Proposal - Kermida Inc - Organic Resources Facility Well Redevelopment

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Ms. Michelle Smith March 18, 2019 KERAMIDA Proposal No. P22379R Paw 2 In the January 23, 2019 letter, IDEM also commented that "If the facility verifies an exceedance of the GWPS for nitrate at MW-13 during the next sampling event, the facility will need to propose immediate additional actions to define the nature and extent of the exceedance, which may include downgradient monitoring well installations and residential well sampling. Additionally, the facility may need to provide a demonstration that the nitrate exceedances at MW-13 are not attributable to the landfill. However, if the source of the nitrate originates from facility's property, corrective measures will still be warranted." KERAMIDA will assist in further evaluations to address IDEM's comments based on the results of 2019 sampling events. SCOPE OF WORK ,rack I: Well. Rede Its men . KERAMIDA will perform redevelopment activities for monitoring well MW-13. The redevelopment procedures include creating alternately high and low velocities of water flow in the well to break down the mudpack or loosen fine particles; and pumping to remove the particles from the well and the immediate area outside the well screen. Specifically, a surge block will be used to disturb well sediment, and a submersible pump will be used to remove sediment from the well. Water quality parameters including temperature, specific conductance, pH, redox potential, dissolved oxygen, and turbidity will be monitored to determine when well redevelopment is completed. Task 2 G—to—undwalct 51gfistigal An 1 i �. It is KERAMIDA's understanding that the groundwater sampling field activities will be performed by the City of South Bend. Following completion of each sampling event (May 2019 and October 2019), the City of South Bend will provide the groundwater data to KERAMIDA. KERAMIDA will then evaluate the data to determine whether there is a statistically significant increase over background values for each constituent listed in Section E9, Ground Water Monitoring Requirements of the January 14, 2008 IDEM approval letter. The evaluation will be performed for wells MW-4, MW-5R, MW-7R, MW-8, MW-9R, MW-11, MW-12, and MW-13. KERAMIDA will use the same statistical program (DUMPStat) and statistical procedures and methodologies used in previous years. The intent of the evaluation is to provide a ninety-five percent (95%) level of confidence to determine if a change in the concentration of a constituent has occurred or if groundwater quality standards have been exceeded, based on the information obtained during sampling, as well as the results of previous sampling events by the City of South Bend. KERAMIDA will follow the guidelines set forth by the IDEM's Analytical Data Deliverable Requirements. KERAMIDA will summarize the results of each statistical evaluation in a semi-annual Statistical Evaluation Report, which will present the results of the statistical evaluation, along with the distribution assumptions. Each report will be submitted to the City of South Bend in draft form for review and comment. Three paper and two electronic copies of the final report will then be submitted to the City of South Bend, who will be responsible for forwarding the document to the IDEM.