~ citizens ~-J energy group ·· 2020 North Meridian St. I Indianapolis I IN 46202

CitizensEnergyGroup.com

VIAE-MAIL

Nuria Muniz U.S. EPA- Region 5 NPL Coordinator 77 West Jackson Boulevard Chicago, IL 60604-3507 muniz.nuria@epa.gov

Re: Riverside Ground Water Contamination Site EPA-HQ-OLEM-2016-0153 Request for Extension of Time to Submit Comments Regarding U.S. EPA Proposed Listing Rule

Dear Ms. Muniz:

On April 7, 2016, the United States Environmental Protection Agency ("EPA") published a proposed rule in the Federal Register, 81 Fed. Reg. 20,277 (2016) (the "Proposed Rule") proposing to add the so-called "Riverside Ground Water Contamination" site (the "Riverside Site") to EPA's National Priorities List ("NPL") under the federal Superfund statute. This Proposed Rule relates to two municipal wellfields in Indianapolis, Indiana called the "Riverside Wellfield" and the "White River Wellfield" (collectively, the "Riverside Wellfield"). Citizens Energy Group (the trade name through which the Board of Directors for Utilities for the Department of Public Utilities of the City of Indianapolis does business) provides water utility service to the City of Indianapolis and surrounding areas, and owns, operates and manages the Riverside Wellfield and its associated water treatment and distribution facilities ("Citizens Water" or "Citizens"). For the reasons set out below, Citizens Water respectfully requests a 30-day extension of time in which to provide comments on the Proposed Rule.

EPA proposed to add the Riverside Site to the NPL primarily due to the low-level detections of certain chlorinated solvents (also called "chlorinated volatile organic compounds" or "CVOCs") in some of the groundwater production wells in the Riverside Wellfield. Notwithstanding these detections, no CVOCs have ever been detected in the finished drinking water Citizens supplies to its customers. Water from Citizens' groundwater wells is combined with surface water and then treated at its White River Treatment Plant. Groundwater generally makes up between 15 - 20%, and surface water makes up 80 - 85%, of the water sent to that plant for treatment before being distributed to customers. Citizens' existing management and treatment process have ensured that all water distributed to customers meets all Safe Drinking Water Act ("SDW A'') standards. In fact, the EPA recognized the safety of the drinking water supplied by Citizen Water in its press release announcing the proposed listing. Thus, granting a 30-day extension will not present any increased risks.

May 25,2016 Page 2

Citizens Water's number one concern is to ensure that the water it provides to customers continues to be safe and to comply with all standards. For obvious reasons, Citizens is keenly interested in EPA's Proposed Rule, is reviewing the relevant information closely, and would like to meet with EPA to discuss questions it has concerning response options in advance of finalizing and submitting its formal comments. For the reasons discussed in this letter, Citizens needs additional time to complete its evaluation of all available data and to discuss this matter with stakeholders including U.S. EPA, the Indiana Department of Environmental Management ("IDEM"), and the City of Indianapolis before finalizing those comments.

As noted by EPA in its proposed listing document, the currently proposed Riverside Site is a very large, complicated site that presents complex hydrogeologic issues affecting groundwater and contaminant transport. Citizens continues to work with interested parties to more fully evaluate the hydrogeologic setting, groundwater data, and response options and alternatives and needs more time to complete those evaluations. In addition, circumstances relating to the listing decision continue to evolve. For example, overall concentrations of CVOCs in the Riverside Wellfield continue to decline. In addition, fewer wells today have CVOCs than in the past. We believe changing land use and current environmental regulations mean that significant new sources are unlikely and, thus we would expect existing contaminant levels to continue to decline. Furthermore, six production wells from the Riverside Wellfield are planned to be relocated over the next 18 months as part of a significant redevelopment project, which will substantially alter the dynamics of groundwater flow and contaminant distribution and migration. Citizens needs more time to study and evaluate the implications of these developments before finalizing its comments.

Despite the fact that the public water supply complies with all applicable standards, Citizens is also in the process of refining a multi-prong strategy in response to the Proposed Rule to go above and beyond current safeguards to ensure public water continues to be safe. This plan would include treatment of water extracted from any well where the "raw," untreated water exceeds drinking water standards (currently only one well, WR 3), and enhanced monitoring and reporting. Citizens Water has been discussing and will continue to discuss the details of this plan with IDEM, the City of Indianapolis, and other stakeholders. Additional time is needed to complete these discussions, evaluate the input received, and finalize the plan. Citizens would then like the opportunity to sit down and discuss that plan and possible alternatives to a Superfund listing with EPA before finalizing its comments.

Citizens believes that an alternative plan to the proposed Superfund listing might pave the way to implementing a solution far more quickly and less expensively than would occur if this were to become a Superfund site, and with far less negative implications for area residents and for major economic development projects targeted for this area that will ultimately benefit those residents and the City as a whole. Citizens recognizes that a Superfund designation could have unintended consequences and could lead to years of tremendous expenditure of public and private money. Before a decision to list is made, Citizens believes that alternatives should be fully explored that might achieve the desired ends more quickly and efficiently.

May 25,2016 Page 3

We are more than happy to discuss this request for an extension with EPA. Citizens would greatly appreciate an expeditious response to this request as the current deadline for comments expires June 5.

Thank you very much for considering this request.

;Jely, 4~ Je~Willman Vice President, Water Operations