ILLINOIS POLLUTION CONTROL BOARD
November 7, 2005
SANGAMON VALLEY FARM
SUPPLY,
Petitioner,
v.
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY and
VILLAGE OF SAYBROOK, ILLINOIS,
Respondents.
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PCB 06-43
(Water Well Setback Exception)
HEARING OFFICER ORDER
Petitioner is directed to file written responses to the following questions with the Clerk of
the Board no later than 14 days before hearing.
Questions for Sangamon Valley Farm Supply
Pertaining to the Petition Received 9-19-2005
and
Agency Recommendation Received 10-11-2005
(Docket PCB 2006-43)
35 IAC 106.310 (b)
1.
Since the Illinois Environmental Protection Agency (Agency) in its recommendation has
identified two additional well setbacks that are impacted by the petition, would you
please provide a revised economic analysis for options designed to meet the Class I
groundwater standards within the minimum setback zones.
2.
a. Do groundwater-monitoring results indicate the hydrocarbon plume is continuing to
migrate closer to the community water supply (CWS) Well #3?
b. Could you please describe how the plume is migrating in relation to the other two
CWS wells?
3.
a. What method will SVFS use to prevent the lateral migration of the contaminant
plume during the injections?
b. Exh. M letter from Regenesis suggests a “barrier-based design along either side of the
street.” Exh. M at 2. Please describe how barriers will be created between Well #3
and the plume?
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c. Could you please describe if you have plans to use barriers between the plume and
the other two CWS wells.
4.
As mentioned in the Agency’s Recommendation on page 7, to demonstrate the
effectiveness of ORC injections, could you please provide more recent monitoring results
to demonstrate ORC injections have been effective at this site.
5.
Exh. E Letter from the Agency dated 2-27-2003, shows that modifications were made to
SVFS’s High Priority Corrective Action Plan. Modifications required additional soil and
groundwater sampling analysis prior to implementing another round of ORC injections.
“These additional samples will demonstrate whether the contamination beneath the
neighboring properties had been remediated below the Tier I Remediation Objectives.”
Exh. M, Att. A. Has such additional sampling been done to show the status of
contamination beneath the neighboring properties?
6.
a. How many series of ORC injections are planned after the second followup round of
injections?
b. How long is the waiting period before more follow-up injections would be planned?
c. What criteria would SVFS use to determine if additional rounds of injections were
needed?
d. For how many consecutive quarters, with no exceedences of the groundwater
standards or 35 IAC 742 remediation objectives, does SVFS plan to go before
discontinuing groundwater remediation efforts?
e. Please describe SVFS’s monitoring plan to ensure adequate rounds of quarterly
sampling to detect contaminant rebound which might occur several months or year
after the injections?
7.
The Agency Recommendation states, “The BAT [Best Available Technology] to address
concerns about ORC, is groundwater monitoring.” Ag. Rec. at 7.
a. Could you please develop a monitoring plan and schedule for the continuing
remediation?
b. In your monitoring plan, could you include how you will demonstrate the ORC
injections are having the desired effects and not creating unintentional negative
impacts to the aquifer and CWS wells?
c. Could you indicate your monitoring parameters for the monitoring wells and the
CWS wells, such as: contaminants of concern, oxidation-reduction potential, pH,
dissolved oxygen, nitrate, total and dissolved iron, sulfate, methane, chemical oxygen
demand, and manganese?
d. Will your monitoring program also include quarterly raw water monitoring for the
CWS wells as suggested by the Agency? Ag. Rec. at 10.
e. In your schedule, could you show milestones such as timeframes for injections,
groundwater sampling, and compliance with the groundwater standards and 35 IAC
742 Remediation Objectives?
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8.
Once groundwater remediation efforts have achieved compliance with the groundwater
standards and 35 IAC 742 remediation objectives, do you foresee any problems with
having the setback exception expire?
35 IAC 106.310(c)
9.
Page 11 of the petition indicates, “The closest edge of the current contaminant plume to
the community water supply well is approximately 115 feet east of the municipal well.”
(Pet. at 11.) The petition on page 3 also states, “…a portion of the current shallow
groundwater contamination had migrated to within approximately 75 feet of the existing
community water supply well … .” (Pet. at 3.)
a. Would you please clarify how close to all three CWS wells contamination was found.
b. Regarding Well #3, the petition on page 11 states that “55 to 60 injection locations
appear to be within the setback of the municipal well.” Exh. C & D show previous
injection locations. Could you please provide a similar diagram showing the possible
locations for the second round of follow-up injections?
c. What will be the distance between the CWS wells and the closest injection point?
d. Would you please indicate what maximum alternative setback would be utilized, i.e.,
how far from the CWS wells was/will the nearest injection be located?
35 IAC 106.310(d)
10.
a. Will other products be injected along with the ORC?
b. Besides the ORC, will microbes, nutrients and water also be injected?
c. Would you please provide an MSDS for ORC and identify what microbes and
nutrients will also be used?
11.
Exh. G Letter from the Agency dated 12-20-2004 requires that SVFS’s Corrective Action
Plan include “documentation that injection of the chemical, or the impact of the treatment
on existing soil and groundwater, will not cause an exceedence of the primary drinking
water regulations at 35 Ill. Adm. Code 611 during or after remediation … .” Exh. G, Att.
A. Has such documentation been submitted yet to Agency? Would you please provide a
copy for the record here?
415 ILCS 5/14.2 (b), (c), (d)
12.
The petition refers to the 200-foot setback of the CWS well and focuses its discussion on
activities inside a 200-foot radius from the well. Since the 400-foot setback applies to all
of the Saybrook CWS wells, please identify how many injections points (previous and
proposed) are located within the 400-foot setback zones.
415 ILCS 5/14.2(c) and 415 ILCS 30/6b
13.
Under the Illinois Water Well Construction Code, 415 ILCS 30/6b, if a well is
contaminated, owners and operators of the contamination source or route are responsible
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for providing an alternative source of potable water. Based on these requirements, please
discuss the contingency planning between SVFS and the Village of Saybrook. As
suggested by the Agency, will you be providing a plan for regular meetings with
Saybrook water supply personnel? Ag. Rec. at 10.
14.
a. Will SVFS work with the Village to do additional sampling of the CWS wells during
the injection and follow up periods?
b. The Agency expressed concern that the ORC might change the character of the
potable groundwater before, during and after drinking water treatment. Ag. Rec. at 9.
In order to detect potential impacts, has SVFS made any arrangements with the
Village to monitor the CWS wells for components that will be injected via the
Geoprobes or for changes in groundwater quality?
c. If not, please explain how the Village’s current monitoring would be sufficient.
d. If testing confirms injected materials, hydrocarbons, or byproducts of the ORC
injections are detected in the CWS wells, what will the course of action be?
15.
a. What is the population served by CWS Well #3?
b. Has SVFS consulted with the Village to determine if another water supply is
available besides CWS Well #1, #2, and #3?
c. If so, please describe how it compares to CWS Well #3 in terms of quality and
quantity and its suitability to serve as a temporary alternate water supply.
415 ILCS 14.2(c)
16.
Pet. at 12 indicates that a survey was conducted to identify all potable water supply well
owners within the setback area of the proposed ORC injection wells. Please provide a
copy of the survey, indicating the radius of the survey area from the injection locations,
how the survey was conducted, and if any other potable wells were identified.
415 ILCS 14.2(f)
17.
Please discuss if the county or Village of Saybrook have ordinances that might be more
stringent than the prohibitions of 415 ILCS 5/14.2.
Petitioner may contact the hearing officer with any questions or requests for clarification.
IT IS SO ORDERED.
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_____________________
Carol Webb
Hearing Officer
Illinois Pollution Control Board
1021 North Grand Avenue East
P.O. Box 19274
Springfield, Illinois 62794-9274
217/524-8509
webbc@ipcb.state.il.us
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CERTIFICATE OF SERVICE
It is hereby certified that true copies of the foregoing order were mailed, first class, on
November 7, 2005, to each of the persons on the attached service list.
It is hereby certified that a true copy of the foregoing order was hand delivered to the
following on November 7, 2005:
Dorothy M. Gunn
Illinois Pollution Control Board
James R. Thompson Center
100 W. Randolph St., Ste. 11-500
Chicago, Illinois 60601
Carol Webb
Hearing Officer
Illinois Pollution Control Board
1021 North Grand Avenue East
P.O. Box 19274
Springfield, Illinois 62794-9274
217/524-8509
webbc@ipcb.state.il.us
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PCB 2006-043
Joey Logan-Wilkey
IEPA
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
PCB 2006-043
Charles J. Northrup
Sorling, Northrup,Hanna,Cullen & Cochran
Suite 800 Illinois Building
607 East Adams, P.O. Box 5131
Springfield, IL 62705
PCB 2006-043
Mayor Ronald Stauffer
Village of Saybrook
234 W. Lincoln Street
P. O. Box 357
Saybrook, IL 61770-0357
