Last modified: Friday, October 29, 2010
Frequently Asked Questions
1. What does the "treatment system" consist of? How does it work? Are you adding chemicals?
a. The treatment system consists of a series of weir structures and settling ponds to promote aeration, detention and sedimentation, which work in combination to oxidize and settle out any iron present in the water. The system does not utilize any chemicals or depend on any mechanical apparatus that is prone to malfunction or breakdown.
b. In the first step of the treatment, the water runs through three weirs, which are placed in a step-down configuration. A three-foot vertical drop between each of the weirs is designed to provide sufficient aeration of the water so as to oxidize any iron prior to settling. Through oxidation, the iron becomes less soluble, thus allowing settling during the sedimentation process.
c. The second step in the treatment process is sedimentation (settling). Sedimentation provides the detention time needed to settle out any suspended iron that results from oxidation. A detention time of 24 hours is targeted to achieve proper settling. The detention area outlet structure is designed to control both the depth and volume of the water coming into the treatment system. Periodic maintenance will include removal of accumulated sediment, which will ensure that sediment does not interfere with treatment process effectiveness.
2. What is happening at the site now? Is untreated water being discharged to Indiana Creek?
a. At this time, the final elements of the settling basins are under construction and the project is anticipated to be complete by the end of this year. Since the inception of construction activities in July 2006, the project has been continuously managed pursuant to the terms of a stormwater pollution prevention plan and permit, which are designed to minimize any discharges while construction activities are ongoing. Once IU has completed construction of the treatment system, then treated discharges will be covered by the recently-issued NPDES permit.
3. What is in the water that is being treated?
a. The main constituent in the water is iron. Most of the iron in the water is oxidized as it goes through the treatment system and precipitates out by the time it reaches the end of the treatment system.
b. We have measured the amount of iron in the water that could conceivably reach the creek and our test results indicate the dissolved iron content is below Indiana's water quality criterion for iron.
c. Our sampling demonstrates that there is no other constituent of potential concern in the runoff.
4. Is the discharge harming Griffy Creek or Griffy Reservoir?
a. No, all of our sampling demonstrates that the dissolved iron is below Indiana water quality action levels.
b. IU is very concerned about protecting Griffy Creek and the Reservoir, which was a driving factor in the University's decision to voluntarily take on this project nearly a decade ago.
c. Before any design development or construction took place, IU performed several rounds of groundwater, surface water, and ash sampling (four quarters in 2001 and follow-up samples in 2005). This sampling demonstrated that, even before any actual remediation work related to the coal ash pile took place, there was no impact to Indiana Creek, and therefore, to Griffy Creek and the Reservoir.
d. Indiana Creek and the groundwater in the area will be made better by this approved remediation project and completion of the treatment system covered by the discharge permit recently issued by IDEM.
5. Why is it taking so long to take care of this situation?
a. Environmental projects like this take years to complete because of factors such as the need to conduct sampling over multiple calendar quarters to ensure that seasonal fluctuations are recognized. Most complex construction projects -- such as IU's North End Zone project or Simon Hall, are multi-year enterprises, and when the focus is on identifying and providing a sound response to an environmental site with complicated terrain, etc., it does take a long time. IU has been acting diligently on this project for several years in order to have the end result be as protective of the environment as possible. We did have problems that IU did not expect that have caused delays.
6. What kind of problems?
a. When original design options were being discussed, IU asked whether a remedy which would have eliminated the requirement to have an NDPES permit was feasible. Our original consultant advised IU that it was, and IU acted in accordance with this opinion and proceeded with the the consultant's original design with the good-faith expectation that everything would work as designed.
b. In 2009, it became apparent to IU that the consultant's design was simply not going to work and that any treatment system that was going to be effective was going to necessitate an NPDES permit from IDEM. IU then hired new consultants. After more study and development of an upgraded treatment system design, IU submitted a permit application to IDEM that formed the basis of the permit that was recently issued. The permit issued by IDEM is the product of two public comment periods, in which IDEM received and considered comments from Environmental Law and Policy Center, the Sierra Club and the Hoosier Environmental Council and from IU.
c. In addition, we encountered the kind of problems associated with any large-scale construction project, such as weather delays, field conditions that necessitate adjustments to the work, etc.
7. The commenters believe this permit, if granted, would degrade Indiana Creek. Aren't they right?
a. We have reached out to the commenters to discuss their concerns, provided them with a tour of the site, and addressed their concerns in the written comments that IU provided to IDEM.
b. No, our sampling demonstrates that the only constituent of concern is iron and, under the terms of the draft permit, we will continue to monitor for iron and other constituents.
c. Our test results of the water even prior to the planned upgrade to the settling basins indicate that, to date, the dissolved iron content is below Indiana's water quality criteria.
d. We do not expect the iron levels in the runoff to endanger Indiana Creek. We will continue to monitor iron levels at the site to ensure that treatment continues to be successful.
