Free Memorandum - District Court of Arizona - Arizona

ATTACHMENT A

Case 2:03-cv-02226-ROS

Document 75-2

Filed 06/21/2006

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H VI( ( t l. i A ~ VI

Óty Council

11465 W. Civic Center Drive - Ste 280 Avondalei AZ 85323-6806 Phone: (623) 478-3000

TOO: (623) 478-3495
Fax: (623) 478-3802
Website: www.avondale.org

May 23, 2006

MAYOR

Marie Lopez Rogers
VICE MAYOR Dr. Charles M. Wolf

VIA UNITED STATES MAIL
Assistant Attorney General Environment and Natural Resources Division P.O. Box 7611 U.S. Department of Justice Washington, D.C. 20044-7611
Re: Crane Co.. et al v. United States. D..J. Ref. 90-11-2-248/1: Comments of City of Avondale. Arizona. on Proposed Partial

COUNCIL MEMBERS
Jim Buster Jason Earp Betty S. Lynch

Frank Scott
Kenneth Weise

Consent Decree
Dear Assistant Attorney General:

CITY MANAGER Charles P. McClendon

I am writing on behalf of the City of Avondale, Arizona to comment upon the proposed Partial Consent Decree between the United States and Unidynamics/Phoenix, Inc. and Crane Co. ("Settling Defendants.") The Partial Consent Decree requires Settling Defendants to undertake response actions under the Comprehensive Environmental Response, Compensation, and Liability Act ("CERCLA"), because of releases of trichloroethylene ("TCE"), perchlorate, and other contaminants within the Phoenix-Goodyear Airport (Nort) Superfund site. Among other things, Settling Defendants are required to further investigate and remediate impacted groundwater in two portions of the aquifer, referred to as Subunit A and Subunit C. Unidynamics, a corporate affiliate of Crane, previously operated a munitions facility on property located at 102 South Litchfield Road, in the nearby City of Goodyear.
Avondale lies directly east of the current known configuration of the PGA North groundwater contaminant plume. Avondale is a rapidly growing city, with a current population of approximately 66,000 and an anticipated population of 125,000 by 2020. Avondale relies solely upon the regional aquifer for its drinking water supply, curently maintaining 13 domestic
supply wells, annually pumping 3.7 bilion gallons from the aquifer. A

the City's drinking water wells, most notably COA-18, are within a mile of the Unidynamics plume. It is likely that some of Avondale's drinking water supply wells are or wil be "at risk" of
number of

contamination, as specified in the consent decree. Further, as the City

grows, it is likely that Avondale wil be required to dril additional
production wells in the aquifer. Accordingly, it is essential that Settling I

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Defendants promptly complete the characterization and containment of their plume.
Although Avondale supports entry of the Partial Consent Decree by the District Court, the City wishes to stress the importance of timely completion of the work to be performed by Settling Defendants to the drinking water supplies of West Valley cities such as Avondale. The slow pace of Settling Defendants' past efforts to characterize and contain their plume previously caused contamination of several drinking water supply
wells maintained by Avondale's neighbor, Goodyear. Avondale canot

afford to suffer the same fate. Accordingly, the City urges the United States Environmental Protection Agency ("EP A") to vigorously enforce the terms of the decree, with a paricular focus on evaluating whether migration of the plume threatens additional municipal water supply wells.

Of paricular concern to the City is thorough and timely implementation of the drinking water supply protection provisions of Task 4.0 of the Partial Consent Decree's Scope of Work. Task 4.0 requires Settling Defendants to identify "at-risk" domestic supply wells; increase groundwater monitoring in the vicinity of these at-risk wells; install additional sentinel and/or extraction wells; and "implement measures to ensure provision of an
uninterrpted water supply."

According to the Statement of Work, "at-risk" domestic water supply wells wil be evaluated utilizing a regional model currently being developed by

the Settling Defendants' consultant and via EPA's Wellhead Protection Area Model ("WH A"), based on a five-year capture analysis. Because of the limitations of the model and the rapid growth in the area, Avondale requests that Settling Defendants' at-risk analysis specifically include an
evaluation of potential impacts on all of Avondale's water supply wells.
Avondale also requests that the City be informed about and consulted

regarding the provisions of Task 4. First, Task 4.1 requires that Settling
Defendants notify EPA upon concluding that certain wells are at-risk. There is no express requirement that Avondale or other impacted cities be notified as well, and they should be. Avondale formally requests that it be copied on the relevant notifications made to EP A.

Likewise, in the event that response actions must be taken because of impacts to an Avondale well, the City should be included in the remedy
selection process. Task 4.2 calls for Settling Defendants, in the event that

additional at-risk wells are identified, to submit a Draft Wellhead
Treatment/Alternative Water Supply Workplan to EPA. That work plan is to include a proposal to treat the contaminated well at the wellhead, dril an alternate well, or provide an alternate replacement supply. No role for the impacted municipality is expressly set forth in the process. Avondale

strongly believes that the City should be engaged and consulted in the
development of any response actions.

For similar reasons, Avondale requests that it be notified, concurrent with EP A, in the event that Settling Defendants become aware of any release or threatened release of a Waste Material that may pose an immediate threat to
Case 2:03-cv-02226-ROS Document 75-2 Filed 06/21/2006 Page 3 of 13

..

public health or the environment in Avondale, as set forth on Section VX of the Consent Decree. Also, the City formally requests that it be included on

the distribution list for all correspondence associated with the reporting
requirements outlined in Section X (Reporting Requirements) of the

Consent Decree.
Avondale does not request that the consent decree must be modified to expressly provide for these things, but does believe that Settling Defendants

and EP A should commit to them in their response to comments and/or in any motion for entry.
The City appreciates the opportunity to comment upon the Partial Consent

Decree and looks forward to completion of the work by Settling
Defendants.
Sincerely, THE CITY OF AVONDALE, ARIZONA

~~&?~

Marie Lopez-Rogers, Mayor
cc: Sue Ellen Woolridge, DOJ

Paul Charlton, U.S. Attorney, Arizona Bethany Dreyfus, EP A Region 9 Mary Aycock, EPA Region 9 Wayne Nastri, Regional Administrator, Region IX Roger K. Ferland, counsel for Crane Co. David Fitzhugh, Assistant City of Avondale Manager Andrew McGuire, Avondale City Attorney Christopher D. Thomas, Squire, Sanders & Dempsey, LLP

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.
May 22, 2006

!1~/t7/ A

/ ..

Goodyear

VIA UNITED STATES MAL
Assistat Attorney General

Environment and Natual Resources Division

P.O. Box 7611 U.S. Deparent of Justice
Washigton, D.C. 20044-7611
Re: Crane Co.. et al v. United States. D.J. Ref.90-11-2-248/1: Comments ofCitv of

Goodvear.

Ariona. on Proposed Partal Consent Decree
Dear Assistat Attorney General:
I am wrting to provide the comments of

Goodyear, Arzona, on the proposed Parial Consent Decree between the United States and UnidynamcslPhoenix, Inc. and Crane Co. (collectively, "Settling Defendants.") The Parial Consent Decree calls for Settling Defendats to ffnance and perform response actions under the federal Superfd act, the Comprehensive Environmental Response, Compensation, and trchloroethylene ("TCE"), perchlorate, and other Liabilty Act ("CERCLA"), in response to releases of hazdous substaces and contaants with the Phoenix-Goodyear Aiort (Nort) National Priorities
the City of

List site.

Crane, previously operated a muntions facilty on property located at 102 South Litchfeld Road, with the PGA Nort site and the Goodyear city limts. Among other the thgs, releases from the Unidynamcs Propert have impacted groundwater in two portons of aquifer, referred to as Subunt A and Subunt C.
Unidynamics, a corporate afliate of

Goodyear is a rapidly growig city of approximately 40,000, having experienced growt approaching 20 percent per year for the past six years. Goodyear's drnkng water supply relies alost exclusively on production of water from Subunt C, a relatively deeper porton of the local groundwater aquifer impacted
by the Unidynamcs plume. Indeed, two of the City's domestic water supply wells, City of Goodyear

Well No.2 ("COG-2") and COG-lO, previously had to be shut down because of groundwater containation migrating from the Unidynamics facility. Goodyear has been an active paricipant in a techncal staeholder group regarding the PGA Nort Site. ~. .. . ,., ..-;./ '
Th proposed Paral Consnt Deree obviousy ha be a loog time in the mai~:~!gog ~-o~ 'i ¿r¡ J

hard work and difffcult negotiations. The City welcomes the completion and lodging of the decree, and
urges the United States to seek entr of

the decree by the Distrct Cour. The City ~Ä~~~.iST'CE
Office of the Mayor

Proud past. Vibrant future! "
190 North Litchfield Road P.O. Box 5100 Goodyeari Arizona 85338 MAY 2 6 2006
623-932-3910 Fax 623-932-1177 1-800-872-1749 TDD 623-932-6500

Case 2:03-cv-02226-ROS

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ENRD

ENFORCEMENT RECORDS

. Assistat Attorney General, Environment and Natual Resources Division

May 22, 2006
Page 2

fair, reasonable, and consistent with CERCLA. Furhermore, timely completion of performed under the decree is essential to preservation and restoration of

the work to be the City's crucial groundwater

supply.

In that regard, while Goodyear supports entry of the decree, the City must reiterate that timely and complete performance by Settling Defendants of the work to be performed under the agreement is critical
to the drg water needs of some 40,000 Goodyear residents. Unfortately, the pace of response

the City's drnkg water wells and groundwater supply. The Parial Consent Decree appears to contan the tools
actions in the past was not sufcient to prevent migrtion ofthe plume and contaation of

necessar to remedy that sitution, and the City urges the United States Environmenta Protection Agency

("EP A") to vigorously employ them.

provisions of

Of paricular concern to the City wil be timely implementation of the drnkg water supply protection Work. Task 4.0 requies Settling Defendants to identify "at-risk" domestic supply wells; increase groundwater monitorig in the vicinity of these at-risk wells; intal additional sentinel and/or extaction wells; and "implement measures to ensure
Task 4.0 ofthe Parial Consent Decree's Scope of

provision of an unterrpted water supply."

The City notes that, because the plume is neither contaed nor fuly charcterized, the analysis of at-risk

wells must be constatly updated. Indeed, due to the observed norteasterly shift of the containant
plume, wells which were not previously at risk may very well be at risk in the near futue. For instance,

COG-3 was not considered at risk until a few months ago, when TCE concentrations in a nearby monitor
well were observed to be increasing on a quaerly basis. Consequently, the Settling Defendants have

increased the monitorig frequency at the well and intiated the instalation of two sentinel wells between the plume and City No.3. Ths is consistent with the criteria set fort in the Consent Decree.

According to the Statement of Work, "at-risk" domestic water supply wells will be evaluated utilizig a
regional model curently being developed by the Settling Defendants' consultat and via EPA's Wellhead

Protection Area Model ("WHPA") based on a ffve-year captue analysis. EPA's WHPA model is a relatively simple analytical model, with limted capabilities in comparson to others curently being used.

To ilustrte the critical importt of Task 4.0 to protection of the City's drg water supply,
Goodyear's consultat, Burgess & Niple, evaluated selected City of Goodyear Wells (COG-I, COG-3,
COG-6, COG-II, COG-18a, COG-18b, and COG-19) utilizing the WH A ModeL.
As more fuly described in the attched, ths prelimar analysis identiffed one well - COG-3 - as

already at risk, and suggests that two additional wells - COG-18A and COG 18b - as likely to be at risk withn two years if the plume continues to migrate norteasterly. Additionally, B&N's model analysis did
not incorporate inuences from other wells located nort and norteast of City wells COG-18a and COG-

18b. Thee additional production wells are located with 0.5 mile of the COG-18 well ffeld and two additional production wells are located withi 1.0 mile of COG-IS well ffeld. The cumulative influence from all of the wells located in the site vicinity would likely increase the captue zone depicted at City wells COG-18a and COG-18b, and hence accelerate the travel time of the Unidynamics plume to those wells' captue zones.

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. Assistàt Attorney General, Envionment and Natual Resources Division May 22, 2006
Page 3

In short,

the Goodyear water supply is in a very vuerable state and will continue to be so uness plume

management strategies (instaation of extaction wells) and contigency plan are implemented, as necessar, on an expedited basis. EP A must ensure that, as the Paral Consent Decree requies, Settlig
Defendants are prepared to "implement measures to ensure provision of an unterrpted water supply"

on a timely basis. Because of the litations öf the model, the rapid growt in the area, and the possibility

that irgation wells may be converted to potable water use, the City also suggests that Setting
Defendants' at-risk analysis also include an evaluation of

wells curently used for irgation only.

The City has two other comments about Task 4. First Task 4.2 cals for Settg Defendants, in the event

that additional at-risk wells are identified, to submit a Draf Wellead Treatment/Alternative Water
Supply W orkplan to EP A, which work plan shall include a proposal to 1reat the contaated well at the
wellead, dr an alternte well, or provide an alternte replacement supply. It does not appear that, in the

event that the at-risk well is a Goodyear well, any formal role in remedy selection is provided to the City. Neverteless, Goodyear believes that the City should be engaged and consulted in the development of any
response actions pertg to its wells, recogng, among other thgs, that wellhead treatment mayor

may not be accepted as readily by the public as other optionS.

Simlarly, Task 4.1 requies Settling Defendats to notify EPA afer concludig that certai wells are atrisk. There is no express requiement that Goodyear be notiffed in the event that the identified well is a City well, and Goodyear formally requests hereby that it be copied on the relevant notications made to

EP A. The inormational needs of a muncipal water provider are certy no less than those of EP A.

For simlar reasons, the City requests that it be notified, concurent with EPA, in the event that Settlig Defendants become aware of any release or theatened release of a Waste Material that may pose an
imediate theat to public health or the envionment, as set fort on Section VX of the Consent Decree.

As the local fist responder, the City requies concurent notice of any such events. Also, the City

formally requests that it contiue to be included on the distrbution list for all correspondence associated
with the reportg requiements outlined in Section X (Reportg Requiements) of the Consent Decree.

The City appreciates the opportty to comment upon the Paral Consent Decree and looks forward to

completion of the work by Settling Defendants.

/ ;;~ ¡4:
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Assistant Attorney General, Envionment and Natual Resources Division

May 22, 2006
Page 4

City of Godyear Point of Contact Dayid Iwanski, Water Resources Manager Work #: 623-88-7062
Cell #: 623~932-9304

emaIl: Dlwanski§Goodyeara.gov

cc:

Sue Ellen Woolrdge, DOJ Paul Charlton, U.S. Attorney, Arona
Bethany Dreyf, EP A Region 9

Mar Aycock, EP A Region 9

Wayne Nastr, Regional Admstrator, Region IX Anthony D. Pantaeoni, Crane Co.
Roger K. Ferland, counsel for Crane Co. David Iwanski, City of Goodyear Dino Gotsis, Burgess & Niple
Chrstopher D. Thomas, Squie, Sanders & Dempsey, LLP

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Sue Ellen Wooldridge Assistant Attorney General Environment and Natual Resources Division U.S. Deparent of Justice
950 Pennsylvana Avenue, NW

Washington, D.C. 20530 (205) 514-2701
Wayne Nastr

Roger K. Ferland Quarles & Brady Streich Lang, LLP One Renaissance Square Two Nort Central Avenue Phoenix, AZ 85004-2391 (602) 229-5607 rferlandCIquarles. com
Dino Gotsis Burgess & Niple 5025 E. Washigton Street, Suite 212 Phoenix, AZ 85034 (602) 244-8100 x 27 dgotsisCIbumip.com

Regional Administrator, Region IX U.S. Environmental Protection Agency 75 Hawthorne Street - ORA-1
San Francisco, CA 94105-3901

(415) 947-8702
nastr. wayneCIepa. gov

Bethany A. Dreyfs
Assistant Regional Counsel U.S. Environmental Protection Agency

75 Hawtorne Street
San Francisco, CA 94105-3901

(415) 972-3886
dreyfs .bethanyCIepa. gov

MarT. Aycock u.s. Environmental Protection Agency

75 Hawthorne Street - SFD-8-2
San Francisco, CA 94105-3901

(415) 972-3289 aycock.maryCIepa. gov

Paul K. Charlton U.S. Attorney
40 Nort Central Avenue, Suite 1200

Phoenix, AZ 85004-4408 (602)514-7670

Anthony D. Pantaleoni Vice President of Environment, Health & Safety
Crane Co.

100 First Stamford Place Stamford, CT 06902 (203) 363-7214 tpantaleoniCIcraneco. com

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WHP A Analysis for Well Captue Zone Assessment for Selected City of Goodyear Wells
1 Introduction
The purose of this study is to use the softare package WHP A to delineate the 5-year

captue zones for selected active City of Goodyear (COG) water supply wells in the vicinity

of the PGA Nort site. The Captures zones are used to identify wells that are at risk or
potentially at risk. Risk is evaluated on the basis whether the 5-year capture zone overlaps the

trchloroethylene (TCE) plume which is delineated by the 5 parts per billion (Ppb) Sitespecific cleanup standard.
2 Model Selection and Assumptions

The analytical code selected for the study is WH A, developed by Brandford and Huyakom (1991) for EP A. WH A is an analytical model that simulates two-dimensional steady-state groundwater flow, and has four major computational modules: RESSQC, MWCAP, GPTRAC and MONTEC. Module RESSQC was used to model the groundwater flow system

in subunt C in this modeling effort. RESSQC can "delieate time-related capture zones
around pumping wells, or contaminant fronts around injection wells, for multiple pumping and inection wells in homogeneous aquifers of infinite areal extent with steady and unform ambient ground water flow". Well interference effects are also accounted for in this module. The major assumptions used in the model are as follows:
1. The analytical model using WH A is an appropriate model for ths study.
2. The groundwater flow in subunit C is at steady-state, uniform and horiontal, and occurs in an infinite aquifer.

3. The water supply wells fully penetrate the subunit C.

4. Subunt C is treated as a single unit and has a unform thickness of 120 feet. The hydraulic conductivity of sub-unit C is assumed to be homogeneous and
isotropic. There is no leakage from subunit A to subunit C.

5. The discharge rates of COG wells are used in the model based on their
permitted recovery capacity.

3 Model parameters

Primar model parameters include regional flow gradient and the diection of flow,
transmissivity of the aquifer, thickness of sub-unit C, and effective porosity. Other inputs

include well locations and corresponding discharge rates. By assuming no leakage from
subunt A to subunit C, the recharge from subunt A is determined to be negligible.

Burgess & Niple
1

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Previous study of the PGA North site indicates that the horizontal hydraulic gradient of the

sub-unt C is relatively flat with an estimated gradient of less than 0.001. The general
direction of groundwater flow with the study area is estimated to be nort-nortwest

(Geomatrx Consultants, Inc., July 2002). Therefore, flow direction in the model is intially
approximated at 1150 counterclockwse from the east, and hydraulic gradient is set to be 0.001.

Seven City wells pumping from Subunt C in the study area were identified. The wells used for this analysis are COG-I, COG-3, COG-6, COG-II, COG-18A and COG-18B. City wells COG-2 and COG-10 were excluded from ths analysis because both wells have already been
impacted by TCE and are not being used for production at present. The anual pennitted

recovery capacity was used to calculate pumping rates for each well except for COG-19. In
the case of COG-19, the average daily pumping rate for year 2005 was used. The applied pumping rates are listed in Table 1.

Table 1. COG Well Pump Rates Applied to WHP A Analysis

.WefNâme
COG-Ol COG-03 COG-06
COG-I 1

Pê.Iitted recovery capacity (2Dm) .

COG-18A COG-18B COG-19 (Centerra)

347 645 539 1730 930 255 657

Several aquifer tests have been perfonned at the PGA Nort site. Based on a sumar from
Geomatrix's conceptual hydrogeologic characterization model report (July, 2002), CH2M Hill
reported transmissivity values ranging from 6,700 to 13,400 ft/day in the upper half of

subunit C and a value of 4,700 ft2/day from aquifer tests perfonned at both PGA North and

South sites. Brown & Caldwell conducted constant-rate pumping and recovery tests at wells

COG-18A and COG-18B imediately following their installation. Estimated average
transmissivity values were 9,600 ft2/day and 1,300 fe/day at COG-18A and COG-18B,

respectively. Geomatr conducted a series of aquifer tests and a borehole dilution test to obtain sub-unt C hydraulic parameter values on the PGA Nort site in 2001 and 2002. Their testing activities yielded a transmissivity value of 8,300 ff/day or a horiontal hydraulic conductivity of 108 :t/day at MW-20, a transmissivity value of 5,500 ft2/day at MW-28, 4,400 ft2/day at MW-29, and 5,500 ft2/dayat COG-06, COG-18A, and COG-18B. In July
2003, Allen, Stephenson & Associates (ASA) performed a stel-drawdown test at COG-Ol.

This test resulted in an estimated transmissivity value of7,166 ft Iday.

Burgess & Niple
2

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The average transmissivity value for subunt C is calculated using 9,600 fe/day (Brown & Caldwell), 8,300 ft?/day (Geomatrx), and 7,166 fe/day (ASA) and is approximated to be 8,400 ft2/day. The thckness and effective porosity of subunit C are estimated to be 120 ft and
0.25, respectively, based on the results of

previous studies.

4 Model Results and Conclusions

Figure 1 ilustrates the 5-year capture zone for active COG wells. It clearly shows that the capture zone of COG-3 overlaps with the TCE plume, which indicates that ÇOG-3 is at risk.

The west edge of the combined captue zones associated with COG-18A, COG-18B and

the TCE plume. These wells could be potentially at risk if we consider that this study only accounts for selected City of Goodyear wells. In reality, multiple wells with high pumping rates and similar completion depths exist in the vicinity of the well field of COG-18A, COG-18B, and COG-6. These unaccounted wells include City of Avondale's water supply wells, a Litchfield Park Service
COG-6 is only about one-quarer mile from the east boundar of

Company well and some high-capacity irrgation wells. Considerig the qualty of the
groundwater in ths general area and the tremendous development in the Cities of Goodyear
and Avondale, additional water supply wells could be drlled in ths area. These factors, if

incorporated into the analysis, would undoubtedly change the size and shape of the capture
zones. The captue zones could combine and become a single large capture zone due to well

interference and proximity.

Although the WH A analysis identified COG-3 as the only well curently at risk, additional futue evaluations should be completed on the other selected City wells. The 5-year captue analysis could change due to development of additional information such as modified pumping conditions in the area, the TCE plume is better defied, and the introduction of other chemical of concern having Site-specified cleanup standards.

References
Allen, Stephenson & Associates, Hydrogeologic Evaluation of COG-01, Goodyear, Arzona, July 2003.

Blandford, T. N. and P. S. Huyakorn, WHA 2.0: A Modular Semi-Anlytical Model for the Delineation of Wellhead Protection Areas. U. S. Environmental Protection Agency, Offce of Groundwater Protection, 1991.
Geomatrx Consultants, Inc, Groundwater Monitorig Report - First Quarer, 2002, Appendix
A, 2002.

Geomatrx Consultats, Inc, Conceptual Hydrogeological Characterization Model Report,

Phoenix-Goodyear Airport North superfd site, Goodyear, Arzona, July 2002.

Burgess & Niple
3

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PHOENIXGOODYEAR MUNICIPAL AIRPORT

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LEGEND

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COG-1

APPROXIMATE EXTENT OF SUB-UNIT A TCE PLUME.

I....:.:.: .1 EXTENT IS DENOTED BY 5 PARTS PER BILLION
APPROXIMATE EXTENT OF SUB-UNIT C TCE PLUME. EXTENT IS DENOTED BY 5 PARTS PER BILLION

CITY OF GOODYEAR PRODUCTION WELL

APPROXIMATE LIMIT OF 5-YEAR CAPTURE (RESULTS BASED ON EPA WHPA MODEL)

APPROXIMATE SCALE 1" = 5280'

tb

..

SITE VICINITY MAP SHOWING SELECTED CITY OF GOODYEAR WELL LOCATIONS, EXTENT OF PGA-N TCE

FIGURE

PLUMES & 5-YEAR CAPTURE ZONES

1

BURGESS a NIPLE PHOENIX, AZ

GOODYEAR, ARIZONA

B&N PROJECT NO.: 34075

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