BEFORE THE POLLUTION CONTROL BOARD

OF THE STATE OF ILLINOIS

SANGAMON VALLEY FARM SUPPLY,

)

1

Pctit~oner,

)

1

v.

)

PCB

06-43

1

ILLINOIS

ENVlRONMENTAL

)

PROTECTION AGENCY

and

1

VILLAGE OF SAYBROOK,

ILLINOIS,

)

1

Respondents.

)

RESPONSE TO POLLUTION CONTROI, BOARD OUESTIONS

NOW COMES the petitioner,

SANGAMON VALLEY FARM SUPPLY ("SVFS"), by and

through its attorneys, Sorling, Northrup,

Hanna,

Cullen

and Cochran,

Ltd., Charles J.

Northrup,

of counsel,

and hereby responds to

the questions

ofthe Hearing Officer, as outlined in the May 4,

2006, Hearing Officer Order. Each question posed by that Order will be repeated herein, with

the

respotlsc of

the petitioner immediately following the

yuestion.

1. The Letter from the Agency dated February 7, 2003

attacbed to the amended petition

as Exhibit E, 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 beiow the Tier I Remediation Objectives."

Exh.M, Att.

A.

Has such

additional sampling been done to show the status of

contamination beneath

tile

neighboring properties?

In April 2003, additional soil sampling was performed to determine if soil

contarnination was

still present above current cleanup standards. Soil

borings were performed in the vicinity of

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MW-7 and in the County Right-of-way between the

liigliway and the facility. Soil samples

collected

from these

borings did not show soil contamination at concentrations exceeding 35

IAC

742

cleanup objectives. Groundwater sampling was

performed on a quarterly basis

following the injections. The status of the groundwater contamination has been shown on Exhibit

A.

2.

The amended petition indicates that the second corrective action plan amendment and

budget included a second follow-up round of injections. Am. Pet. at

5-6

a. How may series of ORC injections are planned after the second follow-up round of

injections?

It is our hope that no additional rounds of ORC injections will be needed after the second follow-

up

round. However,

if

analytical data collected from groundwater samples indicates the

containii~ant

levels have not decreased to acceptable levels, one or two additional rounds of ORC

injections will likely need to be performed.

b.

How

long is the waiting period before more follow-up injections would be planned?

The groundwater sample results will be reviewed and evaluated after each quarterly sampling

event by Regenesis engineers. If Regenesis indicates an additional round of injections will

likely

be necessary, the Corrective Action Plan and Budget Amendment will be filed with IEPA for

approval prior to proceeding.

c.

What criteria would SVFS use to determine if additional rounds of injections were

needed?

The criteria are simple

--

if the rate of contaminant concentration reduction is

shown to slow

down and the

containinant levels are shown to level off, the additional rounds of injections will

be needed.

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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?

Quarterly groundwater sampling is planned at this facility until analytical results show no

exccedences of the groundwater quality standards. Quarterly groundwater sampling will continue

until four consecutive

sampling events

show no exceedcnces of the groundwater

quality

standards. At that time, SVFS will request to discontinue the groundwater monitoring and

receive a "No Further Remediation" letter.

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?

The primary source of contamination (the leaking underground

storagc

tank) has been removed

from the site and is no longer contributing to

groundwatcr contamination. The secondary source

of contamination (the contaminated soils in the immediate vicinity of the former underground

storage tank) has also been removed from the site. Soil

samples

collected on either side of the

highway have shown that soil contamination is not present at

levels above 35 IAC 742

remediation objectives. Based on groundwater sampling to date, it appears the groundwater

moves rather quickly in this area (as shown by the rebound of contaminant concentrations in

MW-7 due to movement of

the

groundwater

from

under

the

highway).

If groundwater

contamination above

35

IAC 742 remediation

objcctives is not identified in four quarterly

sampling events, it is highly unlikely the contaminant concentrations

will rebound in the future.

3.

The Agency Recommendation states, "The BAT [Best Available

'Cechnology] to address

concerns about ORC, is groundwater monitoring." Ag. Rec. at 7.

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a.

Could

you

please develop a monitoring plan and schedule for the continuing

remediation?

Twelve monitoring wells (MW-1 through MW-5 and MW-7 through MW-13) will be sampled

on a quarterly basis.

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?

Twelve monitoring wells

(MW-I through MW-5 and MW-7 through MW-13) will be sampled

on a quarterly basis. In addition, a raw water sample will be collected from CSW Well

#3.

Village personnel will contact SVFS when

either CWS Well

#1 or Well

#2 is brought on-line. If

either well is brought on-line, a raw water sample will be collected and submitted for analysis.

All

san~ples

will be analyzed for the contaminants of concern (benzene, ethylbenzene, toluene,

total xylenes, and

MTBE). The analytical results will be reviewed against previous analytical

results.

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?

All of the water samples collected will be analyzed for the

coutamlnants of concern (benzene,

ethylbeuzene, toluene, total xylenes, and MTBE), 5-day biological oxygen demand, chemical

oxygen demand, total and dissolved iron, total and dissolved manganese, nitrate, sulfate and

methane. On-site readings collected for

each water sample will include temperature, dissolved

oxygen concentration, pH, and oxidation-reduction potential.

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d. Will your monitoring program also include quarterly raw water monitoring for the

CWS wells as suggested by the Agency? Ag. Rec. at 10.

As stated previously, a raw water sample will be collected from CWS Well

#3 during each

quarterly

sampling event. Groundwater

samples will only be collected from CWS Wells

#1 and

#2

if they are brought on-line by Village personnel for temporary use.

e.

In your schedule, could you show milestones such as timeframes for injections,

groundwater sampling, and compliance with the grouudwater standards and 35

IAC 742 Remediation Objectives?

It is difficult to project when injections will be performed as all proposed work is contingent

upon approval of this petition and approval of a Corrective Action Plan and Budget Amendment.

We foresee performing the injections within 30 days of approval of this petition

and

approval of

a Corrective Action Plan and Budget Amendment. In the interim and until the

end of required

remediation, quarterly groundwater samples will be collected for analysis. It is also difficult to

project when groundwater sampling will show compliance with the groundwater standards and

35 IAC 742; however, we hope that the levels can be reached within 12 months of the next set of

injections.

4.

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?

If grouudwater sampling shows that remediation efforts have achieved

compliauce with the

grouudwater standards, the only additional

work projected in the area will be the eventual

abaudoument of the monitoring wells. Once the monitoring wells have been abandoned, the

setback exception could expire.

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5.

Page

12

of

the amended

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..

.

."(Am. Pet. at 4.)

Please clarify

how close to all three CWS wells contamination was found.

During the sampling

event on

October 9, 2002,

the

leading

edge of

the

groundwater

contamination

pl~line

was extrapolated to be approximately 60 feet from CWS Well #3. The

leading edge has since receded to approximately 115 feet from Well #3. During the sampling

event on October 9, 2002, the edge of the groundwater contamination plume was extrapolated to

be approximately 195 feet from CWS Wells

#l and #2. The edge of the plume has since receded

to approximately 235 feet from Wells

#1 and

#2.

6.

Will other products be injected along with the ORC?

The only material to be injected with the ORC is water. No microbes or additional nutrients will

be added.

a.

Besides the ORC, will microbes, nutrients and water also he injected?

The only material to be injected with the ORC is water.

b.

Would you please provide an MSDS for ORC and identify what microhes and

nutrients

will he used?

A copy of the MSDS for the ORC to be used is provided as Exhibit

F.

7.

A Letter from the Agency dated

12-20-2004

attached

to the amended petition as Exhibit

G

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

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not

cause an exceedence of the primary drinking water regulations at

35

111. Adm. Code

611 during or after remediation.

..

."

Exh. G, Att. A.

Has such documentation

been

submitted yet to the Agency? Would you please provide a copy for the record here?

That specific documentation has not been provided. However, we do not believe we can

make

that assertion. We have designed the proposed injection points to limit the potential of impacting

the CWS Wells to a point where concentrations exceed the primary drinking water regulations.

The material being

injccted is a

calciu~n-based

material, for which there is

170 regulatory standard

set.

8.

Under the Illinois Water Well

Construction Code,

415

ILCS

3016b, if

a

well is

contaminated,

owners

and

operators

of

the contamination source

or

route

are

responsible 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.

Copies the

analpica1 summary table for each groundwater sampling event will be forwarded to

Village water personnel. If hydrocarbon contamination is detected in

MW-11 (located between

the contaminated monitoring well MW-7 and CSW Well

#3),

the Village will be

informed of

the

contaminant detection. If hydrocarbon contamination is identified in MW-I 1 at levels above

35

IAC 742 remediation objectives and

35

IAC Groundwater Quality Standards, the Village will be

notified that an amendment will be prepared to the Corrective Action Plan and Budget which

will include

anothcr round of ORC injections and a contingency for construction of a new

connnunity

water well positioned outside the

400-foot

setback

from

the groundwater

contamination plume,

if

hydrocarbon contamination

cxceeding

35

IAC

742

remediation

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objectives and

35

IAC 620 Groundwater Quality Standards is identified in

MW-I3 (located

between MW-I 1 and CSW Well

#3).

9.

a.

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.a.

In order to detect potential impacts, has SVFS made arrangements with the Village

to monitor the CWS wells for components that will

he injected via the Geoprobes or for

changes in groundwater quality?

Village water personnel have agreed to allow testing of the raw water

from the community water

wells during quarterly groundwater monitoring events. Based on the piping

config~iration

in the

well house, water can only be drawn from one well at a time. Since Well

#3 is the closest CSW

to the apparent groundwater

contan~ination

plume (and it is the

priinary well utilized by the

Village),

we propose only sampling Well #3. Water samples collected from CSW Well

#3 will

be analyzed for the same parameters as the monitoring wells.

b.

If not, please explain how the Village's current monitoring would be sufficient.

Not applicable.

c.

If testing confirms injected materials, hydrocarbons, or byproducts of the ORC

injections are detected in the CWS wells, what will be course of action be?

The ORC material

wbich is proposed to be injected is a calcium-based product. Calcium does

not

appear in the

35

IAC 742 remediation objectives, the 35 IAC 61 1 Primary Drinking

Watcr

Standards, nor the

35

IAC 620 Groundwater Quality Standards.

The

main byproduct

ofthe ORC

injection is increased dissolved oxygen. If hydrocarbon contamination is identified in MW-I 1

(located between the contaminated monitoring well MW-7

and CSW Well

#3), al levels above

35

IAC 742 remediation objectives and

35

IAC

Groundwater Quality Standards, an amendment

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will be prepared to the Corrective Action Plan and Budget which will include another round of

ORC injections. The Amendment will also include a contingency for construction of a new

cornmunity

water

well

positioned outside the 400-foot setback from

the

groundwater

contamination plume,

if

hydrocarbon contamination exceeding

35

IAC

742 remediation

objectives and 35 IAC 620 Groundwater Quality Standards is identified in MW-13 (located

between MW-1

1 and CSW Well

#3).

10.

What is the population served by CWS Well #3?

According to water personnel, Well

#3 serves approximately 400 households.

11.

The amended petition at 13 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.

A copy of the results of the water well survey is attached as Exhibit G. The information includes

the radius

information from the remediation site. The

survcy included requests for information

from

the Illinois State Water

Snrvey and the Illinois

State Geological Survey regarding

registered water wells within one

mile of the

remediation site. Village water personnel were

interviewed as to the number of water wells it maintains (currently 2 wells plus the initial test

well). No other water wells were identified within 400 feet of the remediation site. Additionally,

the Village has an ordinance prohibiting installation of a new water well with the incorporated

village limits.

12.

Please discuss if the county or Village of

Saybrook have ordinances that might be

more stringent than the prohibitions of

415

ILCS

5h4.2.

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A

revlew of the

McLean County Code which applies to water wells, showed the

County has no

ordinances which deal with water well setbaclts. Village water personnel indicated

the Village

follows the current State regulations relative to

watcr wells.

Respectfully submitted

SANGAMON VALLEY FARM SUPPLY

One of Its

Attorneys

ClC-'

Charles

J.

Northnip

SORLING, NORTHRUP, HANNA,

CULLEN

&

COCHRAN, LTD.

Suite 800 Illinois Building

607 East Adams

Street

PO Box 5131

Springfield,

IL 62705

(217) 544-1144

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PROOF OF SERVICE

The

undersigned hereby certifies that

a copy of

the

foregoing

document

was

electronically filed with the Pollution Control Board:

Ms. Dorothy

M.

Gunn

Pollution Control Board

James R. Thompson Center

100 West Randolph St., Suite 11-500

Chicago,

IL

60601

and served on the following by placing same in a sealed envelope addressed to:

Mr. Ronald E. Stauffer, Mayor

Ms. Carol Webb

Village of

Saybrook

Hearing Officer

234 W. Lincoln Street

Illinois Pollution Control Board

Sayhrook, IL

61770-0317

1021 North Grand Ave. East

P.

0.

Box 19274

Mr. Joey Logan-Wilkey

Springfield, IL

62794-9274

Illinois

Environinental Protection Agency

1021 North Grand Ave. East

P.

0.

Box 19276

Springfield, IL

62794-9276

and by depositing same in the United States mail in Springfield, Illinois, on the

ay of

.

:7

d

9

,

2006, with postage fully prepaid.

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