Five-Year Review Report
Fourth Five-Year Review Report
for
Arsenic Trioxide Superfund Site
EPA ID NDD980716963
Ransom, Richland, and Sargent Counties, North Dakota
September 2013
Prepared By:
United States Environmental Protection Agency
Region 8
Denver, Colorado
Approved by: __ Date:
o\j tofzon
Martin Hestmark
Assistant Regional Administrator
Office of Ecosystems Protection
and Remediation
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Table of Contents
I.0 Introduction 1
2.0 Site Chronology 2
3.0 Background 3
3.1 Physical Characteristics 3
3.2 Land and Resource Use 7
3.3 History of Contamination 7
3.4 Initial Response 7
3.5 Basis for Taking Action 8
4.0 Remedial Actions 8
4.1 Remedy Selection 9
4.2 Remedy Implementation 13
4.3 Operation and Maintenance (O&M) 18
5.0 Progress Since the Last Five-Year Review 18
6.0 Five-Year Review Process 20
6.1 Administrative Components 20
6.2 Community Involvement 20
6.3 Document Review 20
6.4 Data Review 22
6.5 Site Inspection 23
6.6 Interviews 24
7.0 Technical Assessment 25
7.1 Question A: Is the remedy functioning as intended by the decision
DOCUMENTS? 25
7.2 Question B: Are the exposure assumptions, toxicity data, cleanup levels and
REMEDIAL ACTION OBJECTIVES (RAOs) USED AT THE TIME OF REMEDY SELECTION
STILL VALID? 25
7.3 Question C: Has any other information come to light that could call into
QUESTION THE PROTECTIVENESS OF THE REMEDY? 26
7.4 Technical Assessment Summary 27
8.0 Issues 27
9.0 Recommendations and Follow-up Actions 27
10.0 Protectiveness Statements 28
II.0 Next Review 29
Appendix A: List of Documents Reviewed A-l
Appendix B: Interview Forms B-l
Appendix C: Site Inspection Checklist C-l
Appendix D: Photographs from Site Inspection Visit D-l
Appendix E: NDDH Correspondence and Site Fact Sheet E-l
Appendix F: Analytical Results from SEWUD 2013 F-l
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List of Appendices
Appendix A: List of Documents Reviewed A-l
Appendix B: Interview Forms B-l
Appendix C: Site Inspection Checklist C-l
Appendix D: Photographs from Site Inspection Visit D-l
Appendix E: NDDH Correspondence and Site Fact Sheet E-l
Appendix F: Analytical Results from SEWUD 2013 F-l
List of Tables
Table 1: Chronology of Site Events 2
Table 2: Progress on Recommendations from the 2008 FYR 19
Table 3: Institutional Control (IC) Summary Table for OU1 and OU2 Groundwater 21
Table 4: Summary of SEWUD Arsenic Concentrations 23
Table 5: Current Site Issues 27
Table 6: Recommendations to Address Current Site Issues 28
List of Figures
Figure 1: Site Location 5
Figure 2: Site Vicinity 6
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List of Acronyms
ARAR
Applicable or Relevant and Appropriate Requirement
ARRA
American Recovery and Reinvestment Act
bgs
below ground surface
CCR
Consumer Confidence Report
CERCLA
Comprehensive Environmental Response, Compensation and Liability Act
CFR
Code of Federal Regulations
EPA
United States Environmental Protection Agency
ESD
Explanation of Significant Differences
FYR
Five-Year Review
IC
Institutional Control
MCL
Maximum Contaminant Level
mg/L
milligrams per liter
NCP
National Oil and Hazardous Substances Pollution Contingency Plan
NDDH
North Dakota Department of Health
NPL
National Priorities List
O&M
Operation and Maintenance
OU
Operable Unit
RAO
Remedial Action Objective
RD
Remedial Design
RI/FS
Remedial Investigation/Feasibility Study
ROD
Record of Decision
RPM
Remedial Project Manager
SCADA
Supervisory Control and Data Acquisition
SDWA
Safe Drinking Water Act
SEWUD
Southeast Water Users District
^g/L
micrograms per liter
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Executive Summary
The Arsenic Trioxide Superfund Site (the Site) is located in southeastern North Dakota. The Site
covers 26 townships and 940 square miles, including portions of Richland, Ransom and Sargent
counties. Historic use of arsenic-laced bait to combat grasshopper infestations during the 1930s
and 1940s resulted in contamination of groundwater at the Site. In 1983, the United States
Environmental Protection Agency (EPA) placed the Site on the National Priorities List. The Site
consists of two operable units (OUs).
The triggering action for this policy five-year review (FYR) was the signing of the previous FYR
on September 26, 2008.
The remedy at OU1 currently protects human health and the environment because the Southeast
Water Users District (SEWUD)-East water treatment plant has been upgraded and expanded to
provide rural users, formerly on privately owned, impacted wells, with potable water that meets
the arsenic MCL. However, in order for the remedy to be protective in the long term, treated
groundwater should be monitored on a more frequent basis, a summary of institutional control
activities and results should be submitted to EPA on a regular basis, and the Site fact sheet
should be updated to discuss watering of livestock and poultry.
The remedy at OU2 is protective of human health and the environment. Rural users who had
relied on the Wyndmere and Lidgerwood water treatment plants are now connected to the
SEWUD-East water treatment plant.
Because the remedial actions at all OUs are protective or protective in the short term, the Site is
protective of human health and the environment in the short term.
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Five-Year Review Summary Form
SITE IDENTIFICATION
Site Name:
Arsenic Trioxide Site
EPA ID:
NDD980716963
Region: 8
State:
ND
City/County: Hankinson, Lidgerwood,
Wyndmere and Milnor Cities/Richland, Ransom
and Sargent Counties
SITE STATUS
| NPL Status:
Deleted
I
Multiple OUs?
Yes
Has the site achieved construction completion?
Yes
REVIEW STATUS
Lead agency: EPA
Author name: Frances L. Costanzi and Claire Marcussen
Author affiliation: EPA Region 8 and Skeo Solutions
Review period: 12/10/2012 - 09/26/2013
Date of site inspection: 07/01/2013
Type of review: Policy
Review number: 4
Triggering action date: 09/26/2008
Due date (five years after triggering action date): 09/26/2013
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Five-Year Review Summary Form (continued)
Issues/Recommendations
OU(s) without Issues/Recommendations Identified in the Five-Year Review:
OU2
Issues and Recommendations Identified in the Five-Year Review:
OU(s): OU1
Issue Category: Monitoring
Issue: SEWUD-East water treatment plant only monitors arsenic in
treated water every two years.
Recommendation: Monitor arsenic concentrations in treated water on a
more frequent basis to ensure levels are below the MCL for arsenic
Affect Current
Protectiveness
Affect Future
Protectiveness
Implementing
Party
Oversight
Party
Milestone Date
No
Yes
State
EPA
09/01/2014
OU(s): OU1
Issue Category: Remedy Performance
Issue: NDDH has not provided EPA with regular updates to demonstrate
that informational institutional controls are adequate for achieving site
RAOs
Recommendation: Provide EPA information on a quarterly basis
summarizing the activities related to ensuring informational institutional
controls are adequate.
Affect Current
Protectiveness
Affect Future
Protectiveness
Implementing
Party
Oversight
Party
Milestone Date
No
Yes
State
EPA
09/01/2014
OU(s): OU1
Issue Category: Remedy Performance
Issue: The current fact sheet does not address uses of rural wells for
watering livestock and poultry
Recommendation: Revise the fact sheet to address watering of livestock
and poultry.
Affect Current
Protectiveness
Affect Future
Protectiveness
Implementing
Party
Oversight
Party
Milestone Date
No
Yes
State
EPA
09/01/2014
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Protectiveness Statement(s)
Operable Unit: Protectiveness Determination: Addendum Due Date
OU1 Short-term Protective (if applicable):
Not Applicable
Protectiveness Statement:
The remedy at OU1 currently protects human health and the environment because the
SEWUD-East water treatment plant has been upgraded and expanded to provide rural users,
formerly on privately owned, impacted wells, with potable water that meets the arsenic MCL.
However, in order for the remedy to be protective in the long term, treated groundwater
should be monitored on a more frequent basis, a summary of institutional control activities
and results should be submitted to EPA on a regular basis, and the Site fact sheet should be
updated to discuss watering of livestock and poultry.
Operable Unit: Protectiveness Determination: Addendum Due Date
OU2 Protective (if applicable):
Not Applicable
Protectiveness Statement:
The remedy at OU2 is protective of human health and the environment. Rural users who had
relied on the Wyndmere and Lidgerwood water treatment plants are now connected to the
SEWUD-East water treatment plant.
Sitewide Protectiveness Statement (if applicable)
Protectiveness Determination: Addendum Due Date (if applicable):
Short-term Protective Not Applicable
Protectiveness Statement:
Because the remedial actions at OU1 are protective in the short term, the Site is protective of
human health and the environment in the short term. However, in order for the remedy to be
protective in the long term, treated groundwater should be monitored on a more frequent
basis, a summary of institutional control activities and results should be submitted to EPA on
a regular basis, and the Site fact sheet should be updated to discuss watering of livestock
and poultry.
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Fourth Five-Year Review Report
for
Arsenic Trioxide Superfund Site
1.0 Introduction
The purpose of a five-year review (FYR) is to evaluate the implementation and performance of a
remedy in order to determine if the remedy is protective of human health and the environment.
FYR reports document FYR methods, findings and conclusions. In addition, FYR reports
identify issues found during the review, if any, and document recommendations to address them.
The United States Environmental Protection Agency (EPA) prepares FYRs pursuant to the
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) Section
121 and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP).
CERCLA Section 121 states:
If the President selects a remedial action that results in any hazardous substances,
pollutants, or contaminants remaining at the site, the President shall review such remedial
action no less often than each 5 years after the initiation of such remedial action to assure
that human health and the environment are being protected by the remedial action being
implemented. In addition, if upon such review it is the judgment of the President that
action is appropriate at such site in accordance with section [104] or [106], the President
shall take or require such action. The President shall report to the Congress a list of
facilities for which such review is required, the results of all such reviews, and any
actions taken as a result of such reviews.
EPA interpreted this requirement further in the NCP, 40 Code of Federal Regulations (CFR)
Section 300.430(f)(4)(ii), which states:
If a remedial action is selected that results in hazardous substances, pollutants, or
contaminants remaining at the site above levels that allow for unlimited use and
unrestricted exposure, the lead agency shall review such action no less often than every
five years after initiation of the selected remedial action.
Skeo Solutions, an EPA Region 8 contractor, conducted the FYR and prepared this report
regarding the remedy implemented at the Arsenic Trioxide Superfund site (the Site) in Richland,
Ransom and Sargent Counties, North Dakota. EPA's contractor conducted this FYR from
December 2012 to September 2013. The North Dakota Department of Health (NDDH) is the
lead agency at the Site, with EPA as the support agency. EPA, however, is the lead agency for
this FYR and NDDH, representing the State of North Dakota, has reviewed all supporting
documentation and provided input to EPA during the FYR process.
This is the fourth FYR for the Site. The triggering action for this policy review is the previous
FYR. This is a policy review because the Record of Decision (ROD) was signed on September
26, 1986, which is before October 17, 1986, the effective date of the Superfund Amendments
and Reauthorization Act (SARA). The FYR is required because hazardous substances, pollutants
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or contaminants remain at the Site above levels that allow for unlimited use and unrestricted
exposure. The Site consists of two operable units (OUs). This FYR report addresses both site
OUs.
2.0 Site Chronology
Table 1 lists the dates of important events for OU1 and OU2 at the Site.
Table 1: Chronology of Site Events
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EPA site discovery
June 1, 1981
NDDH completed the first site inspection
August 1, 1982
NDDH started the remedial investigation (RI) for OU1
August 24, 1982
EPA proposed the Site for listing on the National Priorities List (NPL)
December 30, 1982
EPA listed the Site on the NPL
September 8, 1983
NDDH completed a second site inspection
May 1, 1984
NDDH issued the final RI report and started the feasibility study (FS) for
OU1
July 1, 1985
EPA started the first removal action, which included installing a clay cap
over a former bait-mixing station and installing point-of-use treatment
units in rural residences on private wells
September 15, 1986
NDDH completed the OU 1 Final FS Report and EPA issued the OU 1
Record of Decision (ROD)
September 26, 1986
EPA completed the first removal action
December 10, 1986
NDDH started the remedial design (RD) for OU 1
March 26, 1987
NDDH started the combined remedial investigation/feasibility study
(RI/FS) for OU2
April 29, 1987
NDDH completed the OU2 combined RI/FS and EPA issued an
Amended ROD for OU2
February 5, 1988
NDDH began first OU2 RD
February 17, 1988
NDDH began second OU2 RD
June 29, 1988
NDDH completed second OU2 RD
September 26, 1988
EPA started the second removal action
October 24, 1988
NDDH completed first OU2 RD
March 31, 1989
NDDH started the first OU2 remedial action
March 9, 1989
NDDH started the second OU2 remedial action
March 31, 1989
EPA completed the second removal action
June 9, 1989
NDDH completed the RD for OU 1
June 28, 1989
NDDH completed the first and second OU2 remedial actions
March 21, 1991
EPA signed the Explanation of Significant Differences (ESD) for OU2
September 25, 1992
NDDH completed the remedial action of the rural water system to add
the City of Milnor and EPA issued a Preliminary Close-Out Report
September 30, 1992
EPA conducted a final inspection of remedial action construction at
Milnor and issued a Final Close-Out Report
June 30, 1993
Southeast Water Users District (SEWUD) assumed operation and
maintenance responsibility for the Richland plant
July 1, 1993
EPA deleted the Site from the NPL
July 5, 1996
EPA completed the first FYR
January 19, 1999
EPA lowered the Safe Drinking Water Act (SDWA) maximum
contaminant level (MCL) for arsenic from 50 micrograms per liter (|ig/L)
to 10 |ig/L. to become effective January 2006.
January 22, 2001
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EPA completed the second FYR
June 11,2003
EPA started an RI/FS for OU1 to address expansion of SEWUD to
address the new MCL for arsenic
June 25, 2003
NDDH started the RD for the SEWUD expansion
September 20, 2004
NDDH started construction of Segments 1 and 2 of the SEWUD
expansion
August 8, 2005
EPA provided bottled water to rural users with sampling results showing
arsenic levels 10 ng/L or greater
June 4, 2007
EPA issued second ESD for OU 1
September 27, 2007
EPA issued third ESD for OU 1
February 25, 2008
NDDH started the construction of Segment 3 to connect the cities of
Hankinson and Wyndmere to SEWUD
June 10, 2008
NDDH completed construction of Segments 1 and 2
September 25, 2008
EPA completed the third FYR
September 26, 2008
EPA's removal program transferred bottled water program to NDDH
October 1, 2008
EPA completed the RI/FS for OU 1
February 20, 2009
EPA signed fourth ESD on OU 1
February 20, 2009
NDDH started Segment 4 and 4a construction
May 1, 2009
NDDH completed remedy construction of Segment 3, connecting 60
rural users to SEWUD
September 29, 2009
EPA issued a FYR update
February 1, 2010
NDDH completed the RD for the next phase of the SEWUD expansion
March 30, 2010
NDDH completed segment 4 and 4a construction, connecting about 119
rural users to SEWUD
November 30, 2010
NDDH started Segment 5 construction
April 20, 2010
NDDH completed Segment 5 construction
September 1, 2011
EPA issued Site's Final Remedial Action Report for the SEWUD
expansion
September 29, 2011
3.0 Background
3.1 Physical Characteristics
The Site is located in southeastern North Dakota. It covers 26 townships (about 940
square miles) and encompasses portions of Richland, Ransom and Sargent counties
(Figure 1). The site area is sparsely populated farmland with a few small towns, including
Lidgerwood, Wyndmere, Milnor and Hankinson. The Southeast Water Users District
(SEWUD), headquartered in Mantador, pumps water from its source wells located in the
Sheyenne National Grasslands followed by treatment in its eastern water treatment plant,
referred to as SEWUD-East. The SEWUD-East supplies potable water to the cities of
Lidgerwood, Wyndmere, Milnor, Hankinson and surrounding areas (Figure 2).
This area of southeastern North Dakota is primarily sparsely populated farmland. Site
topography consists of gently rolling hills and relatively flat plains. Groundwater aquifer
systems within the Site include shallow glacial drift aquifers, located approximately 3 to
150 feet below ground surface (bgs), and the Dakota Sandstone aquifer, located
approximately 200 to 1,000 feet bgs. The occurrence of arsenic in groundwater is
attributed to both the historical use of arsenic-based grasshopper bait and naturally
occurring sources. Arsenic is present in groundwater at concentrations above the drinking
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water maximum contaminant level (MCL) at the Site, including in the communities of
Lidgerwood, Wyndmere and Milnor, as well as at private homes and farms in
unincorporated areas. EPA designated the Richland Rural Water Treatment System (now
known as SEWUD) as OU1 and the water treatment systems in the cities of Lidgerwood
and Wyndmere as OU2.
Surface waters in the vicinity of the Site consist of perennial and intermittent lakes along
the Milnor Channel, the Wild Rice River and its tributaries, and area sloughs and prairie
potholes. The perennial lakes and intermittent lakes recharge the Milnor Channel
Aquifer. Area sloughs and prairie potholes behave similarly to intermittent lakes;
however, recharge to the aquifer is much slower because of finer-grained sediments in
these areas. The Wild Rice River and its tributaries and throughout most of its length
within the Site, the river is a gaining stream whereby groundwater contributes directly to
the flow of the river.
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Figure 1: Site Location
actions at the Site.
Arsenic Trioxide
Superfund Site
North Dakota
Ransom
County
Ransom,.Richland and Sargent
7 Counties,JNohhTDakbtaT1-
I i i * i i
Richland
County
Sargent
County
Swan Lake
v ' ^ >
Lake Tewaukon
South Dakota
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Figure 2: Site Vicinity
Legend
© SEWUD District Office
Site Boundaries
County Outlines
o
NORTH
Arsenic Trioxide Superfund Site
Ransom, Richland and Sargent Counties, North Dakota
Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only regarding EPA's response
actions at the Site.
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3.2 Land and Resource Use
The primary land use in this sparsely populated site area currently is agricultural, with
very little unaltered prairie land; this land use is expected to continue. Agriculture is
mostly cash crop farming, and is the base of the local economy. The Site area includes a
few small cities, including Lidgerwood, Wyndmere, Milnor and Hankinson.
Groundwater in the area is used for agricultural and domestic purposes. Agricultural uses
include irrigation and livestock watering. Domestic uses include residential consumption
and lawn and garden watering.
Groundwater with elevated arsenic levels appears to be limited to the upper, unconfined
glacial drift aquifers and does not extend into the deeper sandstone unit. The upper
aquifer is a commonly used drinking water source in the region, since the deeper
sandstone unit is typically high in total dissolved solids and has low yield. The Site is
currently serviced by the SEWUD-East.
3.3 History of Contamination
Grasshopper infestations in the years between 1910 and 1950 resulted in congressional
funding to provide arsenic bait to the State and counties of North Dakota and a number of
federal-state cooperative programs. The U.S. Department of Agriculture distributed
federal funds and assistance to the State of North Dakota, which facilitated the
distribution of arsenic bait to the counties and individual farmers and landowners through
extension service and county agents. In addition, county governments funded and
facilitated individual farmers' and landowners' use of arsenic-laced bait, both
independently and in conjunction with federal funding. The bait, which included arsenic
trioxide, sodium arsenate, Paris Green and other arsenic compounds, was commonly
applied to farm fields. Unused materials were often buried or dumped in pits or low-lying
areas. It was estimated that 330,000 pounds of arsenic trioxide bait may have been
applied to the Site.
3.4 Initial Response
Data from the remedial investigation (RI) and a Health Risk Assessment performed by
NDDH estimated that 748 people in 278 homes were subject to increased health risk
because of exposure to arsenic above the MCL in water supplies; all were rural users
using private wells. In response, EPA instituted an emergency response action in 1986 to
address the immediate health impacts of the arsenic-contaminated groundwater. The
response action consisted of installing point-of-use treatment units on one tap per affected
household. The response action also included closure of the approximately 1-acre former
bait mixing area near Wyndmere by installing a clay cap over the area. EPA initially
proposed the Site for listing on the National Priorities List (NPL) on December 30, 1982.
Final listing of the Site on the NPL occurred on September 8, 1983.
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3.5 Basis for Taking Action
Routine water quality monitoring of municipal water supplies by NDDH in 1979
identified elevated levels of arsenic at the water treatment systems in Lidgerwood and
Wyndmere. These levels exceeded the MCL of 50 micrograms per liter (|ig/L) designated
by EPA pursuant to the Safe Drinking Water Act (SDWA) at that time, and were
determined to be a health risk by NDDH and EPA. Additional monitoring detected more
widespread occurrence of arsenic within groundwater in surrounding rural areas.
From 1982 to 1986, NDDH conducted a remedial investigation/feasibility study (RI/FS)
overseen by EPA. NDDH and EPA concluded in a final RI Report dated July 1985, that
the elevated levels of arsenic in groundwater resulted both from use of arsenic-based
grasshopper bait and naturally occurring sources. Concentrations of arsenic ranged from
undetected to 1,560 |ig/L in 704 samples collected from 558 groundwater supply
locations. However, the degree of influence of arsenic on groundwater quality because of
bait application could not be determined because background levels for arsenic were not
available prior to the RI. The arsenic contamination in the groundwater appeared to be
limited to the seven major unconfined aquifers in the glacial drift.
With the exception of the Wyndmere mixing area, contaminant source areas were not
located during the RI. RI samples taken along a confirmed area of bait-spreading
indicated no evidence of remnant arsenic within the soils. RI soil borings taken from
other areas of the Site resulted in arsenic concentrations similar to background levels. The
RI also indicated that grasses and woody-stemmed bushes grown in arsenic-impacted soil
are not expected to raise arsenic levels in grazing animals. The RI concluded that the
most likely exposure pathway of arsenic is from human ingestion of groundwater, meat
products or dairy products. Any locally produced meat or dairy products have the
potential to contribute arsenic to the human diet since the livestock may have been
exposed for a significant length of time to high-arsenic drinking water.
NDDH issued an FS on September 26, 1986. During the same time, the City of
Lidgerwood was ordered to take appropriate measures to provide drinking water that met
the MCL for arsenic. The city built a new water treatment plant, overseen by NDDH
under the SDWA, which was completed in 1986. NDDH investigations during that time
also determined that the raw water supply for Wyndmere exceeded the MCL for arsenic.
However, the existing Wyndmere treatment plant was found effective in reducing the
arsenic to below the MCL, so no additional immediate action was required.
4.0 Remedial Actions
In accordance with CERCLA and the NCP, remedial actions are required to protect human
health and the environment and to comply with applicable or relevant and appropriate
requirements (ARARs). A number of remedial alternatives were considered for the Site. The
final remedy selection was made based on an evaluation of following criteria:
Effectiveness in protecting human health and the environment
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Cost
Engineering implementation, reliability and constructability
Feasibility
Applicability
Reliability.
The evaluation included an assessment of the extent to which each remedial alternative would
effectively prevent, mitigate or minimize threats to, and provide adequate protection of public
health, welfare and the environment. The evaluation also included an analysis of potential
adverse environmental impacts associated with each alternative.
4.1 Remedy Selection
Originally, EPA designated the Site as a single OU, which was the Richland Rural Water
Treatment System (now known as Southeast Water Users District, or SEWUD). In 1986,
the Lidgerwood and Wyndmere water treatment systems were effective in the removal of
arsenic. However, after EPA signed the Site's 1986 Record of Decision (ROD), the cities
of Lidgerwood and Wyndmere requested consideration of their respective water
treatment plant expansions as part of the Site's overall remedial action. Therefore, as part
of the February 5, 1988 Record of Decision Amendment (ROD Amendment), EPA
designated the Richland Rural Water Treatment System as OU1 and the Lidgerwood and
Wyndmere treatment plants as OU2.
OU1
EPA selected the OU1 remedy in the Site's OU1 ROD, which was signed on September
26, 1986. The purpose of the remedy was to reduce human exposure to arsenic-
contaminated groundwater by providing treated drinking water through rural water
distribution systems to households with elevated levels of arsenic. The selected remedy
was to treat arsenic-contaminated groundwater to achieve the background concentration
of 25 |ig/L, which was below the MCL at that time of 50 |ig/L for arsenic pursuant to the
SDWA. The remedy included:
Expansion of the existing Richland water treatment plant, currently known as
SEWUD-East, and its associated distribution capacity to provide drinking water
to rural households.
"No action" for individuals using water from the Lidgerwood and Wyndmere
systems because of effective removal of arsenic by the cities' treatment systems.
Continuation of quarterly groundwater monitoring in the Lidgerwood system and
rural systems, annual monitoring of the Wyndmere system, annual monitoring of
the glacial aquifer systems, and random annual sampling of private wells outside
of the existing contamination boundaries.
Investigation of institutional controls, including restrictions on existing well use,
restrictions on well drilling, a well permitting system, and economic incentives
for participation in the new distribution system.
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Several developments occurred after EPA issued the Site's ROD. The City of
Lidgerwood requested consideration of the construction of its water treatment plant and
the replacement of its distribution system as part of the overall remedial action for the
Site under Section 104 of CERCLA. Therefore, associated costs could be considered
reimbursable. In addition, the Lidgerwood plant did not operate correctly after the first
six months of operation in the late summer of 1986. The City of Wyndmere also
requested consideration of the expansion of its water treatment plant capacity to cover
periods of high demand, during which it must bypass its plant with untreated water high
in arsenic, as part of the overall remedial action for the Site.
September 25. 1992 Explanation of Significant Differences (ESP): The Bureau of
Reclamation, through an Interagency Agreement with EPA and NDDH, recommended
expansion of the Richland Rural water treatment plant's distribution system to
incorporate Milnor. This action would limit the potential exposure of residents in Milnor
to arsenic-contaminated drinking water supplies. EPA approved Milnor's addition to the
remedy for OU1; this was designated as Phase 2 of OU1. The ESD explains the decision
to add Milnor as a second phase of the remedial action for OU1. The addition of Milnor
did not alter the original RAO; it only expanded the scope and cost of the remedial
action. Therefore, EPA did not consider it a fundamental change to the original remedy.
With these modifications, the primary components of the site-wide remedy included:
Expansion of the SEWUD-East and its associated distribution system to provide
safe drinking water to households in Milnor and rural areas within the Site.
Expansion and modification of the Lidgerwood water treatment plant to increase
treatment capability and storage capacity and thereby provide safe drinking water
to households in Lidgerwood.
Expansion and modification of the existing Wyndmere treatment plant to increase
treatment capability and storage capacity.
Monitoring of the treatment plants, glacial aquifer systems and private wells.
Institutional controls to encourage public participation in the project and restrict
private water supply well use.
September 27. 2007 ESD: The Site's second FYR in 2003 concluded that the remedy
may no longer protective because of the arsenic MCL change from 50 |ig/L to 10 |ig/L.
For the remedy to be protective, EPA determined that additional remedial action was
needed. Activities included increasing the capacity of the SEWUD water treatment plant
and adding wells to meet the increased water demands of the Wyndmere and Hankinson
communities. As an interim measure, EPA and NDDH offered bottled water to interested
rural households located within the site boundary whose groundwater wells contained
arsenic levels in excess of the 10 |ig/L MCL. EPA issued an ESD dated October 8, 2007,
documenting the bottled water interim action.
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February 25. 2008 ESP: The 2008 ESD consisted of connecting approximately 60 rural
users to the SEWUD water supply system near Wyndmere and the Lake Elsie area for
residents whose groundwater wells contained arsenic levels that exceeded or were equal
to the MCL of 10 |ig/L. Additionally, the ESD documented the expansion of the SEWUD
water treatment plant's treatment capacity and the addition of wells to meet the increased
water demands resulting from providing the rural water service to the communities of
Wyndmere and Hankinson.
February 20. 2009 ESD: As a result of the third FYR, EPA and NDDH determined that
work needed to continue to connect rural users with contaminated wells meeting the
criteria for inclusion in the project, and to expand the SEWUD treatment system to
accommodate the increased demand from these users. Additionally, the third FYR
determined the need for implementation of institutional controls to protect future users of
domestic groundwater wells in the Site area.
The 2009 ESD documented the decision to connect remaining qualified rural households
to the SEWUD system (about 330 rural households). In addition, the SEWUD treatment
plant and system required expansion to accommodate the increased demand. The 1986
ROD stated that institutional controls would be investigated further and that feasible and
implementable institutional controls would be adopted. This ESD documented the need
for institutional controls, defined required specific institutional controls, and presented
additional institutional controls for evaluation and implementation, if feasible. The 2009
ESD required the implementation of the following informational institutional controls:
1. As required by the SDWA, the SEWUD produces an annual Consumer
Confidence Report (CCR), which is mailed to existing members and placed on the
SEWUD website. EPA and NDDH will develop a fact sheet for inclusion with the
annual mailing that contains information about the Site, arsenic in the
groundwater that exceeds drinking water standards, and options available for
residential users with concerns about their well water. The fact sheet also states
that after completion of the site remedy, EPA will not be responsible for future
improvements to the public water system, barring changes to the protectiveness of
the remedy. SEWUD will provide an annual report to NDDH and EPA that
summarizes this effort and includes any contacts with citizens regarding the Site.
2. In accordance with North Dakota Administrative Code, the North Dakota Water
Commission receives well logs from drillers when new wells are constructed.
NDDH proposes an agreement with the Commission where NDDH will receive
copies of the well logs for the 26 townships included in the site area, and will
provide the fact sheet described above to property owners within the Site's
boundaries when new wells are drilled.
3. NDDH will work with the State Board of Water Well Contractors to provide
information, including the fact sheet, to North Dakota certified well drillers
regarding the arsenic contaminated groundwater and about what can be done.
11
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4. At a minimum, the fact sheet will also be posted on EPA Region 8's website and
NDDH's Groundwater Protection website.
In addition, the 2009 ESD also stated that "because the most protective situation is to
have multiple layers of institutional controls, NDDH, with EPA's assistance, will evaluate
and implement the following institutional controls, if feasible:
1. NDDH will coordinate with appropriate local government officials in both
counties to request the addition of a notification to building permits and/or to
provide building applicants a fact sheet informing residents about the arsenic-
contaminated groundwater. Additionally, NDDH will request that local officials
consider implementing a requirement that new domestic wells be tested for
arsenic and that new wells drilled within the city limits not be approved for
domestic purposes.
2. NDDH will evaluate whether the site can be designated as a "groundwater
protected area" for the purposes of installing domestic water wells.
3. NDDH will investigate whether a "One Call" system may be used prior to
domestic well drilling to provide further notification to residents regarding the
contaminated groundwater.
4. NDDH and EPA will discuss with SEWUD various options for expanding their
informational outreach to non-members in the 26-township area, such as by
mailings and newspaper notices.
OU2
The City of Lidgerwood requested that the construction of its water treatment plant and
the replacement of its distribution system be done at the same time as the overall
remedial action for the Site. Therefore, associated costs could be considered
reimbursable. In addition, the Lidgerwood plant did not operate correctly after the first
six months of operation in the late summer of 1986. The City of Wyndmere also
requested the expansion of its water treatment plant capacity to cover periods of high
demand, during which it must bypass its plant with untreated water high in arsenic, be
done at the same time as the overall remedial action for the Site. Associated costs were
also reimbursable.
In April 1987, a Cooperative Agreement was awarded to NDDH to study the Lidgerwood
and Wyndmere water treatment plants, with the objective of determining the extent of
repairs necessary to correct problems at the Lidgerwood plant and of verifying the
Wyndmere plant's capacity problem. EPA selected the remedy in the Site's February 5,
1988 ROD Amendment and designated the Lidgerwood and Wyndmere water treatment
systems as OU2. The ROD Amendment for OU2 provided for:
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Reimbursement from the Superfund to the City of Lidgerwood for remedy-
associated costs associated with construction of its water treatment plant.
Modification of the Lidgerwood water treatment plant.
Expansion of the Wyndmere water treatment plant to increase its storage capacity
with a 50,000-gallon potable water storage reservoir and related minor
adjustments and modifications to the existing plant.
4.2 Remedy Implementation
The primary remedial components included the expansion of the SEWUD-East (OU1),
and the Lidgerwood and Wyndmere water treatment plants (OU2) and their associated
distribution systems between 1986 and 1992. Additional components of the remedy for
both OUs included bottled water provisions prior to the completion of the water treatment
plant and distribution system expansions, as well as institutional controls. Details of
remedy implementation at each OU are described below.
QUI - SEWUD-East
Remedial design for the OU1 remedial action started March 26, 1987 and was completed
on June 28, 1989. The groundwater treatment plant uses a precipitation technology using
a chemical (e.g., ferric coagulant) to co-precipitate arsenic into an insoluble solid. The
insoluble arsenic precipitant is then removed from the liquid phase by filtration.
Phase I of construction to expand the SEWUD-East and distribution system began July
19, 1990. Expansion activities included the installation of about 300 miles of water
distribution pipeline, the addition of seven additional water storage reservoirs, installation
of three additional water supply wells and doubling of the size of the treatment plant.
Phase 2 of construction activities began in September 1991 to add Milnor to the
distribution system and ended in June 1993. During the summer of 1992, remedial
actions included the connection of about 300 homes and businesses to a new 135,000-
gallon drinking water reservoir and distribution system. Phase 1 and Phase 2 of the
construction activities for OU1 was completed on June 23, 1993. Following the
completion of Milnor remedial activities, Richland Rural water treatment system took
over operation and maintenance of the treatment system.
EPA documented the completion of work in a Final Close-Out Report, dated June 30,
1993, and deleted the Site from the NPL on July 5, 1996.
In 2001, the MCL for arsenic was lowered to 10 |ig/L, with this new standard becoming
enforceable in January 2006. This prompted a FYR in June 2003. The review determined
that the remedy may no longer be protective of human health as a result of the changing
MCL. EPA started an extensive rural user well sampling program in June 2003 to
determine if rural users in the 26 townships were drinking water with arsenic
concentrations over the MCL. Of the 375 wells sampled, 84 percent were at or above the
MCL. Many of them were significantly above the MCL. As an interim measure, EPA and
13
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NDDH offered bottled water to interested rural households located within the site
boundary whose groundwater wells contained arsenic levels in excess of the 10 |ig/L
MCL. EPA issued an ESD dated September 27, 2007, documenting the bottled water
interim action.
EPA and NDDH expanded the remedy using a segmented design and construction
approach, with the scope of work for each segment dictated by the amount of available
funding. In total, six segments were constructed: segments 1, 2, 3, 4, 4a and 5. The
remedial design for the expansion of the SEWUD started on September 20, 2004 and was
completed on March 30, 2010. NDDH was the lead for this work and EPA was the
support agency. NDDH entered into a contract with the SEWUD, and the SEWUD
conducted the design and construction under oversight from NDDH and EPA.
Segment 1 Construction
Segment 1 construction activities provided treated water to the cities of Hankinson and
Wyndmere. Construction activities in Wyndmere began in August 2005 and were
completed in October 2006. They included the installation of about 11 miles of new
water pipeline from an existing line to a new 100,000-gallon underground water storage
reservoir and construction of a pumping facility on a vacant lot directly west of the
existing Wyndmere water treatment plant. Construction activities also included
modifications to SEWUD's existing Reservoir B pumps, piping and controls.
Construction activities associated with providing water to Hankinson included the
installation of about three miles of new water pipeline from an existing line to a new
200,000-gallon underground water storage reservoir and construction of a pumping
facility in Hankinson. Improvements to Hankinson's water distribution system also
provided water to eight households within city limits that did not previously have
municipal water service.
On November 21, 2007, EPA performed the final inspection for Segment 1 remedial
action. The operational and functional period began on November 21, 2007. On
November 21, 2008, the remedy was declared operational and functional, and SEWUD
took over operation and maintenance of the Segment 1 work.
EPA encouraged the City of Lidgerwood to abandon its aging treatment plant and
connect to the SEWUD system. The city declined and chose to enter an EPA Office of
Research and Development demonstration project. The project examined potential
process modifications for existing water treatment plants to reduce arsenic levels and
bring them into compliance with the new arsenic MCL. While EPA funded this work, its
scope was outside of the Superfund program and process. Since the City of Lidgerwood
chose not to connect to the SEWUD-East system and chose instead to participate in the
demonstration project, the City of Lidgerwood took on financial and operation and
maintenance responsibilities for the treatment system.
14
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Segment 2 Construction
Prior to the design and construction of Segment 1, it was determined that SEWUD's
existing water supply wells and water treatment equipment serving eastern North Dakota
would not provide a sufficient quantity of water for the existing user base and also satisfy
the water demands for the communities of Hankinson and Wyndmere during peak
demands. Therefore, Segment 2 included well field expansion and expansion of the
SEWUD-East water treatment plant.
The well field expansion included the completion of two production wells and associated
appurtenances along with the construction of two meter pits. The raw water transmission
from the new production wells to their tie-in with the existing transmission line included
the installation of 3,200 feet of piping.
The existing water treatment plant building was expanded to include an addition directly
north of the existing building and the installation of the following equipment: two new
water filters, high service pumps, backwash pumps, chemical feed equipment,
miscellaneous process piping, valves and fittings; clear well, chemical feed room, a
operator control room, and an electrical/motor control center room. Expansion activities
also included modifications to the backwash and sanitary sewer pond at the treatment
plant site.
Construction of Segment 2 began in May 2006 and was completed in August 2007. EPA
performed a final walk-through of the SEWUD-East water treatment plant on March 19,
2008. When the remedy was declared operational and functional in fall 2009 SEWUD
became responsible for all future operation and maintenance activities.
Segment 3 Construction
Segment 3 construction activities provided treated water to 54 rural households in the
area north and west of the City of Wyndmere and to the south and west of the City of
Hankinson. Activities included the installation of approximately 36 miles of water line
and the installation of associated valves, hydrants, curb stop assemblies and residential
meter units. Construction began in June 2008 and completed in August 2009.
Segment 4/4a Construction
Segment 4 construction began in May 2009 and was completed in November 2010. It
connected approximately 125 rural users to SEWUD-East and provided individual
connections to the cities of Cayuga and Geneseo. Additionally, two water supply
reservoirs, B and G, were expanded to supply new customers; this segment is referred to
as Segment 4a. Its construction took place between October 2009 and July 2010.
Segment 5 Construction
The American Recovery and Reinvestment Act (ARRA) provided 100 percent of the
design funds and 90 percent of the construction funds for Segment 5, which is the final
phase of the project. Segment 5 was divided into three separate designs and related
construction contracts for pipeline installation, facilities construction and well field
15
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expansion. Construction on Segment 5 began in April 2010. It was completed in
September 201 1. The construction included:
Expanding the well field to ensure availability of an adequate quantity of raw
water to include connecting the City of Lidgerwood and other users;
Upgrading the water treatment facility with an additional filter vesse;.
Constructing a new reservoir and pump station to maintain adequate flows to an
area previously unserved by rural water;
Upgrading four pump stations so that adequate service would be provided to new
users and so that existing users maintained the level of service they were
experiencing prior to the expansion;
Constructing two new storage reservoirs to provide system capacity;
Installing an emergency generator to diminish the impact of service interruptions
because of loss of power;
Installing a geothermal system to lessen the system's dependence on non-
renewable energy sources; and
Installing water lines and associated valves, hydrants, curb stop assemblies and
residential meter setter units to provide water service to approximately 132 rural
households.
The City of Lidgerwood signed a water purchaser agreement with SEWUD on February
1 1, 2010.
Institutional Controls
In 1993, NDDH prepared a review document identifying feasible and implementable
institutional controls for the Site. The following institutional controls were proposed by
NDDH:
1. Initiate economic incentives to maximize public participation in the rural water
supply project.
2. Restrict public water supply well use within the project area.
3. Propose to require water quality monitoring of new wells within the project area.
The institutional control review document also indicates that NDDH will continue to
evaluate newly available water quality data and based on its review may act to expand the
scope of the institutional controls to provide additional protection of public health.
As of the 2008 FYR and 2010 FYR update, no records were available that documented
full implementation of the institutional controls. Further, specific institutional controls
were not outlined in decision documents until the Site's 2009 ESD. The 2009 ESD
specified four informational institutional controls as well as evaluation and
implementation of four additional institutional controls, if feasible. Section 6.3 provides a
summary of the institutional controls and their implementation.
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0U2 - Lidgerwood and Wyndmere Treatment Plants
Lidgerwood Treatment System
Following construction in 1986, the Lidgerwood water treatment plant proved difficult to
operate and frequently produced water of unacceptable quality. The Bureau of
Reclamation evaluated plant performance between 1988 and 1989. Based on this
evaluation, the Bureau recommended expansion of the treatment building, addition of a
23,000-gallon potable water storage reservoir, automation of the backwash system and
several operational changes.
Implementation of the recommended plant modifications occurred between August 1989
and January 1990. The operational and functional period, which included treated water
quality monitoring in accordance with a monitoring program developed by NDDH,
indicated the plant was able to consistently reduce arsenic concentrations from
approximately 130 to 160 |ig/L in the source water to approximately 20 to 30 |ig/L
following treatment, meeting the MCL of 50 |ig/L at that time. Following the operational
and functional determination, the City of Lidgerwood assumed responsibility for the
ongoing operation and maintenance of the treatment system.
According to the February 2010 FYR update, because of declining performance for
arsenic removal at the Lidgerwood treatment plant, the City of Lidgerwood chose to enter
an EPA Office of Research and Development demonstration project. On May 28, 2009,
NDDH received ARRA funding to implement construction activities at the Site, which
included funds for SEWUD to connect the City of Lidgerwood to the SEWUD system
and become part of OU1. SEWUD signed a water purchaser's agreement with the City of
Lidgerwood on February 11, 2010, providing the city with potable water from SEWUD.
Wyndmere Treatment System
In 1987, NDDH investigated concerns expressed by the City of Wyndmere that its
existing treatment plant had inadequate capacity to meet periods of high water demand.
Based on NDDH findings, EPA amended the Site's ROD to address the capacity issue.
Remedial measures initially included modifications to increase treatment capacity and the
addition of a 50,000-gallon potable water storage tank. However, once plant operations
resumed, plant operators identified problems with the plant's backwash cycle. Initial
modifications to increase plant capacity and add the storage tank took place between
August 1989 and January 1990. Between April 1990 and January 1991, additional
activities related to the backwash filters and the post-chlorination unit occurred.
Following initial construction modifications, there was a plant shakedown period to
demonstrate the successful achievement of the design criteria. The test period, which
included treated water quality monitoring in accordance with a monitoring program
developed by NDDH, indicated the plant consistently reduced arsenic concentrations
from approximately 85 |ig/L in the source water to 2 |ig/L following treatment.
Following the operational and functional determination, the City of Wyndmere assumed
responsibility for the ongoing operation and maintenance of the treatment system.
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Because of the change in the arsenic MCL from 50 |ig/L to 10 |ig/L, additional rural
users required connection to SEWUD. In the interim, users were provided with bottled
water. As part of Segment 1 construction for OU1, the City of Wyndmere was connected
to SEWUD. Construction activities in Wyndmere began in August 2005 and were
completed in October 2006 and Wyndmere became part of OU1.
4.3 Operation and Maintenance (O&M)
As described in the Site's decision documents, each respective locality assumed long-
term water treatment plant O&M responsibilities: the City of Lidgerwood for the
Lidgerwood treatment plant, the City of Wyndmere for the Wyndmere treatment plant
and SEWUD for its water treatment plant. Following the connection of the cities of
Wyndmere and Lidgerwood to SEWUD's treatment plant, these two cities were no
longer responsible for treatment plant O&M activities. SEWUD assumed responsibility
for O&M of the SEWUD treatment plant in July 1, 1993. This responsibility continues.
The primary activities associated with O&M for the treatment and distribution systems
include:
Water supply well operation and maintenance;
Routine treatment plant process monitoring and quality control;
Distribution system operation and maintenance;
Maintenance of chemical delivery lines and filtration units; and
Water quality reporting to NDDH.
The above activities are conducted according to the O&M plan; no deviations from these
activities were noted during the site inspection conducted on July 1, 2013.
According to the Site's 2009 ESD, NDDH is responsible for overseeing the operation and
maintenance of the remedy and the implementation of institutional controls. Further,
according to the 2009 ESD, EPA is not responsible for future improvements to the public
water system, barring changes to the protectiveness of the remedy. EPA provides
oversight and prepares the FYR reports.
5.0 Progress Since the Last Five-Year Review
The protectiveness statement from the 2008 FYR for the Site stated:
The remedy is expected to be protective of human health and the environment upon completion,
and in the interim, exposure pathways that could result in unacceptable risks are being
controlled. Many rural users have well water that contains arsenic at or above the new arsenic
MCL (effective February 2002; enforceable January 2006). In order to be protective, EPA in
coordination with NDDH and the SEWUD should connect qualified rural users to the SEWUD
system and upgrade the SEWUD system to be able to handle the increased demand. Bottled
water should continue to be provided to rural users until those rural users are connected to the
SEWUD system or until they refuse to be connected. The SEWUD needs to continue operating
and maintaining their water treatment plant in order to be able to continue providing safe
18
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drinking water to users. Finally, EPA and NDDH must work together to develop ICs that will
ensure new rural users are informed of the health hazards associated with the consumptive use
of groundwater from private wells in the project area.
The 2008 FYR included six issues and recommendations. This report summarizes each
recommendation and its current status below.
Table 2: Progress on Recommendations from the 2008 FYR
Kccummcmhilions
Psirlj
Responsible
Milcslonc
Diilo
Action Tiikiwi ;iihI
OlMCOIllC
Diiio or
Action
The lead for the bottled water
program is transferring from
EPA Region 8 removal
program to NDDH. NDDH
needs to continue to provide
bottled water to rural users until
those rural users are connected
or refuse connections to the
SEWUD system.
EPA/NDDH
10/01/08
The lead was transferred
to NDDH to provide
bottled water until
connections to the
SEWUD system are
made. Complete.
10/01/08
Design and construct
additional connections,
treatment plant modifications,
storage reservoir modifications
and well field expansion.
EPA/NDDH
2010
Completed as part of
Segment 5.
09/01/11
Institutional controls should be
implemented to inform new
rural users that their wells may
contain arsenic above the MCL
EPA/NDDH
1Q2009
Informational institutional
controls are documented
in a 2009 ESD and
implemented by NDDH.
Complete.
9/5/2013
The City of Lidgerwood
decided to participate in an
EPA demonstration project and
has taken on financial
responsibility and O&M of its
treatment system.
City of
Lidgerwood
TBD
Lidgerwood was
connected to the SEWUD
system and signed a water
purchaser agreement with
SEWUD. Complete.
02/11/10
EPA and NDDH need to decide
if the groundwater monitoring
component of the ROD is
necessary.
EPA/NDDH
1Q2009
The 2009 ESD eliminated
the monitoring
component. Complete.
02/23/09
Coordinate with NDDH to
develop and implement
institutional controls that will
provide long-term
protectiveness for the Site.
EPA/NDDH
1Q2009
Informational institutional
controls are documented
in a 2009 ESD and
implemented by NDDH.
Complete.
9/5/13
As shown in Table 2, informational institutional controls have been documented in the 2009
ESD.
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6.0 Five-Year Review Process
6.1 Administrative Components
EPA Region 8 started the FYR in December 2012 and scheduled its completion for
September 2013. EPA Remedial Project Manager (RPM) Frances Costanzi led the EPA
site review team, with contractor support provided to EPA by Skeo Solutions. The review
schedule established consisted of the following activities:
Community notification,
Document review,
Data collection and review,
Site inspection,
Local interviews, and
FYR Report development and review.
6.2 Community Involvement
EPA will make the final FYR Report available to the public. EPA will place copies of the
document in the designated site repository: Southeast Water Users District,
206 Main Street, Mantador, North Dakota 58058. Upon completion of the FYR, EPA will
place a public notice in The Daily News in Wahpeton to announce the availability of the
final FYR Report in the Site's document repository. The FYR Report will also be
available on EPA's website.
6.3 Document Review
This FYR included a review of relevant, site-related documents, including the ROD,
ROD Amendment, ESDs, remedial action reports and recent monitoring data. A complete
list of the documents reviewed can be found in Appendix A.
ARARs Review
Remedial actions are required to comply with the chemical-specific ARARs identified in
the ROD. In performing the FYR for compliance with ARARs, only those ARARs that
address the protectiveness of the remedy are reviewed. No new or changed ARARs were
identified that would impact the protectiveness of the remedies
Institutional Controls Review
Specific institutional controls were outlined in the Site's 2009 ESD, which included four
informational institutional controls as well as evaluation and implementation of four
additional institutional controls, if feasible. A summary of the institutional controls and
when each was implemented is summarized in Table 3.
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Table 3: Institutional Control (IC) Summary Table for QUI and OU2 Groundwater
ICs
Needed?
I( s Kc(|iiiml
b\ Decision
Document?
l( OI>.jcc(i\c
I( 1 IISlI'llIllCIII ill PlilCC
Yes
Yes, 2009 ESD
If feasible, restrict or prohibit
domestic use of water from the
shallow aquifer.
None3
ICs established that educate, inform
and notify residents and well drillers
that shallow groundwater within the
Site may contain arsenic levels
above SDWA MCLs and that there
are potential risks of consuming
arsenic-contaminated water.
EPA/NDDH prepared a fact sheet and posted
on their websites.
SEWUD included fact sheet in annual water
quality reporting to its members.
NDDH provided fact sheet to State Water
Commission.
NDDH provided fact sheet to Board of Water
Well Contractors and North Dakota certified
well drillers.
NDDH informed local government officials to
include a notification to be added to building
permits.
NDDH implemented a review of the "One
Call" system prior to domestic well drilling to
provide further notification to residents
regarding the contaminated groundwater.
NDDH/EPA continue to work with SEWUD
to discuss various options for expanding their
informational outreach to non-members in the
26 townships within the Site
a. NDDH did not designate the Site as a groundwater protected area because of the high spatial variability in the
distribution of arsenic exceeding the MCL of 10 |ig/L: establishing the entire site as a "protected area" was
considered but determined infeasible since it would prohibit the installation of wells in areas where arsenic in
groundwater is below the arsenic MCL.
As shown in Table 3, NDDH investigated designating the site area as a "groundwater
protected area" in order to address the institutional control objective of restricting or
prohibiting domestic use of water from the shallow aquifer. However, because of the high
variability in the distribution of elevated arsenic concentrations this institutional control
was deemed infeasible. Although well drillers are responsible for furnishing a fact sheet
to customers requesting a new well on their property, there is no requirement that the well
be sampled prior to use to ensure that the MCL for arsenic is not exceeded.
The remaining institutional controls implemented were informational, meeting the
institutional control objective of educating, informing and notifying residents and well
drillers that shallow groundwater within the Site may contain arsenic levels above SDWA
MCLs and that there are potential risks of consuming arsenic-contaminated water.
EPA and NDDH prepared a fact sheet for inclusion with the mailing of the annual water
quality report to SEWUD members as summarized in the CCRs. The fact sheet was
included in the CCR mailing to inform SEWUD members about the Site, arsenic in the
groundwater that exceeds drinking water standards, and options available for residential
users with concerns about their well water. The CCR reports and facts sheets are mailed
to rural water subscribers in May of each year with the inclusion of the fact sheet starting
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in May of 2012. The fact sheet is also posted on SEWUD's website
(http://www.seh2o.com/index.php) as well on NDDH's website
(http://www.ndhealth.gov/WQ/GW/pubs/FinalATSFactSheet.pdf). while EPA Region 8
has posted links to NDDH and SEWUD websites where the fact sheet can be located.
NDDH does not require permits for potable wells to be drilled on private property.
NDDH receives drilling logs from the State Water Commission and enters them into its
database, which can be accessed on a searchable Web page. On a quarterly basis, NDDH
personnel search the database for wells which have been installed within the Site
boundary. Searches were conducted by NDDH on July 25, 2012; September 19, 2012;
December 27, 2012; March 7, 2013; and June 20, 2013, while letters and fact sheets were
sent on June 20, 2013. An example of the letters is included in Appendix E. In addition,
the SWC sends out drilling contractor license renewals each December, at which time
fact sheets are included in the renewal notices. NDDH provided the fact sheet to the State
Water Commission prior to its mailing in December 2011 and 2012.
Since county officials in Richland and Sargent counties do not issue building permits or
require permits for new well installations for construction projects in the 26 townships
included in the Site, NDDH furnished fact sheets to Mr. Steve Ginsbach, District Director
of Southeast North Dakota for the North Dakota Township Officers Association, which
oversees townships within the Site. Fact sheets were sent to Mr. Ginsbach on June 28,
2013 for distribution to each individual township officer in support of the review of all
building projects within a particular township by the Board of Township Supervisors.
In addition, NDDH reviews the North Dakota One Call Records to identify residents
planning to drill a domestic well and inform these new well users of the Arsenic Trioxide
Superfund Site. NDDH reviewed the One Call Records on March 7, 2013 and June 20,
2013 and sent letters on June 20, 2013.
Copies of NDDH correspondence documenting the distribution of information to various
agencies is provided in Appendix E.
6.4 Data Review
The Site's 2009 ESD required the implementation of informational institutional controls,
which includes the submittal of the CCRs. Thus, the available data used for this FYR are
those data collected in support of the CCRs specifically for SEWUD-East water treatment
plant, since this plant services the Site. In preparing this FYR Report, data from the CCRs
and recent data received from SEWUD for its East water treatment plant servicing the
site was reviewed. Arsenic concentrations in the treated water samples are listed in Table
4. Complete laboratory results for the analysis performed in 2013 are included in
Appendix F.
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Table 4: Summary of SEWUD Arsenic Concentrations
Concentration (jig/L)
Sample Date
Sample Result Source
7.1
2008
2009 SEWUD Annual Water Quality
Report for Year Ending 2008; and 2010
SEWUD Annual Water Quality Report
for Year Ending 2009
9.73
2010
2011 and 2012 CCRs
9.45
2/27/2013
SEWUD-East correspondence
The purpose of this monitoring is to confirm that the SEWUD-East water treatment plant
servicing the Site is producing water that meets the SDWA MCLs. As shown above, the
treated water from the SEWUD-East water plant continues to meet the currently
enforceable MCL of 10 |ig/L for arsenic. However, SEWUD is only requested by NDDH
to sample for arsenic every two years. Since the concentrations measured in 2010 and
2013 have increased since 2008, annual sampling of arsenic is recommended at the
SEWUD-East to ensure the concentrations of arsenic remain below the MCL of 10 |ig/L.
Site Inspection
A site inspection was conducted on July 1, 2013. The purpose of the site inspection was
to observe site conditions and interview, where appropriate, state government personnel
and other people associated with the Site. Parties in attendance at the site inspection
included: Frances Costanzi (EPA RPM), Carl Anderson (NDDH), Steve Hansen
(SEWUD), Brian Bergantine (AE2S), and Treat Suomi and Claire Marcussen (Skeo
Solutions). For a full list of site inspection activities, see the Site Inspection Checklist in
Appendix C. For photographs of the Site, see Appendix D.
The site inspection began in a conference room at SEWUD, where Ms. Costanzi provided
an overview of the status of the Site and summarized the overall objectives of the FYR
process. Ms. Costanzi also indicated that the site information repository needs to be
updated to include copies of all current documents available for public review. Mr.
Hansen and Mr. Bergantine then provided an overview of the various segments installed
as part of the phased remedial action that occurred at the Site. Following the meeting, Mr.
Hansen led a tour of the Site, beginning with the geothermal unit and associated
generator located at the SEWUD building. This equipment was installed as part of the
ARRA funding received for the Site. Site inspection participants then toured the
SEWUD-East, viewing the series of water filters as well as pumps and chemical
treatment lines inside the plant building. The control room was also viewed. The tour
then proceeded outdoors to include the fill stands that deliver treated water to users
without a potable connection, followed by visits to the well field located in the Sheyenne
National Grasslands. Production wells in the well field were observed to be secured and
in good condition. The tour then concluded with visits to underground reservoirs
identified as Reservoir N and Reservoir G.
23
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6.6 Interviews
The FYR process included interviews with NDDH, the O&M contractor and SEWUD.
The purpose was to document the perceived status of the Site and any perceived problems
or successes with the phases of the remedy implemented to date. All of the interviews
took place following the site inspection in July 2013. The interviews are summarized
below. Appendix B provides the complete interviews.
Carl Anderson: Carl Anderson (NDDH) indicated that, overall, the project has been a
success because of a cooperative effort between State and federal agencies, the local rural
water system and rural residents. The remedy continues to successfully treat water to
arsenic concentrations below the MCL of 10 |ig/L. Mr. Anderson indicated that he has
not received any complaints or concerns regarding the project from qualified rural
residents, residents whose private well exceeded the MCL for arsenic. NDDH has
received inquiries related to sampling private wells and funding options that may be
available for non-qualified rural residents to connect to the rural water system. Site work
in the past five years includes upgrades to the SEWUD treatment plant, well field, water
storage reservoirs and water distribution system. Mr. Anderson is comfortable with the
current institutional controls.
Steve Hansen: Steve Hansen (SEWUD) is the general manager of SEWUD. Mr. Hansen
stated that for a project of this size, coordinating contractors for the different segments
was successful. Efficiencies were identified by using existing infrastructure in some areas
and using existing SEWUD-East pumping stations by upgrading the pumps and controls
to handle the additional users. Mr. Hansen indicated that the remedy is performing well
and that arsenic concentrations continue to be maintained below the MCL. He also
indicated that no unexpected O&M difficulties have occurred and efficiencies have been
observed. The efficiencies include the addition of more energy efficient pumps and
variable frequency drives installed on the pumps, which saves on electricity, as well as
the automation the backwash system at the water treatment plant.
Brian Bergantine. P.E.: Mr. Bergantine is the operations manager for O&M contractor
AE2S and oversees O&M activities for the project on behalf of SEWUD. Mr. Bergantine
indicated that the selected remedy is operating and functioning well and that the remedy
has been a very good solution to supplying potable water to rural users impacted by
arsenic contamination in their private wells. Monitoring as documented by NDDH shows
that rural residents are being supplied with water that is below the MCL for arsenic. A
continuous monitoring of the remedy is not occurring since the SEWUD-East water
treatment plant has been improved to better remotely monitor the operations of the water
treatment plant through the Supervisory Control and Data Acquisition (SCADA) system.
The SCADA system allows for remote real-time monitoring. Mr. Bergantine is not aware
of any significant changes in Site O&M activities or unexpected O&M difficulties. Mr.
Bergantine noted that efficiencies were realized with the treatment system when new
variable frequency drive motors were installed on the pumps that allow for much more
efficient operations at the water treatment plant.
24
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7.0 Technical Assessment
7.1 Question A: Is the remedy functioning as intended by the decision documents?
Yes. The review of documents, data, ARARs, interviews and the results of the Site
inspection indicate that overall the remedy is functioning as intended by the ROD and
ROD Amendment, as modified by the ESDs, to include implementation of informational
institutional controls. Rural users whose wells exceed the current MCL for arsenic of 10
|ig/L have been provided with a connection through multiple phases of expansions to
SEWUD-East, with the final expansion completed in September 2011. NDDH furnished
information regarding institutional controls for the FYR that support the conclusion that
the remedy is functioning as intended. However, in order to ensure that informational
institutional controls continue to function as designed, NDDH should provide EPA
regular updates of their findings and activities. In addition, efforts should be made to
provide fact sheets to owners of new wells as quickly as possible.
Treated water samples from SEWUD-East are sampled and analyzed for arsenic once
every two years. Based on a review of available data the concentration of arsenic detected
in 2010 and 2013 are close to the MCL. Therefore, it is recommended that arsenic in
treated water be analyzed on a more frequent basis to ensure that the treated water
remains below the MCL for arsenic.
7.2 Question B: Are the exposure assumptions, toxicity data, cleanup levels and remedial
action objectives (RAOs) used at the time of remedy selection still valid?
Yes. The exposure assumptions, toxicity data and RAO used at the time of remedy
selection are still valid. The cancer slope factor originally used to evaluate drinking water
human health risks associated with arsenic at the time of the RI was 15.0 milligrams per
kilogram per day"1 (mg/kg/day)"1,which is more stringent than the current cancer slope
factor of 1.5 mg/kg/day"1. Since the cleanup goal selected was the SDWA MCL rather
than a risk based concentration in drinking water, the availability of a less stringent
toxicity value does not impact the protectiveness of the remedy. The SDWA MCL for
arsenic was 50 |ig/L at the time of the ROD and was subsequently lowered to 10 |ig/L.
This ARAR change was documented in the 2009 ESD. The periodic monitoring of the
treated water from SEWUD-East indicates that the dissolved concentrations of arsenic
remain below the current MCL of 10 |ig/L.
The RI indicated that the most likely exposure pathway to arsenic is from human
ingestion of groundwater or from consumption of locally raised meat or dairy products.
Any locally produced meat or dairy products have the potential to contribute arsenic to
the human diet, since the livestock may have been exposed for a significant length of
time to elevated levels of arsenic in untreated groundwater. This exposure pathway may
still be occurring, if domestic/irrigation wells continue to be used for watering livestock
instead of using treated water from the distribution system. The RI also indicated that
forage grasses and woody-stemmed bushes are not expected to contribute to elevated
arsenic levels in locally raised grazing animals, due to lack of uptake from soils.
25
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Contaminant source areas were not located during the RI and samples taken along a
confirmed area of bait-spreading indicated no evidence of remnant arsenic within the
soils, while samples collected from other areas of the Site resulted in similar results.
According to the Natural Research Council (NRC)1 chronic oral arsenic toxicosis in
domestic animals is seldom reported; the reason for this may be the fact that arsenic is
relatively nontoxic to domestic animals and is typically excreted in the urine rather than
absorbing it into their bodies. A study of dairy cows in Minnesota determined that arsenic
does not transfer into milk or cheese, even from cattle exposed to arsenic at 10 times the
human drinking water standard . In addition, the NRC indicates that arsenic is often
added as a mineral along with other metals to livestock feed for growth promotion.
Considering the low potential for uptake from site soils and for transfer through the food
chain, the cleanup level and RAO are appropriate for this pathway.
With respect to livestock and poultry themselves, an acceptable upper limit of 200 |ig/L
for arsenic contained in water for livestock and poultry has been established by the
Montana, Missouri and Ohio State Extension Services.3'4'5 The RI indicated only four out
of 437 public and private wells sampled exceeded the safe upper limit of 200 |ig/L for
watering livestock and poultry. The current fact sheet used as part of the informational
institutional control currently only addresses potable use of the groundwater and does not
address the potential for adverse effects associated with using untreated well water for
watering livestock.
Although a number of lakes are located within the Site boundary, the RI determined the
lakes are primarily recharging groundwater, thus impacted groundwater is not
discharging to the lakes. Further, although overland flow may occur during heavy
precipitation events and during snow melt which could transport soil to downgradient
lakes, this contaminant migration pathway is considered incomplete, however, since
source area soils have not been identified during the RI.
7.3 Question C: Has any other information come to light that could call into question the
protectiveness of the remedy?
No. No additional information has become available that could call into question the
protectiveness of the remedy.
1 Mineral Tolerance of Animals: Second Revised Edition, Natural Research Council
(http://www.nap.edu/catalog/11309.html)
2 Assessing the Impact of Arsenic on Upper-Midwestern Dairy Operations. University of Minnesota, Water
Resources Center, http://wrc.umn.edu/randpe/agandwq/arsenicanddairies/index.htm
3 When is Water Good Enough for Livestock? By Jim Bauder MSU Extension Soil and Water Quality Specialist
http ://www. montana.edu/cpa/news/wwwpb -archive s/ag/baudr 146. html
4 Water Quality for Livestock Drinking, By Donald L. Pfost and Charles D. Fulhage Agricultural Engineering
Extension, University of Missouri Extension. http://extension.missouri.edu/i3/E03 81
5 Livestock and Water, by Stephen Boyles Ohio State University Extension Beef Specialist. Ohio State University
Extension http://beef.osu.edu/library/water.html
26
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7.4 Technical Assessment Summary
The review of decision documents, ARARs and the results of the site inspection indicate
that parts of the remedy are functioning as intended by the ROD and 2009 ESD and other
Site decision documents. Although contaminated source soils were not identified,
historical use of pesticides has potentially impacted a number of rural wells; the majority
of the residences using these wells have been connected to a treated water distribution
system. In addition, informational controls are in place to inform potential well users that
the groundwater may be contaminated with arsenic above the MCL. However, in order to
ensure that informational institutional controls continue to be effective, NDDH should
provide EPA routine updates of their findings and activities. In addition, efforts should be
made to provide fact sheets to owners of new wells as quickly as possible. Further,
treated water samples from SEWUD-East are only sampled and analyzed for arsenic once
every two years with concentrations of arsenic detected close to the MCL. Therefore, it is
recommended that arsenic in treated water be analyzed on a more frequent basis to ensure
that the treated water remains below the MCL for arsenic. In addition, it is recommended
that the fact sheet be revised to discuss the potential for adverse effects on livestock
associated with watering animals with untreated Site groundwater.
8.0 Issues
Table 5 summarizes the current site issues.
Table 5: Current Site Issues
Issue
Affects Cu rrcnt
Protcctivcncss?
(Yes or No)
Affects Future
Protcctivcncss?
(Yes or No)
SEWUD-East water treatment plant only monitors
arsenic in treated water every two years.
No
Yes
NDDH has not provided EPA with regular updates to
demonstrate that informational institutional controls
are adequate for achieving site RAOs.
No
Yes
The current fact sheet does not address uses of rural
wells for watering livestock and poultry
No
Yes
9.0 Recommendations and Follow-up Actions
Table 6 provides recommendations to address the current site issues.
27
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Table 6: Recommendations to Address Current Site Issues
Affects
Issue
Recommendation /
Party
Oversight
Milestone
Protectiveness?
.Follow-Up Action
Responsible
Agency
Date
(Yes or No)
Cu rrent
Future
SEWUD-East
Monitor arsenic
water treatment
concentrations in
Plant only monitors
arsenic in treated
treated water on a more
frequent basis to ensure
NDDH
EPA
09/01/2014
No
Yes
water every two
it is below the MCL for
years.
arsenic.
NDDH has not
Provide EPA
provided EPA with
information on a
regular updates to
demonstrate that
informational
regular basis
summarizing the
activities related to
NDDH
EPA
09/01/2014
No
Yes
institutional
ensuring informational
controls are
institutional controls
adequate for
achieving site
RAOs.
are adequate.
The current fact
Revise the fact sheet to
sheet does not
address watering of
address uses of
rural wells for
livestock and poultry.
NDDH
EPA
09/01/2014
No
Yes
watering livestock
and poultry
The following additional items that do not affect protectiveness warrant additional follow up:
Update the site repository to include copies of all current documents available for public
review
10.0 Protectiveness Statements
OUl
The remedy at OUl currently protects human health and the environment because the SEWUD-
East water treatment plant has been upgraded and expanded to provide rural users, formerly on
privately owned, impacted wells, with potable water that meets the arsenic MCL. However, in
order for the remedy to be protective in the long term, treated groundwater should be monitored
on a more frequent basis, a summary of institutional control activities and results should be
submitted to EPA on a regular basis, and the Site fact sheet should be updated to discuss
watering of livestock and poultry.
28
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0U2
The remedy at 0U2 is protective of human health and the environment. Rural users who had
relied on the Wyndmere and Lidgerwood water treatment plants are now connected to the
SEWUD-East water treatment plant.
Site-wide
Because the remedial actions at OU1 are protective in the short term, the Site is protective of
human health and the environment in the short term. However, in order for the remedy to be
protective in the long term, treated groundwater should be monitored on a more frequent basis, a
summary of institutional control activities and results should be submitted to EPA on a regular
basis, and the Site fact sheet should be updated to discuss watering of livestock and poultry.
11.0 Next Review
The next FYR will be due within five years of the signature/approval date of this FYR.
29
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Appendix A: List of Documents Reviewed
United States Environmental Protection Agency, 1986. OU1 Record of Decision, EPA ID
NDD980716963.
United States Environmental Protection Agency, 1988. OU2 Record of Decision Amendment,
EPA ID NDD980716963.
United States Environmental Protection Agency, 1992. OU2 Explanation of Significant
Difference, EPA ID NDD980716963.
United States Environmental Protection Agency, 1992. Preliminary Close Out Report, EPA ID
NDD980716963.
United States Environmental Protection Agency, 1993. Final Close Out Report, EPA ID
NDD980716963.
United States Environmental Protection Agency, 1999. First Five-Year Review, EPA ID
NDD980716963.
United States Environmental Protection Agency, 2003. Second Five-Year Review, EPA ID
NDD980716963.
United States Environmental Protection Agency, 2007. OU 1 Explanation of Significant
Difference, EPA ID NDD980716963.
United States Environmental Protection Agency, 2008. OU 1 Explanation of Significant
Difference, EPA ID NDD980716963.
United States Environmental Protection Agency, 2008. Third Five-Year Review Report, EPA ID
NDD980716963.
United States Environmental Protection Agency, 2009. OU 1 Explanation of Significant
Difference, EPA ID NDD980716963.
United States Environmental Protection Agency, 2009. Remedial Action Report Rural Water
System Expansion - Segment 3, EPA ID NDD980716963.
United States Environmental Protection Agency, 2010. Annual Update to the Five-Year Review,
EPA ID NDD980716963.
North Dakota Department of Health, 2011. Arsenic Trioxide Superfund Site Fact Sheet: What
you should know if you drink water from a well,
(http://www.ndhealth.gov/WO/GW/pubs/FinalATSFactSheet.pdf)
A-l
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Southeast Water Users District, 2009. Annual Drinking Water Quality Report for the Year
Ending 2008.
Southeast Water Users District, 2010. Annual Drinking Water Quality Report for the Year
Ending 2009.
Southeast Water Users District, 2011. Consumer Confidence Report (CCR).
Southeast Water Users District, 2012. Consumer Confidence Report (CCR).
A-2
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Appendix B: Interview Forms
Arsenic Trioxide Superfund Site
Five-Year Review Interview Form
Site Name: Arsenic Trioxide
Interviewer
Name:
Claire Marcussen
Subject Name:
Time: 1:30 P.M.
Brian Bergantine
EPA ID No.:
Affiliation:
Affiliation:
Date:
NDD980716963
Skeo Solutions
AE2S (O&M Contractor)
07/08/2013
Interview Format (circle one): In Person
Phone
Mail
Other
Interview Category: O&M Contractor
1. What is your overall impression of the project, including cleanup, maintenance and reuse
activities (as appropriate)?
It is my impression that the project went very well and the remedy supplied by SEWUD
(Rural Water) has been a very good solution. The contractors did a very good job of cleanup
prior under each segment of the project.
2. What is your assessment of the current performance of the remedy in place at the Site?
My assessment of the current performance of the remedy in place at the Site is that it is
working very well. The residents living within the site boundary now have a potable source
water which has arsenic concentrations below the MCL established by EPA.
3. What are the findings from the monitoring data? What are the key trends in contaminant
levels that are being documented over time at the Site?
The findings were documented by NDDH during its monitoring of the wells. This data was
used to determine the impacted residents.
Because the remedy hooked up the residents with elevated arsenic concentrations in their
drinking water and provided them with potable water that has arsenic concentrations below
the MCL, I would say the key trend is that all residents that signed up for rural water from
SEWUD are being protected.
4. Is there a continuous on-site O&M presence? If so, please describe staff responsibilities and
activities. Alternatively, please describe staff responsibilities and the frequency of site
inspections and activities if there is not a continuous on-site O&M presence.
Although the staff is not continuously on site at the SEWUD water treatment plant,
improvements were implemented under this project that allow SEWUD staff to better
remotely monitor plant operations through the SCADA system. The staff visits the plant
routinely as part of O&M activities; however, I'm unaware of the exact frequency.
B-l
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5. Have there been any significant changes in site O&M requirements, maintenance schedules
or sampling routines since startup or in the last five years? If so, do they affect the
protectiveness or effectiveness of the remedy? Please describe changes and impacts.
To my knowledge, there have not been any significant changes in site O&M requirements,
maintenance schedules or sampling routines. However, as stated above, the new SCADA
system has allowed the staff to better monitor and control the operations of the water
treatment plant.
6. Have there been unexpected O&M difficulties or costs at the Site since startup or in the last
five years? If so, please provide details.
To my knowledge, there have not been any unexpected O&M difficulties or costs since
startup. Currently, arsenic is co-precipitated with the removal of the iron from the water. As
was discussed during the FYR meeting in Mantador, if the well water quality was found to
not have high enough iron concentrations in it for co-precipitation of arsenic with the iron,
there may be a need to add a ferric coagulant. The concentration of iron within the wells is
currently high enough to effectively reduce the arsenic concentrations below the MCL
without the addition of a ferric coagulant.
7. Have there been opportunities to optimize O&M activities or sampling efforts? Please
describe changes and any resulting or desired cost savings or improved efficiencies.
I am not aware of any opportunities to optimize O&M activities after the project was
implemented, but this question would be better directed to the SEWUD General Manager.
During the project, new variable frequency drive motors were installed on the pumps, which
allow for much more efficient operations at the water treatment plant. Additionally, the
installation of the new SCADA system has allowed plant staff to better manage their time by
allowing them to remotely monitor and operate the facility.
8. Do you have any comments, suggestions or recommendations regarding O&M activities and
schedules at the Site?
No additional comments.
B-2
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Arsenic Trioxide Superfund Site
Five-Year Review Interview Form
Site Name: Arsenic Trioxide
Interviewer Name: Claire Marcussen
Subject Name: Steve Hansen
EPA ID No.: NDD980716963
Affiliation: Skeo Solutions
Affiliation: Southeast Water Users
Time: 4:00 P.M.
District (SEWUD)
Date: 07/08/2013
Interview Format (circle one): In Person Phone Mail
Other
Interview Category: O&M Contractor
1. What is your overall impression of the project, including cleanup, maintenance and reuse
activities (as appropriate)?
I think for a project of this size and how it had to be bid in different segments, according to
the funding that was available, it went together well. We were able to keep the project
moving forward each year. In a lot of the areas, we were able to tie into existing
infrastructure. We were also able to use our existing pumping stations by just upgrading the
pumps and controls to handle the additional users. We had very few issues with cleanup for
the miles of water lines that were installed.
2. What is your assessment of the current performance of the remedy in place at the Site?
I think the system is performing very well as of today.
3. What are the findings from the monitoring data? What are the key trends in contaminant
levels that are being documented over time at the Site?
We are getting good removal of contaminants and have met all NDDH standards in
maintaining levels that are below the MCL established by EPA.
4. Is there a continuous on-site O&M presence? If so, please describe staff responsibilities and
activities. Alternatively, please describe staff responsibilities and the frequency of site
inspections and activities if there is not a continuous on-site O&M presence.
There is not someone on site continuously. We do have operators on site at the SEWUD
water treatment plant on a daily basis to do testing to make sure we are getting proper
removal from our filters. We also have a SCADA system to monitor the plant operations
remotely from our office. We are also able to monitor all pumping stations from our office
and on operators' cell phones.
5. Have there been any significant changes in site O&M requirements, maintenance schedules
or sampling routines since startup or in the last five years? If so, do they affect the
protectiveness or effectiveness of the remedy? Please describe changes and impacts.
No real changes as we were already monitoring all sites. By upgrading some of the computer
equipment, we are now able to get more information through our SCADA system.
B-3
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6. Have there been unexpected O&M difficulties or costs at the Site since startup or in the last
five years? If so, please provide details.
There have been no unexpected O&M difficulties at the Site.
7. Have there been opportunities to optimize O&M activities or sampling efforts? Please
describe changes and any resulting or desired cost savings or improved efficiencies.
We have been able to optimize O&M activities with the addition of more energy efficient
pumps and variable frequency drives that save on electricity and also by automating our
backwash system at the water treatment plant. We are able to do a better job of maintaining
our filters.
8. Do you have any comments, suggestions or recommendations regarding O&M activities and
schedules at the Site?
This project has helped cities and rural residents with high levels of arsenic in their drinking
water. It has given them the opportunity to have access to a safe source of drinking water.
B-4
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Arsenic Trioxide Superfund Site
Five-Year Review Interview Form
Site Name: Arsenic Trioxide
Interviewer Name: Claire Marcussen
Subject Name: Carl Anderson
EPA ID No.: NDD980716963
Affiliation: Skeo Solutions
Affiliation: North Dakota Department of
Health (NDDH)
Time: 8:00 A.M.
Date: 07/12/1013
Interview Format (circle one): In Person Phone Mail
Other
Interview Category: State Agency
1. What is your overall impression of the project, including cleanup, maintenance and reuse
activities (as appropriate)?
The project provided the opportunity for qualified rural residents to obtain a safe source of
drinking water. The project required a cooperative effort between state and federal agencies,
the local rural water system, and rural residents. The remedy implemented was successful at
meeting the objectives of the project.
2. What is your assessment of the current performance of the remedy in place at the Site?
SEWUD is required to comply with the SDWA, which includes compliance sampling. The
analytical results from the most recent arsenic test (samples collected in 2010) indicated that
arsenic was present in the treated water at a concentration of 9.73 parts per billion, which is
below the arsenic MCL of 10 parts per billion. Therefore, the water treatment system is
reducing arsenic concentrations in the raw water supply to a level that is protective of human
health.
3. Are you aware of any complaints or inquiries regarding site-related environmental issues or
remedial activities from residents in the past five years?
The project was only available to qualified rural residents, which included those living within
the site boundary whose domestic water supply contained arsenic at a concentration greater
than the arsenic MCL. NDDH has received inquiries regarding the inclusion of rural
residents living outside the site boundary. Other inquiries received included questions related
to sampling private wells and funding options that may be available for non-qualified rural
residents to connect to the rural water system.
4. Has your office conducted any site-related activities or communications in the past five
years? If so, please describe the purpose and results of these activities.
The grant for the project ended on December 30, 2012; site work was ongoing during the
past five years. Site work included upgrades to the SEWUD treatment plant, well field, water
storage reservoirs and water distribution system. Other activities associated with the site
included sampling private wells, attending design and construction meetings, completing
project management and oversight, and completing project reports.
B-5
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5. Are you aware of any changes to state laws that might affect the protectiveness of the Site's
remedy?
No.
6. Are you comfortable with the status of the institutional controls at the Site? If not, what are
the associated outstanding issues?
Yes.
7. Are you aware of any changes in projected land use(s) at the Site?
The Site encompasses approximately 936 square miles of primarily agricultural land. I am
not aware of any significant land use changes; however, changes (e.g., housing
developments) may have occurred.
8. Do you have any comments, suggestions or recommendations regarding the management or
operation of the Site's remedy?
SEWUD is responsible for the oversight, operation and maintenance of the water treatment
plant and water distribution system and is required to maintain compliance with the
provisions of the SDWA. SEWUD has provided reliable service throughout the duration of
the project and I expect that to continue.
B-6
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Appendix C: Site Inspection Checklist
FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST
I. SITE INFORMATION
Site Name: Arsenic Trioxide Site
Date of Inspection: 07/01/2013
Location and Region: Ransom, Richland and
Sargent Counties, ND/Region 8
EPA ID:NDD980716963
Agency, Office or Company Leading the Five-Year
Review: EPA Region 8
Weather/Temperature: 80s and Sunny
Remedy Includes: (Check all that apply)
~ Landfill cover/containment
~ Access controls
^ Institutional controls
Groundwater pump and treatment
~ Surface water collection and treatment
n Other:
~ Monitored natural attenuation
~ Groundwater containment
~ Vertical barrier walls
Attachments: ^ Inspection team roster attached
1 1 Site map attached
II. INTERVIEWS (check all that apply)
1. O&M Site Manager Brian Bersantine Operations Manauer
Name Title
Interviewed PI at site 153 at office PI bv olionc Phone:
Problems, suggestions |~~| Report attached:
07/08/2013
Date
2. O&M Staff
Name Title
Interviewed 1 1 at site l~~l at office IH b\ ohonc Phone:
Problcms/siiaacstions |~~| Report attached:
mm/dd/wvv
Date
c-i
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3.
Local Regulatory Authorities and Response Agencies (i.e., state and tribal offices, emergency
response office, police department, office of public health or environmental health, zoning office,
recorder of deeds, or other city and county offices). Fill in all that apply.
Asencv EPA
Contact Frances Costanzi
Name
Problems/suggestions ~ Report attached:
Remedial
Proiect
Manaser
Title
Date
303-312-6571
Phone No.
Asencv NDDH
Contact Carl Andersen
Name
Problems/suggestions ~ Report attached:
Proiect
Manaser
Title
07/12/2013
Date
701-328-5213
Phone No.
Asencv SEWUD
Contact Steve Hansen
Name
Problems/suggestions ~ Report attached:
General
Manaser
Title
07/08/2013
Date
701-242-7432
Phone No.
Asencv
Contact
Name
Problems/suggestions ~ Report attached:
Title
Date
Phone No.
Asencv
Contact
Name
Problems/suggestions ~ Report attached:
Title
Date
Phone No.
4.
Other Interviews (optional) PI Report attached:
III. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply)
1.
O&M Documents
£3 O&M manual £3 Readily available
Up to date
~ n/a
1^1 As-built drawings ^ Readily available
Up to date
~ n/a
1^1 Maintenance logs ^ Readily available
Up to date
~ n/a
Remarks: North Dakota has an asreement with the SEWUD and EPA has asreed with North Dakota
2.
Site-Specific Health and Safety Plan
Readily available
13 Up to date PI N/A
1^1 Contingency plan/emergency response plan ^
Readily available
1^1 Up to date |_| N/A
Remarks:
3.
O&M and OSHA Training Records
Remarks:
Readily available
13 Up to date PI N/A
C-2
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4.
Permits and Service Agreements
~ Air discharge permit
~ Readily available
~ Up to date E
]N/A
~ Effluent discharge
~ Readily available
~ Up to date E
]n/a
~ Waste disposal, POTW
~ Readily available
~ Up to date IS
N/A
Kl Other Dcrmits: North Dakota State Dcrmit to
odcrate water treatment olant.
~ Readily available
~ Up to date IS
N/A
Remarks:
5.
Gas Generation Records
Remarks:
~ Readily available
~ Up to date E
]N/A
6.
Settlement Monument Records
Remarks:
~ Readily available
~ Up to date IS
N/A
7.
Groundwater Monitoring Records
Readily available
13 Up to date 1 1 N/A
Remarks:
8.
Leachate Extraction Records
~ Readily available
~ Up to date IS
N/A
Remarks:
9.
Discharge Compliance Records
~ Air ~ Readily available ~ Up to date
ISIn/a
~ Water (effluent) ~ Readily available ~ Up to date
ISIn/a
Remarks:
10.
Daily Access/Security Logs
Remarks:
~ Readily available
~ Up to date IS
N/A
IV. O&M COSTS
1.
O&M Organization
I~1 State in-house
I~1 PRP in-house
1 1 Contractor for state
1 1 Contractor for PRP
1 1 Federal facility in-house
1 1 Contractor for Federal facility
M SEWUD navs for the O&M costs. Costs are not separable from normal one ration costs.
C-3
-------
2.
O&M Cost Records
~ Readily available Q Up to date
~ Funding mechanism/agreement in place Unavailable
Original O&M cost estimate: _ ~ Breakdown attached
From: mm/dd/wvv
Date
From: mm/dd/wvv
Date
From: mm/dd/wvv
Date
From: mm/dd/wvv
Date
From: mm/dd/wvv
Date
Total annual cost by year for review period if available
To: mm/dd/wvv
Date
Total cost
To: mm/dd/wvv
Date
To: mm/dd/wvv
Date
To: mm/dd/wvv
Date
To: mm/dd/wvv
Date
Total cost
Total cost
Total cost
I I Breakdown attached
I I Breakdown attached
I I Breakdown attached
I I Breakdown attached
I I Breakdown attached
Total cost
3. Unanticipated or Unusually High O&M Costs during Review Period
Describe costs and reasons: None
V. ACCESS AND INSTITUTIONAL CONTROLS M Applicable ~ N/A
A. Fencing
1. Fencing Damaged
Remarks:
~ Location shown on site map ~ Gates secured
N/A
B. Other Access Restrictions
1. Signs and Other Security Measures ~ Location shown on site map ~ N/A
Remarks: Pump houses and waste treatment plant locked, secured and located in a rural area.
C. Institutional Controls (ICs)
C-4
-------
1. Implementation and Enforcement
Site conditions imply ICs not properly implemented ~ Yes E| No ~ N/A
Site conditions imply ICs not being fully enforced ~ Yes 153 No |~1 N/A
Type of monitoring (e.g., self-reporting, drive by): State is responsible for reviewing institutional controls
Frequency: Quarterly
Responsible party/agency: NDDH
Contact Carl Anderson 07/01/2013 701'328'
5213
Name Title Date Phone no.
Reporting is up to date Yes ~ No ~
N/A
Reports are verified by the lead agency
I~1 Yes
lElNo
~ n/a
Specific requirements in deed or decision documents have been met
IEI Yes
~ No
~ n/a
Violations have been reported
I~1 Yes
lElNo
~ n/a
Other problems or suggestions: Report attached
See institutional control review in Section 6.3.
2. Adequacy £3 ICs are adequate ~ ICs are inadequate ~ N/A
Remarks: See institutional control review in Section 6.3.
D. General
1. Vandalism/Trespassing ~ Location shown on site map ^ No vandalism evident
Remarks:
2. Land Use Changes On Site £3 N/A
Remarks:
3. Land Use Changes Off Site £3 N/A
Remarks:
VI. GENERAL SITE CONDITIONS
A. Roads Applicable ~ N/A
1. Roads Damaged ~ Location shown on site map ^ Roads adequate ~ N/A
Remarks:
B. Other Site Conditions
Remarks:
VII. LANDFILL COVERS ~ Applicable ^ N/A
A. Landfill Surface
1. Settlement (low spots) ~ Location shown on site map ~ Settlement not evident
Arial extent: Depth:
Remarks:
C-5
-------
2.
Cracks
1 1 Location shown on site map
1 1 Cracking not evident
Leneths:
Widths:
Deoths:
Remarks:
3.
Erosion
Arial extent:
Remarks:
1 1 Location shown on site map
1 1 Erosion not evident
Depth:
4.
Holes
Arial extent:
Remarks:
~ Location shown on site map
~ Holes not evident
Depth:
5.
Vegetative Cover
1 1 Grass
1 1 Cover properly established
I~1 No signs of stress
1 1 Trees/shrubs (indicate size and locations on a diagram)
Remarks:
6.
Alternative Cover (e g
Remarks:
r., armored rock, concrete)
~ n/a
7.
Bulges
Arial extent:
Remarks:
~ Location shown on site map
~ Bulges not evident
Heisht:
8.
Wet Areas/Water Damage Q Wet areas/water damage not evident
1 1 Wet areas
1 1 Location shown on site map
Arial extent:
1 1 Ponding
1 1 Location shown on site map
Arial extent:
I~1 Seeps
1 1 Location shown on site map
Arial extent:
1 1 Soft subgrade
1 1 Location shown on site map
Arial extent:
Remarks:
9.
Slope Instability
1 1 Slides
~ Location shown on site map
~ No evidence of slope instability
Arial extent:
Remarks:
B.
Benches ~ Applicable ~ N/A
(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in
order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)
1.
Flows Bypass Bench
Remarks:
1 1 Location shown on site map
1 1 N/A or okay
2.
Bench Breached
Remarks:
1 1 Location shown on site map
1 1 N/A or okay
C-6
-------
3.
Bench Overtopped
1 1 Location shown on site map
I~1 N/A or okay
Remarks:
C.
Letdown Channels
~ Applicable ~ N/A
(Channel lined with erosion control mats, riprap, grout bags or gabions that descend down the steep side
slope of the cover and will allow the runoff water collected by the benches to move off of the landfill
cover without creating erosion gullies.)
1.
Settlement (Low spots)
~ Location shown on site map
~ No evidence of settlement
Arial extent:
Depth:
Remarks:
2.
Material Degradation
~ Location shown on site map
~ No evidence of degradation
Material t\ Dc:
Arial extent:
Remarks:
3.
Erosion
~ Location shown on site map
~ No evidence of erosion
Arial extent:
Depth:
Remarks:
4.
Undercutting
~ Location shown on site map
~ No evidence of undercutting
Arial extent:
Depth:
Remarks:
5.
Obstructions
Tvpe:
~ No obstructions
|| Location shown on site map Arial extent:
Size:
Remarks:
6.
Excessive Vegetative Growth Tydc:
~ No evidence of excessive growth
~ Vegetation in channels does not obstruct flow
|| Location shown on site map Arial extent:
Remarks:
D.
Cover Penetrations
~ Applicable ~ N/A
1.
Gas Vents
I~1 Active
1 1 Passive
1 1 Properly secured/locked Q Functioning Q Routinely sampled Q Good condition
1 1 Evidence of leakage at penetration Q Needs maintenance Q N/A
Remarks:
C-7
-------
2
Gas Monitoring Probes
1 1 Properly secured/locked ~ Functioning ~ Routinely sampled
1 1 Good condition
1 1 Evidence of leakage at penetration ~ Needs maintenance
~ n/a
Remarks:
3
Monitoring Wells (within surface area of landfill)
1 1 Properly secured/locked ~ Functioning ~ Routinely sampled
1 1 Good condition
1 1 Evidence of leakage at penetration ~ Needs maintenance
~ n/a
Remarks:
4
Extraction Wells Leachate
1 1 Properly secured/locked ~ Functioning ~ Routinely sampled
1 1 Good condition
1 1 Evidence of leakage at penetration ~ Needs maintenance
~ n/a
Remarks:
5
Settlement Monuments ~ Located ~ Routinely surveyed
Remarks:
~ n/a
E.
Gas Collection and Treatment ~ Applicable ~ N/A
1
Gas Treatment Facilities
1 1 Flaring ~ Thermal destruction
~ Collection for reuse
1 1 Good condition ~ Needs maintenance
Remarks:
2
Gas Collection Wells, Manifolds and Piping
1 1 Good condition ~ Needs maintenance
Remarks:
3
Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)
1 1 Good condition ~ Needs maintenance ~ N/A
Remarks:
F.
Cover Drainage Layer ~ Applicable ~ N/A
1
Outlet Pipes Inspected ~ Functioning ~ N/A
Remarks:
2
Outlet Rock Inspected ~ Functioning Q N/A
Remarks:
G.
Detention/Sedimentation Ponds ~ Applicable ~ N/A
1.
Siltation Area extent: Dcoth:
1 1 Siltation not evident
Remarks:
~ n/a
C-8
-------
2.
Erosion Area extent: Depth:
1 1 Erosion not evident
Remarks:
3.
Outlet Works ~ Functioning
Remarks:
~ n/a
4.
Dam ~ Functioning
Remarks:
~ n/a
H. Retaining Walls ~ Applicable ~ N/A
1.
Deformations ~ Location shown on site map
1 1 Deformation not evident
Horizontal displacement: Vertical displacement:
Rotational displacement:
Remarks:
2.
Degradation ~ Location shown on site map
Remarks:
1 1 Degradation not evident
I. Perimeter Ditches/Off-Site Discharge ~ Applicable
~ n/a
1.
Siltation ~ Location shown on site map
1 1 Siltation not evident
Area extent:
Depth:
Remarks:
2.
Vegetative Growth ~ Location shown on site map
1 1 Vegetation does not impede flow
~ n/a
Area extent:
Tvpe:
Remarks:
3.
Erosion ~ Location shown on site map
~ Erosion not evident
Area extent:
Depth:
Remarks:
4.
Discharge Structure ~ Functioning
Remarks:
~ n/a
VIII.
VERTICAL BARRIER WALLS ~ Applicable
IE|n/a
1.
Settlement ~ Location shown on site map
~ Settlement not evident
Area extent:
Depth:
Remarks:
C-9
-------
2.
Performance Monitoring Tydc of monitoring:
1 1 Performance not monitored
Freauencv: 1"! Evidence of breaching
Head differential:
Remarks:
IX.
GROUND WATER/SURFACE WATER REMEDIES ^Applicable ~ N/A
A.
Groundwater Extraction Wells, Pumps and Pipelines £3 Applicable ~ N/A
1.
Pumps, Wellhead Plumbing and Electrical
Good condition ^ All required wells properly operating EH Needs maintenance 1 1 N/A
Remarks:
2.
Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances
Good condition EH Needs maintenance
Remarks:
3.
Spare Parts and Equipment
1^1 Readily available Good condition EH Requires upgrade EH Needs to be provided
Remarks:
B. Surface Water Collection Structures, Pumps and Pipelines ~ Applicable ^ N/A
1.
Collection Structures, Pumps and Electrical
1 1 Good condition EH Needs maintenance
Remarks:
2.
Surface Water Collection System Pipelines, Valves, Valve Boxes and Other Appurtenances
1 1 Good condition EH Needs maintenance
Remarks:
3.
Spare Parts and Equipment
1 1 Readily available EH Good condition EH Requires upgrade EH Needs to be provided
Remarks:
C.
Treatment System ^ Applicable EH N/A
C-10
-------
1.
Treatment Train (check components that apply)
Metals removal O Oil/water separation Q Bioremediation
~ Air stripping ~ Carbon adsorbers
153 Filters:
153 Additive (e.e.. chelation asent. flocculent): When needed, ferric coaeulant added to co-orecimtate
arsenic if iron in groundwater is not hieh enoueh.
I-! Others:
153 Good condition Q Needs maintenance
[53 Sampling ports properly marked and functional
[53 Sampling/maintenance log displayed and up to date
153 Equipment properly identified
I-! Ouantitv of sroundwater treated annually:
I-! Ouantitv of surface water treated annuallv:
Remarks:
2.
Electrical Enclosures and Panels (properly rated and functional)
1 1N/A £3 Good condition Q Needs maintenance
Remarks:
3.
Tanks, Vaults, Storage Vessels
1 1 N/A £3 Good condition Q Proper secondary containment
1 1 Needs maintenance
Remarks:
4.
Discharge Structure and Appurtenances
[53 N/A ~ Good condition Q Needs maintenance
Remarks:
5.
Treatment Building(s)
1 1 N/A ^ Good condition (esp. roof and doorways)
1 1 Needs repair
1 1 Chemicals and equipment properly stored
Remarks:
6.
Monitoring Wells (pump and treatment remedy)
1 1 Properly secured/locked Q Functioning Q Routinely sampled
1 1 Good condition
1 1 All required wells located ~ Needs maintenance
£3 N/A
Remarks:
D. Monitoring Data
1.
Monitoring Data
£3 Is routinely submitted on time £3 Is of acceptable quality
C-ll
-------
2. Monitoring Data Suggests: ~ N/A
I I Groundwater plume is effectively contained ^ Contaminant concentrations are declining
Remarks: Monitoring data collected by SEWUD show that arsenic is below the MCL in treated groundwater
however, monitoring is only performed every two years and the treated results are close to the MCL.
E. Monitored Natural Attenuation
1. Monitoring Wells (natural attenuation remedy)
~ Properly secured/locked ~ Functioning Q Routinely sampled
~ All required wells located ~ Needs maintenance
Remarks:
X. OTHER REMEDIES
If there are remedies applied at the site and not covered above, attach an inspection sheet describing the physical
nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.
^ N/A
XI. OVERALL OBSERVATIONS
A. Implementation of the Remedy
Describe issues and observations relating to whether the remedy is effective and functioning as designed.
Begin with a brief statement of what the remedy is designed to accomplish (e.g., to contain contaminant
plume, minimize infiltration and gas emissions).
The remedy is effectively removing arsenic from raw water through the use of a ferric coagulant and
Fillers lo reduce arsenic concentrations in treated water below the MCL.
B. Adequacy of O&M
Describe issues and observations related to the implementation and scope of O&M procedures. In
particular, discuss their relationship to the current and long-term protectiveness of the remedy.
SEWUD has not observed any issues related to the O&M procedures.
C. Early Indicators of Potential Remedy Problems
Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high
frequency of unscheduled repairs that suggest that the protectiveness of the remedy may be compromised
in the future.
Nona
D. Opportunities for Optimization
Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
Optimizations include upgrading pumps with more energy efficient models as well as automating the
backwash system.
I I Good condition
[El N/A
C-12
-------
Appendix D: Photographs from Site Inspection Visit
Southeast
Water Users
0»»l A
SEWUD Office, Mantador, North Dakota.
Geothermal unit located at the SEWUD building.
D-l
-------
Backup generator for the SEVVUD building.
SEWUD water treatment plant.
D-2
-------
Filter units inside the SEWUD water treatment plant with overhead chemical treatment lines.
Pumps inside the SEWUD water treatment plant.
D-3
-------
2007
North Dakota Arsenic
Trioxide Superfund Project
Phase IV - Segment 2
Southeast Water Users District - East
Wells and WTP Expansion
Funded by:
US Environmental Protection Agency
North Dakota Department of Health
Owner:
Southeast Water Users District
General Manager: Steve Hansen
Engineer:
AE2S
EAPC Architects and .Engineers -
Placard denoting the expansion of the SEWUD water treatment plant.
D-4
-------
Control room inside the SEWUD water treatment plant.
Fill station for water users at the SEWUD water treatment plant.
D-5
-------
Entrance to SEWUD well field, located in a wellhead protection area on the Sheyenne National
Grasslands.
Secured production well for SEWUD water treatment plant.
D-6
-------
Secured production well for SEWUD water treatment plant.
W;lV i lUi;
Southeast Water Users District
Steve Hansen, Genera! Mgr.
Placard on Reservoir N denoting completion of Segment 5 of SEWUD expansion.
D-7
-------
Exterior view of Reservoir N.
Pump located within Reservoir N.
D-8
-------
Fill station at Reservoir N.
City of Hankinson Reservoir.
D-9
-------
Exterior of Reservoir G and fill stand
Control panel inside Reservoir G.
D-10
-------
Appendix E: NDDH Correspondence and Site Fact Sheet
Documentation of SWC Database Review.
Database Searched
Domestic Wells Found
Database Searched
" 25 2>J 12
0
North Dakota State Water Commission .'SWC.
l» I'J, 2«»12
n
SWC
12 2" 2012
4
SWC
3 " 20J 3
6
SWC cV North Dakota One Cail ND1 >
o "2K/2U13
9
SWC & NDt
9- 2<»'2U1
12 ' 2i i 20
E-l
-------
NORTH DAKOTA
DEPARTMENTo/ HEALTH
ENVIRONMENTAL HEALTH SECTION
Gold Seal Center, 918 E. Divide Ave.
Bismarck, ND 58501-1947
701.328.5200 (fax)
www.ndhealth.gov
June 20, 2013
PO Box 478
Hankinson, ND 58041
City of Hankinson
Subject: Arsenic Trioxide Superfund Site
To Whom It May Concern:
This letter is to inform you that our records indicate that you recendy installed a drinking
water well within the Arsenic Trioxide Superfund Site and your well may be at risk for
elevated levels of arsenic. Arsenic is a toxic chemical that occurs naturally in the
environment in the soil, rock and minerals, but it can also appear as a by-product of
agricultural and industrial uses. In certain areas within Richland and Sargent counties,
arsenic-laced bait was used extensively to combat grasshopper infestations during a period
from the 1930s - 1940s. This bait was commonly applied to farm fields and unused
materials were often buried in pits or other low lying areas nearby. The use and disposal
of this arsenic may have contributed to the elevated concentrations of arsenic found in
groundwater in some areas of the site.
Since your property lies within the boundaries of the Arsenic Trioxide Superfund Site, we
are sending this Fact Sheet that explains the site in more detail. Please do not hesitate to
contact me at 701-328-5210 or ssrnrkdil1@nd.gov if you have any questions.
Sincerely;
Shane Stockdill
Environmental Scientist
NDDH - Division of Water Quality
Encl. Arsenic Trioxide Superfund Site Fact Sheet
Environmental Health
Section Chief's Office
701.328.5150
Division of
Air Quality
701.328.5188
Division of
Municipal Facilities
701.328.5211
Division of
Waste Management
701.328.5166
Division of
Water Quality
701.328.5210
E-2
-------
i
NORTH DAKOTA
DEPARTMENT of HEALTH
d% United Stales
l Environmental Protection
kAgency
ArsenicTrioxide Superfund Site
Fact Sheet
What you should know if
you drink water from a well
Contacts
Carl Anderson, Supervisor
Groundwater Protection Program
North Dakota Dept. of Health
Water Quality Division
918 East Divide Avenue
Bismarck, N.D. 58501-1947
701-328-5213
www.ndhealth.gov
Southeast Water Users District
206 Main Street
PO Box 10
Mantador, N.D. 58058-0010
701-242-7432
www.seh2o.com
Fran Costanzi, Project Manager
U.S. EPA, Region 8
1595 Wynkoop Street (EPR-SR)
Denver, CO 80202-1129
303-312- 6571
800-227-8917 (toll free Region 8)
www.epa.gov/region8/superfund/
nd/arsenic/
Drinking-Water Well Users May Be at Risk
Homeowners and potential buyers of homes with existing water
wells in Richland and Sargent counties in North Dakota, as well as
anyone considering drilling a new well in the area, should be aware
that shallow aquifer groundwater may contain elevated levels of
arsenic.
The U.S. Environmental Protection Agency (EPA), in cooperation
with the North Dakota Department of Health (NDDoH) and the
Southeast Water Users District (SEWUD), has taken steps to
remedy the health risk posed by arsenic in the area identified as the
Arsenic Trioxide Superfimd Site. The area encompasses about 936
square miles in southeast North Dakota and includes 26 townships.
What is Arsenic, and Why is It a Problem?
Arsenic is a toxic chemical that occurs ~""V
naturally in the environment in the soil, / \ I 1
rocks and minerals. It can also appear
as a by-product of agricultural and
industrial use. In Richland and Sargent counties, arsenic-laced bait
was used extensively to combat grasshopper infestations during the
1930s and early 1940s. The bait was commonly applied to farm
fields, and unused materials were often buried or dumped in pits or
low-lying areas.
In 1979, in the communities of Lidgerwood, Wyndmere and
Milnor, shallow wells in the shallow upper were discovered to
contain arsenic at concentrations above the drinking water
standard of 50 parts per billion (ppb). Arsenic was also found in
wells at private homes and farms in unincorporated areas. In 2006,
the standard for arsenic was changed from 50 ppb to 10 ppb, which
is roughly equivalent to a few drops of ink in an Olympic-size
swimming pool.
Continued on reverse
E-3
-------
Some people who drink water containing arsenic in excess of the
standard over many years could experience adverse health effects,
such as skin damage or circulatory system problems, and may have
an increased risk of getting cancer. Short-term exposure to high
doses of arsenic in drinking water (about a thousand times higher
than the 10 ppb drinking water standard) can also cause adverse
effects in people. Such exposures are not known to occur from
public water supplies in the U.S. that comply with the drinking
water standard for arsenic.
What Should I Do to Limit My Risk?
Owners of existing groundwater wells should determine if their
water has been tested for arsenic levels. NDDoH, in Bismarck,
N.D., maintains records of previously tested wells and will provide
results to owners at no charge. If your well has not been tested,
contact NDDoH for more information or view the brochure at
www.ndhealth.gov/WQ/GW/pubs/WeHTestingBrochure.pdf.
Should arsenic levels exceed the 10 ppb drinking water standard,
owners of wells with water intended for household use (drinking,
cooking, etc.) have several options:
Household point-of-use treatmentwater purification units
installed at owners' homes,
Connection to the public water supplycontact SEWUD for
details, or
Using bottled drinking water.
These are options for well owners to consider. The well owner is
responsible for the costs related to these options.
What Happens Next?
EPA and NDDoH have completed the remediation activities at the
site, which has included the connection of cities to public water
systems, the expansion of SEWUD water treatment facilities and
the installation of pipelines to connect rural users to the public
water supply.
Ongoing measures include the creation of Institutional Controls
(ICs) by EPA and NDDoH. ICs are "non-engineered instruments,"
such as administrative and legal controls, that will help minimize
the potential for human exposure to arsenic contamination in the
future and protect the integrity of existing remedies. This fact sheet
is a part of the IC for the Arsenic Trioxide Superfimd Site.
Townships in the
Arsenic Trioxide
Superfund Site
Richland County
Barney
Belford
Bright wood
Danton
Dexter
Duerr (East)
Duerr (West)
Elma
Grant
Homestead
Liberty Grove
Moran
West End
Wyndmere
Sargent County
Dunbar
Mall
Herman
Kingston
Marboe
Milnor
Ransom
Rutland
Shuman
Tewaukon
We ber
Willey
fwia Southeast
H«J/Vater Users
E-4
-------
NORTH DAKOTA
DEPARTMENTsf HEALTH
ENVIRONMENTAL HEALTH SECTION
Gold Seal Center, 918 E. Divide Ave,
Bismarck, ND 58501-1947
701,328.5200 (fax)
www.ndhealfh.gov
June 28,2013
Mr, Steve Ginsbach
Southeast District Director - NDTOA
16290 91st SE
Hankinson, ND 58041
Re; Arsenic Trioxide Superfund Site Fact Sheet
Mr, Ginsbach,
As we discussed in our recent telephone conversation, I have enclosed copies of the Arsenic
Trioxide Superfund Site Fact Sheet (Fact Sheet) for you to distribute to the township officers for
the townships included within the Arsenic Trioxide Superfund Site (ATS), The Fact Sheet
summarizes the site history, townships included with the ATS, potential health risks associated
with drinking water containing elevated concentrations of arsenic, potential options lor ensuring
a safe drinking water supply, and project contacts.
An important component of the project is the implementation of "Institutional Controls" (ICs)
that educate, inform, and notify residents and well drillers that shallow groundwater within the
project boundary may contain arsenic at concentrations that pose potential risk to those
consuming the water. The enclosed Fact Sheet is one of the ICs developed for the ATS,
One of the challenges of informing the public of the potential risks is to provide appropriate site
information to residents prior to the installation of private water supply wells. During our
conversation, you indicated that in Richland and Sargent counties, township boards are
responsible for issuing building permits for projects within their jurisdiction and that it may be
possible to provide the Fact Sheet to residents during the permit application process. Although.
the installation of drinking water wells may not be included in every project approved by a
township, the information provided on the Fact Sheet may be of interest to the applicant.
I have enclosed Fact Sheets for distribution to the 26 townships included within the boundary of
the ATS. and 1 appreciate your efforts to encourage them to provide this Information to building
permit applicants. I can be contacted at 701-328-5213 if anyone has any questions or if
additional Fact Sheets arc needed. The Fact Sheet is also included on the NDD11 website at
http://www.ndhealth.gov/WQ/GW/pubs/FinalATSFactSheet.pdf.
Sincerely,
Carl Anderson
Ground Water Protection Program Manager
MDDH - Division of Water Quality
End. Arsenic Trioxide Superfund Site Fact Sheets
Environmental Hsailh
Section Chief's Office
701.328.51 SO
Division of
Air Quality
701,323.5188
Division of
Municipal Facilities
701.328.S211
Division of
Waste Management
701.328.5168
Division of
Water Quality
701.328.5210
E-5
-------
Appendix F: Analytical Results from SEWUD 2013
Public Health
Prevent. Promote. Protect.
Fargo Cass Public Health
FARGO CASS PUBLIC HEALTH
Environmental Laboratory
435 14th Avenue South
Fargo, ND 58103
Phone 701-298-6986
Fax 701-241-8110
envirolab@cityoffargo.com
SEWUD-West
PO Box 10
Mantador. ND 58058
Order Number: 13-131
Sample Number: 13-295
Phone: 701-242-7432
Fax: 701-242-7807
Customer Sample Number:
Collection Site: Waterplant
Collection Date: 2/27/2013
Collection Time: 2:00 PM
ReceiveDate: 2/28/2013
ReceiveTime: 11:04 AM
Collected by:
Matrix: Water
Analyte
Nitrate-Nitrite as N
Arsenic
SAR
Silica
Conductivity
pH
Total Dissolved Solids (TDS)
Turbidity
Chloride
Fluoride
Sulfate
Calcium
Approved By:
Results for 13-295
Result
< 0,200
9,45
S1
29.6
439
7.5
261
0.05
3,32
0.509
14.5
69.1
-------
FARGO CASS PUBLIC HEALTH
Environmental Laboratory
435 14th Avenue South
Fargo, ND 58103
Phone 701-298-6986
Public Health Fax 70i-24i-sno
prevent, promote, prelect. envirolab@cityoffargo.com
Fargo Cass Public Health
SEWUD-West
PO Box 10 Order Number: 13-131
Mantador, ND 58058 Sample Number: 13-295
Phone: 701-242-7432
Fax: 701-242-7807
Customer Sample Number:
ReceiveDate: 2/28/2013
ReceiveTime: 11:04 AM
Collection Site: Waterplant
Collection Date: 2/27/2013
Collection Time: 2:00 PM
Collected by:
Matrix. Water
Results for 13-295
Analysis
Analysis
Analyte
Result
Method
Date
Time
Analyst
Iron
<0.010
mg/L
EPA 200.7
3/8/2013
9:00 AM
M. Amundson
Magnesium
13.8
mg/L
EPA 200.7
3/8/2013
9:00 AM
M. Amundson
Manganese
<0.010
mg/L
EPA'200.7
3/8/2013
9:00 AM
M. Amundson
Potassium
2.27
mg/L
EPA 200.7
3/8/2013
9:00AM
M. Amundson
Sodium
2.68
mg/L
EPA 200.7
3/8/2013
9:00 AM
M. Amundson
Total Hardness as CaC03
229
mg/L
EPA 200.7
3/8/2013
9:00 AM
M. Amundson
Bicarbonate as CaC03
216
mg/L
SM 2320B
3/1/2013
11:15AM
Kim Jirava
Carbonate as CaC03
<1.00
mg/L
SM 2320B
3/1/2013
11:15 AM
Kim Jirava
Hydroxide as CaC03
< 1,00
mg/L
SM2320B
3/1/2013
11:15 AM
Kim Jirava
Phenolphthalein as CaC03
<1.00
mg/L
SM 2320B
3/1/2013
11:15 AM
Kim Jirava
Total Alkalinity as CaC03
216
mg/L
SM 2320B
3/1/2013
11:15 AM
Kim Jirava
Approved By:
Date:
r/lS
The mission ofFargo Cass Public Health is to (jfssure a 2o$irfunity for all people through
assessment, education, advocacy, intervention, prevention and collaboration
<"J I 1" ₯ O I'
on-going
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Water Quality Data Table - SEWUD - EAST - ND3901068
In order to ensure that tap water is safe to drink, EPA prescribes regulations which limit the amount of contaminants
in water provided by public water systems. The table below lists all of the drinking water contaminants that we
detected during the calendar year of this report. Although many more contaminants were tested, only those
substances listed below were found in your water. All sources of drinking water contain some naturally occurring
contaminants. At low levels, these substances are generally not harmful in our drinking water. Removing all
contaminants would be extremely expensive, and in most cases, would not provide increased protection of public
health, A few naturally occurring minerals may actually improve the taste of drinking water and have nutritional
value at low levels. Unless otherwise noted, the data presented in this table is from testing done in the calendar year
of the report. The EPA or the State requires us to monitor for certain contaminants less than once per year because
the concentrations of these contaminants do not vary significantly from year to year, or the system is not considered
vulnerable to this type of contamination. As such, some of our data, though representative, may be more than one
year old. In this table you will find terms and abbreviations that might not be familiar to you, To help you better
understand these terms, we have provided the definitions below the table.
Contaminants
MCLG
or
MRDLG
MCL,
TT, or
MRDL
Your
Water
Range
Low | High
Sample
Date
Violation
Typical Source
Disinfectants & Disinfectant By-Products
(There is convincing evidence that addition of a disinfectant is necessary for control of microbial contaminants)
Chlorine (as 12)
(ppm)
4
4
1,2
0,9
1.3
2011
No
Water additive used to control
microbes
Inorganic Contaminants
Barium (ppm)
2
2
0,223
NA
2009
No
Discharge of drilling wastes;
Discharge from metal
refineries; Erosion of natural
deposits
Fluoride (ppm)
4
4
1.13
NA
2009
No
Erosion of natural deposits;
Water additive which
promotes strong teeth;
Discharge from fertilizer and
aluminum factories
Arsenic (ppb)
0
10
9.73
NA
2010
No
Erosion of natural deposits;
Runoff from orchards; Runoff
from glass and electronics
production wastes
F-3
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~n
i
4--
SOUTHEAST WATER USERS DISTRICT
TEST RESULTS
INORGANIC CONTAMINANTS
EGHEST LEVEL RANGE OF HEALTH:
dFLIANCI OTIS DETECTION LANGU
7.1 ppto NA WMtj»n4iid
u^foc iCi -yiiq. it doe- cort
Mi-trae. EPA'idari'&id b*
of a:;> riidi-;
ects agair
from drink in
the health e
a mineral kr
concentrartk
such as skin
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