; Further the negative impact of the volume ofdischarge water to Crawfordfs Ditch shall also be discussed,

68. Appendix F - why are these analytical results tablesprovided here? They shall be relocated in a moreappropriate location and shall be referenced in the text.

20

69. Appendix H. - estimated costs for treatment of air emissionsfrom the air stripper shall be included.

70. Appendix K, specification 9.2.1 - states that an additionalwell and greater flow rates are needed. The design documentprovides no discussion of this additional well, althoughextraction scenarios that were evaluated indicate thatadditional wells shall certainly be considered.

71. Appendix K - are some specifications missing? The lastspecification ends in mid-sentence. A complete set of specsshall be provided.

72. Appendix J, Drawing P2, if treatment is deemed necessary forthe air stream emissions, the necessary equipment andinstrumentation shall be included here.

Editorial

73. In general, all tables, including those in appendices, shallbe uniquely numbered for reference purposes.

74. Appendix F, Table 3 - 2nd sample ID shall be MW-8S.

21

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENTUKINK1NG WATEK BRANCH

PUBLIC WATER SYSTEMAPPLICATION FOR CONSTRUCTION PERMIT

3271AC8-3-3<a)

Hermit Number:

Date Received by IDEM:

1. Name of Public Water System and I'WSID Number:

2. Address (where permit is to be sent): 3. Telephone Number:

4. City: 5. Zip Code: 6. County:

7, Name of Person who is to receive Permit (Mayor, Town Board President or Owner/Operator):

8. Location of Project:

9. Brief Description of Project (use extra sheet if necessary):

10. Is This Project Funded By:

Indiana Department of Commerce:Farmers Home Administration:

Other (please specify):

Yes D

Yes D

oror

No D

No D

11. Certification by Design Engineer:I hereby certify that 1 am familiar with the information contained in this application and that to the best ofmy knowledge and belief such information is true, complete and accurate.

Engineer Signature: Date: P.E. Seal:

12. Firm: 13. Telephone Number.

14. Address:

Approved by State Board of Accounts, 1992 Turin *;1606H(K2 2 92)

Public Water SystemApplication for Construction Permit327IAC8-3-3(a)

Page 2

NOTE:THE APPLICATION WILL BE RETURNED IF NOT ACCOMPANIED WITH THEREQUIRED FEE UNLESS THE APPLICANT IS EXEMPTED UNDER 327 (AC 8-3-7(a)

15. CONSTRUCTION PERMIT FEE SCHEDULE

b.

New Public Water System Treatment Plant:Groundwater:

Up to 500,000 gallons per dayGreater than 500,000 gallons per day

Surface Water:Up to 500,000 gallons per dayGreater than 500,000 gallons per day

Public Water System Treatment Plant Expansion:Up to fifty percent (50%) design capacity:

Up to 500,000 gallons per dayGreater than 500,000 gallons per day

Greater than fifty percent (50%) design capacity:Up to 500,000 gallons per dayGreater than 500,000 gallons per day

c. Other Water Treatment Facilities:WellsPump or Pump StationChemical AdditionStorage Tank

Miscellaneous Process Modification

d. All Water Distribution System:2,501 -5,000 linear feet5,001 - 10,000 linear feetGreater than 10,000 linear feet

$ 875 D$ 1,750 G

$ 1,250 D$ 2,500 D

$ 625 Q$ 1,250 D

$ 1,250 Q$ 2,500 Q

$ 500 D$ too n$ 250 D$ 200 G$ 50 per process G

$ 150 G$ 250 Q$ 500 a

16. Water Main Construction (New or Keplacement)

Is this project for a water main extension?(If yes, you MUST ALSO complete Attachment A)

Yes G No G

17. New Well(s) Construction, Replacement or Rehabilitation (Briefly describe the type, size, pumpagegpm,total dynamic head):

18. New Water Treatment Facilities (Briefly describe the treatment type, size, capacity):

SULuFurm #U5058<Kl» 2 92)

Public Water SystemApplication for Construction Permit Pace 3327IAC8-3-3(a) *19. New Distribution System Facilities (Briefly describe the storage tanks, boosters stations):

20. Identification of Potentially Affected Persons:

The Administrative Adjudication Act requires thatthe Department of Environmental Management(DGM) give notice of its decision on your applicationto the fol lowing persons:

a. each person to whom the decision is specificallydirected;

b. each person to whom a law requires notice to begiven;

c. each competitor who has applied to the DEM fora mutually exclusive license, if issuances is thesubject of the decision and the competitor'sapplication has not been denied in an order forwhich all rights to judicial review has beenwaived or exhausted;

d. each person who has provided the DEM with awritten request for notification of the decision;

e. each person who has substantial and directproprietary interest in the issuance of the(permit) (variance);

f. each person whose absence as a part in theproceeding concerning the (permit) (variance)decision would deny another party completerelief in the proceeding or who claims an interestrelated to the issuance of the (permit) (variance)and is so situated that the disposition of thematter, in the person's absence may;

1. as a practical matter impair or impede the ^^persons ability to protect that interest, or

2. leave any other person who is a party to aproceeding concerning the permit subject toa substantial risk of incurring multiple orotherwise inconsistent obligations by reasonof the person's claimed interest.

1C 4-21.5-3-5(0 provides that we may requestthat you assist us in identifying these people.Our failure to properly identify and notify thesepeople of the decision could result in voiding thedecision which is made.

WList below persons'whom you have reason to believe have a substantial or proprietary interest in this matter, orcould otherwise be considered to be potentially affected under the law. Failure to notify a person who is laterdetermined to be potentially affected could result in voiding our decision on procedural grounds. To ensurecon for ma nee with the Administrative Adjudication Act and to avoid reversal of a decision, please list all suchparties and provide mailing labels to expedite the process. (Use additional sheets if necessary.)

Nnmo

Street

Pity, Slat*, 7ip

Name

Street

Titv, Rfc.t*, ftp

SuteKorm#J5058iK^ 2 92)

Public Water SystemApplication for Construction Permit Pace 4327IAC8-3-3(a)

NameStreetCity, State, Zip

NameStreetCity, State, Zip

NameStreetCity.State.Zip

NameStreetCity.State.Zip

NameStreetCity, State, Zip

NameStreetCity, State, Zip

[certify that to the best of my knowledge ! have listed all potentially affected parties, as defined by 1C 4-21.5,known to me. If "NONE" is indicated it signifies that no such parties exist.

Public Water System Public Water SystemOfficial Signature:_________________;_____ Name: ______________________________

Name ofOfficial (Printed): ____________________ Date:

Application Approved: ri Date _________ Application Denied: Q Date

THE COMPLETED APPLICATION, ALONG WITH ALL REQUIRED FEESAND ATTACHMENTS SHOULD BE MAILED TO:

CASHIER'S OFFICEPUBLIC WATER SYSTEM

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT105 South Meridian Street

P.O. Box 7060Indianapolis, Indiana 46206*7060

Stale Form * U505B < K'2 2 92)

Public Water SystemCheck List for Construction Permit ATTACHMENT A327 IAC 8-3-3U)1 . Water Main Construction;

ApplicableAWWA Standard Class

a. Pipe Material

Ductile Iron DPolyvinyl Chloride DOther D

b. Length of oioe:

c. Type of Joint: Push-On D Mechanical D Other O

d. Is minimum "Depth of Cover" in conformancewith the frost penetration map? Yes D

e. Is the size of the proposed water mainunder 6 inches? (If Yes, please explain) Yes G

f. Is the size of the proposed water mainproviding fire protection and servingfire hydrants at least 6 inches? Yes D

g, Is the proposed pressure/ leakage testingin conformance to AWWA Standard C600-87? Yes D

h. Is the proposed disinfection procedurein conformance to AWWA Standard C65I-86? Yes D

i. Will the fire hydrants and water mains ateach tee, bend and dead end be properlyblocked or anchored? Yes D

j. Will the installation procedure (bedding,haunching backfill, making joints, etc.)meet AWWA or Manufacturers" specifications? Yes D

2. Design Specifics and Plans:

a. Will a minimum of 10 feet horizontal clearancebe maintained wherever the water mains andsewers (including storm sewers) run parallel? Yes D

b. Will a minimum of 18 inches vertical clearance bemaintained wherever the water mains and sewers(including storm sewers) cross each other? Yes Q

c. Are required stream crossings designed inconformance with 10 States Standards? Yes D

d. Are valves provided at each intersection or notmore than 500 foot intervals? (If not, pleaseexplain). Yes Q

e. Are hydrants provided at each intersectionor at intervals not exceeding 600 feet?(If not, please explain.) Yes D

Page 1

PressureRating

No D

No D

No D

No D

No D

NO a

No D

NO a

NO a

NO a

NO a

NO a

FOROFFICE

aaaaaD

aN^

aaa

a

a '*^f

a

a

a

a

aSlutr Ki 2 9!>i

Public Water SystemCheck List for Construction Permit327 IAC 8-3-3(a)

ATTACHMENT A Page 2

2. Design Specifics and Plans (con't.):

f. Is there a history of external corrosionproblems with buried pipe in project area?If Yes, explain corrosion protectionmeasures: Yes Q No D

Polyethylene Encasement D Other

3. System Design Data:

a. Number of existing service connectionsserved by the present supply.

b. Number of service connections served bythe water main extension.

c. Will the normal operating pressure onthe proposed water main extension be60 psi and not less than 35 psi? (If not,please explain.)

d. Is the existing distribution system capableof delivering adequate water to theproposed main extension?

e. Is the diameter of the proposed watermain the same size as the existing atthe point of connection? (If not, pleaseexplain).

Yes D No D

Yes D No

Yes D No D

4. Plans and Specifications:

a.

b.

c.

One (1) complete set of final plans suitable for reproduction(24" x 36" - standard size) and a set of specifications submitted.

Each and every page of the plans must be signed and sealed,as well as the cover page of the specifications by a professionalengineer who is registered in the State of Indiana.

A master plan of the public water system distribution systemand the site plan of the proposed projects.

D

D

a5. A list of names and addresses of all persons or parties who may be

potentially affected by the construction of this project.

a. All persons whose property is adjacent to the construction site.

b. AH persons with a substantial and direct proprietary interest inthe issuance of this permit such as nearby businesses who couldhave their business in some way affected by the issuance of theconstruction permit.

The failure to properly identify and notify these people could have the result of voidingany decision made regarding this permit.

DD

D

SuiwFyrm #35058(R2-2 92)

Public Water SystemCheck List for Construction Permit ATTACHMENT A Page 3327lAC8-3-3(a>6. Certification to Furnish Water (This section must be completed):

The ___,————————————————————————————————————————__ has agreed to(City, Town, Village, Water Company or Water Authority)

furnish water to the area in which water main extensions are proposed by

_____ according to plans titled "___________________ "(Developer)

and prepared by _________________________________ . The undersigned(Engineering Firm)

acknowledges the public water supplier's responsibility for examining the plans and specifications to

determine that the proposed extensions meet local rules or laws, regulations and ordinances.

Date: By:

(Signature of Authorized Public WaterSystem Official)

Public WaterSystem Name: ______________________ Tit|e:

FOR AGENCY USE ONLY

Name of Reviewer:

Date review started:

Date information requested: _____________________ Date received:

Date of second information requested:________________ Date received:

Date review completed: _______________________

Stale Korm *J5058iK2 2 92)