cotter/lincoln park community advisory...

CAG Pipeline Comments 2016-02-01: of 5

From: Cotter/Lincoln Park Community Advisory Group To: Jennifer Opila, State Unit Leader Date: February 1, 2016 Re: Stage I - Public Comment on Cotter Corporation’s Amended Proposal to

Replace SCS Pumpback Line The CAG members thank you for the opportunity to submit Comments. GENERAL COMMENTS: In preparation of these comments, we thank Marcus Griswold of SKEO for research, answering CAG questions, and offering advice. We also thank two of our CAG members for their life experience which aided the CAG’s understanding: Bill Matthews, a previously certified pipe welder who worked in the field on similar projects for many years; and, Michael Stiehl, who had exposure to similar issues as a previous Fremont County Commissioner and citizen active in the State. The CAG members appreciate very much Cotter’s decision to replace the pipeline which experienced breaks and spills eight times between November 2010 and December 2015. Even though Fremont County will not be allowed to permit the installation of the pipeline as it is entirely on site at the Cotter property, we trust that CDPHE and the EPA will ensure that all engineering protocols are followed. If a more detailed plan for the project is submitted to the agencies, a certified professional with expertise in this type of installation should submit a report with any findings or recommendations that will be made available to the public. The pumpback system and pipeline plays a critical role in protecting off-site community groundwater from on-site contaminated groundwater. The regulatory agencies handling of this project will be crucial in gaining community trust going forward into the RI/FS and Remedial phases of the superfund cleanup. Request: The CAG requests that Bill Matthews and one other member be permitted to observe at some point during each phase of the pipeline replacement. Request: Require Cotter to create a map showing the location of the entire pipeline, including identification of the 2008 installation, and include identifying site features. Based on the best of our knowledge, the CAG members offer the following comments and requests, and we look forward to your response.


SPECIFIC COMMENTS: 1. Contractors: The proposal does not name contractors working for Cotter on this

project. We were told at the Jan 14, 2016 CAG that Kumar & Associates would perform compaction tests, but it is unclear from the proposal as to who will be performing the other phases of work.

Request: Include in the proposal all names and qualifications of contractors, and their roles in each phase of the project.

2. Engineered Plan and Design: Superfund policy and Section XI, item 57 of the Administrative Settlement Agreement and Order on Consent between Cotter, EPA and CDPHE do not require local, State, or federal permits (except what’s required under the license) for any action conducted entirely on-site. Both do require Cotter to comply with all applicable State and federal laws and regulations, especially those more stringent than federal laws. However, it is of concern that relevant laws known as ARARs (Applicable and Relevant or Appropriate Requirements) have yet to be developed for this site. We also note that the 2008 Stoller as-built report, the specs to be used again for this project, did not appear to be a stamped engineer’s plan or design. Given the above, based on feedback from the Colorado Board of Licensure for Architects, Professional Engineers and Professional Land Surveyors, Marcus Griswold of SKEO was told that the replacement of the pipeline would likely require an engineering stamp, especially addressing the following two items:

a. The design and installation of the pipeline appears to constitute the State’s definition of “the practice of engineering” specified in Section 12-25-102(10)(a) of Colorado Revised Statutes. b. Due to the concentration of uranium and molybdenum reported in the July 2015 analysis of water from the pipeline, a Professional Engineer would need to certify that the system is not a danger to the public, as required in Board Rule 3.1.1 under the State Board of Licensure for Architects, Professional Engineers and Professional Land Surveyors.

In 2008, the Stoller Corporation did prepare a “Site-Specific Health and Safety Plan” for the overall project. Stoller’s report states, “The work was performed in accordance with the health and safety plan and Occupational Safety and Health Administration and Mine Safety and Health Administration trenching rules.”

The CAG is also of the opinion that the community would benefit from access to the pipeline installation plan, in addition to the submitted proposal, which would provide information on erosion and sediment control, air/soil monitoring, health and safety, and the guidance Cotter will follow.

Request: The CAG members agree with Bill Matthews that a stamped

engineered plan and design should be developed to satisfy the general goal to


protect human health and the environment at this site. This is especially necessary due to the nature of its purpose, to prevent migration of contaminated groundwater off-site, and due to the length of time it may have to be in service.

3. Trench Depth and Frostline: Potential for frost heave and seismic

displacement should be considered when designing the pipe system. Cotter’s proposal does not include slopes or site topography, though the Stoller 2008 plan does. Having access to topographic maps could assist in understanding the rationale for the pipeline design.

We were told at the CAG by Steve Cohen of Cotter that the total depth of the trench will be 42”. Pueblo County has adopted a depth of 48 inches to be “one foot below the frost line” which is 6” deeper than Cotter’s plan (https://prbd.com/faq.php) [see #7 under Plumbing FAQs]. Bill Matthews was told by the City of Canon City that their water lines have a minimum of 42 inches of soil cover over the pipe. It would be of benefit to the community if an engineered plan and design confirmed the proposed depth of the trench. The CAG members believe that during the design and installation process the frost line and soil type should be studied thoroughly to assess the potential for expansion and contraction around the pipeline. While HDPE is more tolerant of expansion and contraction than PVC pipe, a combination of bad welds and contraction/expansion could cause joint leaks. In addition, both Bill Matthews and Michael Stiehl voiced the opinion that the terrain, geology, and possible expansive soils in the area where the new pipe will be installed does not appear to be identical to the area of the 2008 installation. Request: For all of the above reasons, the CAG again believes there is a need for a stamped engineered plan and design for this project based on studies of site specific soil types, geology and frostline along the new installation.

4. Bedding Beneath the Pipe: We were told at the January 14th CAG meeting that Cotter will not be placing any bedding material beneath the pipe, but will use the native soil encountered unless any rocks or a pit is discovered. Michael Stiehl voiced the opinion that there should be bedding material according to the International Pipeline Institute. Mr. Cohen disagreed and believes the installation instructions for the pipe is sufficient. Michael Stiehl responded that those instructions are not specific to this particular site. Also, Bill Matthews reported that he was told by the City of Canon City that they used a minimum of 6” of bedding beneath their pipe installations.

Request: Require Cotter’s proposal to include an engineer’s opinion on the above, based on a study of the soils and geology in this specific area where the new pipe will be installed.

5. Pipeline Installer Qualifications: The current pipeline proposal would benefit from documentation citing the qualifications of the pipeline installer and their familiarity with butt fusion techniques. This information is from the Plastic Pipe


Institute’s TN-42 Recommended Minimum Training Guidelines for PE Pipe Butt-Fusion Joining Operators for Municipal and Industrial Projects (2009).

Request: Require the above information in Cotter’s proposal for pipeline replacement.

6. Welding and Cold Weather: Bill Matthews voiced a concern about welding

being done during cold weather. Note that many of the prior leaks occurred as a result of couplers breaking or becoming loose. For example, the September 8, 2014 leak occurred when the welding at the joint connecting two pipes loosened (September 8, 2014 email from Cotter, John Hamrick, to Jennifer Opila at CDPHE). Cotter’s proposal does not mention any considerations regarding recommended temperatures or weather during welding of the pipe.

Request: Require Cotter to make this determination backed by a qualified

engineer and pipe welder. We recommend that the project not be conducted during cold weather.

7. Additional Items to consider: The following items were found in the

Polyethylene Piping Systems Field Manual for Municipal Water Applications, M&I Division 2009 Edition:

a. Vibratory placement can cause severe disturbance to the bedding and liquefaction of the surrounding soils. b. If HDPE is stored in direct sunlight and installed in cold or cool soil, considerations should be given to allowing the pipeline to reach temperatures near the soil temperature prior to installation and welding. c. Proper care of the joints is critical to prevent leaks. Note that many of the prior leaks at the Site occurred as a result of couplers breaking or becoming loose, as mentioned in paragraph #6 above. Joints should be entirely free of dirt, contaminants, water or any other material prior to fusion. If temperatures are at or around 32 degrees Fahrenheit, pipe ends should be pre-heated prior to fusion. If conditions are windy, this can cause unacceptable temperature variations and joint contamination during fusion. To eliminate this possibility, a shelter could be used to protect the fusion heater plate and the pipe plugged to prevent blow through. The optimal temperature of the fusion plate is 425 degrees Fahrenheit. d. To ensure proper Quality Assurance at the site, a datalogger can be used. A datalogging device can be attached to the hydraulic fusion machines to record the critical areas of the butt fusion process. This data can be reviewed before allowing the joint to be buried to make sure the proper fusion procedure was followed by the operator. This information can be downloaded to a PC as a permanent record of the joints on a job.


Request: Again, an engineer’s stamped design and plan would provide much more detail than Cotter’s current proposal, which might include items suggested above.

8. Monitoring and Maintenance:

a. As recommended in the proposal, having a leak detection system is a positive step to assessing pipe failure. The community would benefit from a more detailed description of how the leak system will be monitored and documented. The Plastic Pipeline Institute also recommends the audio technique for monitoring leaks, which listens for the sound emitted as the fluid flows irregularly through an unplanned opening in the pipe, (Plastic Pipe Institute, 2009. PPI-TN27: Frequently asked questions. HDPE pipeline for water distribution and transmission applications). b. Pump system: The pipeline and pumps act as a single system and could be addressed as such. More specifics could be provided on the operations and maintenance plan for the pipeline and pump as a system. For instance, the recent silting in of the pump also included rusting of the pump. We recommend regular cleaning and maintenance of the pump, preferably by a mechanical engineer. Request: Require Cotter to include a more detailed description of how the leak system will be designed, monitored and documented. Also require Cotter to include more specifics on the day-to-day operations and the maintenance plan for the pipeline and pump system after it is installed.

To: CDPHE, Jennifer Opila EPA Mark Aguilar From: Mike Stiehl, Cotter/Lincoln Park Community Advisory Group member Date: February 1, 2016 Subject: Cotter amended proposal to replace SCS Pumpback pipeline – Phase 1 comment Considerations:

1. Repeated failure of existing pipeline. 2. Geology, terrain and soil types within pipeline route. 3. Design of new pipeline. 4. Installation oversight, accountability.

Discussion:

1. There are several theories regarding cause of the repeated failures. The use of PVC is often cited, but it’s unlikely that PVC would fail repeatedly unless there are other contributing factors. It’s likely that there are multiple factors.

2. Soil types and terrain A. When the new ponds were constructed @ 1980, they used “Clay-like materials”

beneath and above the hypalon liner. This material was acceptable to the CDPHE as a Bentonite substitute because of its expansive characteristics. This soil was taken from onsite in essentially the same area as the pipeline route.

B. As the pipeline route descends, it crosses and drops off a “shelf” that is apparent from standing onsite. There is a break in vegetation and, although well-eroded, a visible drop-off in elevation, near the midpoint of the route. At least one break has occurred at this transition.

C. Current excavation, as observed during a CAG tour of repairs, revealed presence of cobbles of large size, dug up during excavation, which could damage new pipe if not accommodated in new design.

D. The site is sufficiently different from past projects. E. If the soil was sufficiently expansive to qualify as liner material, then it is

sufficiently expansive to impact pipeline placement and engineering. 3. Design of new pipeline:

Cotter has continually stated that the new installation will abide by the Plastics Pipe Institute “PPI.” However, the design and drawings presented DO NOT APPEAR TO ADHERE TO PPI guidelines. I referred to PPI SECOND EDITION HANDBOOK OF PE PIPE, (“Handbook”) Chapter 7, “Underground Installation of PE Piping” for information. http://plasticpipe.org/pdf/chapter07.pdf

A. Cotter’s plans (developed for a different location) are not location-specific about bedding. The Handbook requires appropriate bedding depending on soil types encountered during excavation (p. 270 – “…the trench bottom padded with 4 to 6 inches of tamped bedding material…” Bedding may be omitted if engineering determines soil types at depth are appropriate for the entire length of the trench.

http://plasticpipe.org/pdf/chapter07.pdf

B. Haunching is not addressed. From the Handbook: “The backfill under the lower half of the pipe (haunches) distributes the superimposed loadings. The nature of the haunching material and the quality of its placement are one of the most important factors in limiting the deformation of PE pipe.” Hand tamping is recommended for this important step.

C. Cotter’s plan for Primary Initial Backfill – the fill to 75% of pipe diameter – placement method does appear to be in accordance with the Handbook. Cotter calls this step “Pipe Embedment.”

D. Secondary Initial backfill Same as C. above – also called “Pipe Embedment” by Cotter.

E. Final Backfill appears to adhere to Handbook guidelines. F. THIS MOST IMPORTANT POINT:

There are many questions about the pipeline’s design and execution. It is in the best interests of Cotter, the Agencies and the Community that the pipeline be replaced – it’s good that Cotter will be doing this – it will fix a problem. But it is also an OPPORTUNITY to gain trust among the Agencies and the Community. EVEN MORE IMPORTANTLY, it is imperative that it be done properly. If there are lingering questions about the design, materials, or methods, then the opportunity will be wasted and repeated failures may continue to plague us. Again quoting from the Handbook, “Engineered Installation Guidelines for PE Pipe: There will be applications where the engineer will want to prepare a specific embedment specification. These applications would most likely include gravity flow pipes that are relatively deep, shallow cover applications where the pipe is subject to vehicular or train loading, pipes placed in unstable, soft, or wet soils, high DR pipes, and pipes in deep applications such as landfills and embankments.” If Cotter chooses not to conform to the recommendations of the PPI, then a Licensed Engineer must explain why not. The Agencies must REQUIRE an Engineered plan with Stamp for this specific project, in this specific location, with onsite soils and terrain analysis. It is important to achieve a permanent fix to this problem, and it is imperative to engender trust from the Community for future projects as we move forward in decommissioning the site.

4. Installation Oversight:

Cotter has named a firm for oversight of the installation. Please confirm the credentials of this firm and ensure that a qualified representative of the Firm will be onsite during all phases of the excavation, installation and testing. There are insufficient guidelines in Cotter’s current plan for the overseeing firm – too many operations are unspecified and left to interpretation. It would also be appropriate for a representative member of the CAG to be present during certain phases of the project.

TO: Jennifer Opila, Radiation Unit Manager

FROM: Cotter/Lincoln Park Superfund Site Community Advisory Group (CAG)

DATE: August 14, 2016

RE: CAG Additional Comments on Cotter Corporation’s (Cotter) Amended Proposal to Replace SCS Pumpback Line and SCS Pumpback System Maintenance

Thank you for the opportunity to submit additional comments on the replacement of the SCS Pumpback Line. Please find CAG comments on the system maintenance included as well.

GENERAL COMMENTS:First and foremost, the CAG members wish to thank CDPHE's Radiation Management Unit (RMU) for their excellent questions in the letter to Cotter dated March 28, 2016, regarding the SCS pipeline replacement proposal. We applaud and are encouraged by the depth of questions that were issued to Cotter for clarification, which were based upon standard industry requirements. We commend the Department for the direction in which the letter to Cotter took and hope that the Department will stand firm on their recommendations for proper pipeline installation.

Beginning December 17, 2015, nine letters have been exchanged between Cotter and CDPHE regarding the replacement and maintenance of the SCS pumpback line. The pipeline in question has failed many times since 2011; including a very recent failure of a feeder line, during warm weather, over the final weekend in July. Due to a series of failures, the CAG can only assume that this pipeline - along with all of its feeder lines - has extended beyond its use, or was installed incorrectly, and should be replaced in the manner that the Department alluded to in its March 28th letter. The CAG believes the requests made in this letter were not unreasonable and should be adhered to without further delay or discussion. The CAG submits these comments believing the intent of the March 28, 2016, letter from CDPHE to Cotter is not out of-the-ordinary and should be formalized and enforced forthwith.

SPECIFIC COMMENTS:The CAG's specific comments issue from CDPHE's letter to Cotter dated March 28, 2016, and Cotter's July 8, 2016, response.

1. The CAG concurs with CDPHE's requests to Cotter that:"… due to the nature and potential consequences of the work involved, the Agencies request this proposal/scope of work be designed and sealed by a Colorado Registered Professional Engineer." The CAG also believes that many of the comments by the Department would be addressed by Cotter's submittal of an 'engineer-based scope of work.'" [our emphasis]

REQUEST:The highest standard of professionally-engineered specifications be required

Attachment 4 - 9/28/2016 Cotter/Lincoln Park Superfund Site CAG Comment

for the complete pipeline and replacement of all feeder lines and maintenance of the entire line. The CAG requests this in order to ensure that the cause for these ongoing spills is once and for all taken care of in an exacting and judicious manner.

2. The Agencies requested that "… Cotter produce a map outlining the location of the entire SCS pumpback pipeline, including the identification of the area of the pipeline replaced during the 2008 installation, the current proposed 3,500 linear feet of pipeline, and other identifying site features.

REQUEST:The CAG supports the Agencies' request for this map and asks that this map be submitted.

3. The CAG wants clarification regarding Cotter's statement that this pipeline will be used for site remediation in its response item #4 in the July 8, 2016, letter:"Cotter's pipe selection is very conservative and provides for future potential pumping, as site remediation moves into the groundwater remediation phase."

REQUEST:• The CAG requests answers as to how this line might be used for remediation

purposes in the future.• In light of this statement, the CAG firmly believes that the pipeline should be

professionally engineered. The CAG believes the pipeline should be built with reinforced pipe for long-term lifespan use.

4. The CAG agrees with CDPHE's request to "… review the Plan and Profile drawings, including information on clean outs, high point vents, pipe restraints, and backflow prevention."

REQUEST:The CAG asks that CDPHE's request be adhered to.

5. The CAG members do not object to the entire 3500' pipeline being assembled, then placed into the excavation as long as all of the proper conditions are met before and after transfer provided that the Professional Engineer believes this is the proper manner to lay the pipeline into the trench.

REQUEST:The entire pipeline should be pressure tested before and after placement in trench.

6. The CAG acknowledges that Cotter is proposing engineered, stamped and sealed soil compaction tests and supervision of Kumar & Associates as they are licensed professional geotechnical engineers who per their website have experience in large industrial projects:

"Kumar's in-house materials laboratory is accredited by the American Association of State Highway and Transportation Officials (AASHTO) and validated by the US Army Corps of Engineers (USACE), and is periodically inspected by CDOT. Our materials testing personnel are well qualified and have WAQTC, NICET, ACI, PTI, AWS, ICC (IBC), LabCAT and CDOT Materials Course Certifications."


However, the CAG has little confidence in Kessler Reclamation. The CAG was unable to locate any website for Kessler Reclamation, any mention of professional organizations to which it belongs, or any accreditations. Therefore, again the CAG respectfully requests that a professional engineer supervise this project.

REQUEST:The CAG finds Cotter's response confusing as to which company will be performing which duty. In light of Cotter's allusion to the fact that this pipeline might be used for remediation purposes, the CAG would like to better understand each companies' duties.

7. In light of the most recent spill over the final weekend of July 2016 of approximately 7,000 gallons due to leakage on the feeder line which is part of the SCS pumpback line. This spill was not due to a cold-weather incident and no reason was given for the break in the feeder line.

REQUEST: Therefore, the CAG requests that all feeder lines be replaced during this project. The CAG believes this would be a judicious time to replace all of the old feeder lines.

8. Finally, the CAG believes that the possibility of discharging the Upstream SCS Trench into the SCS Pumpback system could be handled by the same Professional who would be engineering the entire project.

REQUEST: • The validity of discharging the Upstream SCS Trench into the SCS Pumpback

System Maintenance proposal.• A comprehensive maintenance plan for this systems maintenance.

In addition to the above requests, the CAG wishes that our previous comments of February 1, 2016, remain under consideration.

CONCLUSION:In conclusion the CAG would like to commend CDPHE for their stance - in its entirety - in the March 28th letter and advise that the Agencies remain steadfast in the direction of this letter regarding these matters and proceed without further delay. The CAG has highlighted a few of the items in which we support the requests made by the Agencies; however, this should not be deemed as a complete list. We concur with all of the requirements that would issue from the demeanor of this letter. The standard that the Potentially Responsible Party (PRP) is held to on this project appears to the CAG as a harbinger of requirements for future projects.

The CAG members request that this Comment be placed on the Colorado Department of Public Health and Environment (CDPHE) website.

Thank you,Lincoln Park Superfund Site Community Advisory Group (CAG)


CAG 3rd Pipeline Comment Page 1 of 8

Cotter Uranium Mill/Lincoln Park Superfund Site Community Advisory Group (CAG)

Canon City, CO 81212

September 28, 2016

Jennifer Opila, State Radiation Unit Manager Colorado Department of Public Health and Environment 4300 Cherry Creek South Drive Denver, CO 80260 Via Email: [email protected]

RE: OUTSTANDING ISSUES ON SCS PUMPBACK PIPELINE – 3RD SET OF CAG COMMENTS

Dear Mrs. Opila,

These comments incorporate our previous comments sent in February and August. At the September CAG meeting you stated that the Radiation Management Unit (RMU) is satisfied with Cotter’s latest response of July 8, 2016 in the above matter, and would be granting conditional approval in a Stage II document allowing replacement of the troubled SCS Pumpback pipeline with a Professional Engineer only required for soil compaction. You stated that getting the project done before winter was more important than waiting for Cotter to address the remaining outstanding issues, and that any outstanding issues should be covered in Cotter’s final construction report.

In light of the RMU’s subsequent capitulation from your letter of March 28, 2016, the CAG has chosen to immediately voice our concerns. It is our sincere hope that you will hear the CAG’s third statement of our strong approval for the Department’s initial intent to require a Colorado Licensed Professional Engineer for the entire project. The CAG believes approving a pipeline replacement of this magnitude without a Colorado Registered Professional Engineer’s plan, seal and oversight will be highly unusual, if not unprecedented.

I. QUESTIONS: The CAG members request answers to the following questions and issues:

1. Provide a written response stating the potential changes you are making in original requirements from your March 28, 2016 letter to Cotter, a letter which the CAG applauded as it reflected our concerns submitted in comments over prior response periods.


2. Is this pipeline replacement considered “maintenance” by the agencies, as Cotter claims?

3. Provide a formal definition of “maintenance” so that the CAG will have a better

understanding of what is considered maintenance in the future. This could include cost, percentage of a pipeline or something else being replaced, as well as the potential threat to human health and the environment.

4. Will Cotter be able to use this pipeline in the remedial design and feasibility phase? 5. According to EPA Guidance, how does this pipeline replacement feed into the

CERCLA process and future remediation work? 6. Does CDPHE and the EPA consider the pipeline replacement to be an early action to

clean up parts of a Superfund site that may become a threat to health and environment before the long-term cleanup begins?

II. CAG REQUESTS: Explanations follow in Section IV, Specific Comments

CAG 1st REQUEST: Require an Engineer for all phases of the pipeline replacement as originally requested on March 28, 2016.

CAG 2nd REQUEST: Do not relax the March 28th requirements due to viewing approaching winter as an emergency situation.

CAG 3rd REQUEST:

1. Provide surveyed locations and maps of all feeder lines and associated measured contaminants for the entire reach of the SCS Pumpback Pipeline.

2. Replace all feeder line pipes during this pipeline installment, thus enabling new pipe to be joined with new pipe.

3. Incorporate all feeder line pipe back flow preventers into the pressure monitoring system.

4. Not only should the SCS Pumpback Pipeline replacement be professionally engineered, but the entire pipeline and all feeder lines should be as well.

CAG 4th REQUEST: Require Cotter to follow the PPI Guidance for leak testing, as well as a leak detection plan designed and overseen by a Colorado Registered Professional Engineer. This is necessary in order to ensure that additional soil and groundwater contamination are not occurring below the pipeline.


III. GENERAL COMMENTS: There have been nine spill events associated with the pumpback system pipeline since 2010, when first discovered by the CAG from documents released by a Colorado Open Records Act request. Those spills have ranged between 500 and 210,000 gallons. Only four spills were sampled and analyzed, with a range of concentrations for uranium between 577 ug/L and 2,840 ug/L, and a range of concentrations for molybdenum between 840 ug/L and 3,740 ug/L. For reference, the groundwater standard for uranium is 30 ug/L, and for molybdenum is 100 ug/L.

As much as we would like to see this problem resolved, the CAG members believe it is more important to replace the pipeline correctly than to replace it quickly. The CAG members believe this project requires certification from a Professional Engineer so that the system will protect the safety, health, property, environment and welfare of the public.

Cotter’s recalcitrant behavior should not be rewarded by declaring approaching winter as an emergency situation making it necessary to withdraw the department’s requests in your letter dated March 28th.

The RMU’s recent acceptance of Cotter’s perfunctory responses in their July 8, 2016 letter leads the CAG to the conclusion that piece-meal measures will be allowed by the Agencies. The CAG repeats our concern, that the way in which the Agencies govern this major construction project of a pipeline (that conveys highly-contaminated water and will be used for future remediation) is a harbinger of how the many remediation processes will be governed in the future. This decision to allow Cotter’s proposal to go forward without a Colorado Registered Professional Engineer for the whole project will undermine any confidence the CAG has in future remediation processes.

IV. SPECIFIC COMMENTS: 1. Colorado Registered Professional Engineer

In its largely-applauded, strongly-worded March 28, 2016 letter, the Department noted the import of this project:

“Regardless, due to the nature and potential consequences of the work involved, the Agencies request this proposal/scope of work be designed and sealed by a Colorado Registered Professional Engineer. In addition, many of our other concerns, and comments listed below would be addressed by submitting an engineered-based scope of work/proposal.”

However, on July 8, 2016, Cotter responded that they considered “the project to be a routine maintenance issue.” In the same document, Cotter directly contradicts that statement by saying the pipeline may be used for remediation purposes, something much more than routine: "…future potential pumping, as site remediation moves into the groundwater remediation phase."


Only one piece of the pipeline’s replacement will require professional engineering per Mrs. Opila’s statement at the CAG: soil compaction. However, the Lincoln Park Superfund Site Cotter Corporation (N.S.L.) May 2016 QAPP Revision 1.0, at page 10 states:

At various points in time during the RI/FS process and through final site decommissioning, Cotter expects to retain specialist contractors and consultants for various tasks. These specialist contractors could include, but are not limited to: geotechnical, geochemical, geological, civil, hydrology/hydraulics, mechanical, radiological, regulatory, and electrical contractors. When engineering services are required, Cotter will only utilize professional engineers, licensed in the State of Colorado. Documents prepared by licensed engineers will be stamped and signed.

It seems inconsistent to require the above during data collection and analysis in the QAPP, but not during the design, construction and installation of a pipeline which will be used to transport contaminated groundwater during remediation.

The original 2008 S.M. Stoller Corporation As-Built plan did not include an engineer’s stamp, though S.M. Stoller employed certified Professional Engineers at the time. However, the proposed replacement of 3,500 feet of SCS pipeline would likely require an engineering stamp based on the state of Colorado’s definition of “the practice of engineering” specified in Section 12-25-102(10)(a), of the Colorado Revised Statutes defined as:

CRS 12-25-102. Definitions. As used in this part 1, unless the context otherwise requires: (10) (a) "Practice of engineering" means the performance for others of any professional service or creative work requiring engineering education, training, and experience and the application of special knowledge of the mathematical and engineering sciences to such professional services or creative work, including consultation, investigation, evaluation, planning, design, and the observation of construction to evaluate compliance with plans and specifications in connection with the utilization of the forces, energies, and materials of nature in the development, production, and functioning of engineering processes, apparatus, machines, equipment, facilities, structures, buildings, works, or utilities, or any combination or aggregations thereof, employed in or devoted to public or private enterprise or uses.

Relevant state laws known as Applicable and Relevant or Appropriate Requirements (ARARs) have not been fully developed at the Lincoln Park Superfund site. In spite of ARARs not being fully developed for this site, the general goal at the site should be at least to protect human health, the environment, and to eliminate exposure pathways. Due to the concentrations of contaminants transported in the pipeline, a Professional Engineer would need to certify the system is not a danger to the public as required in Board Rule 3.1.1 under the State Board of Licensure for Architects, Professional Engineers and Professional land Surveyors, which states:

3.1.1 Primary Obligation of Licensees. Licensees shall at all times recognize that their primary obligation is to protect the safety, health, property, and welfare of the public. If their professional judgment is overruled under circumstances where the safety, health,


property, or welfare of the public is endangered, they shall notify their employer or client and/or such other authority as may be appropriate.

In addition to the details outlined in the pipeline replacement proposal, the community would benefit from access to the pipeline installation plan, which provides information on erosion and sediment control, air/soil monitoring, health and safety, and the guidance Cotter will follow. For instance, the installation plan might provide information on plans in place to ensure that excavated soils do not run off into the sump pit or off site. According to the last significant pipeline replacement project completed by Stoller Corporation:

A Site-Specific Health and Safety Plan was prepared for the overall project to detail the engineering controls, personnel protection, and monitoring practices that ensured worker safety during the work activities. The work was performed in accordance with the health and safety plan and Occupational Safety and Health Administration and Mine Safety and Health Administration trenching rules.

CAG 1st REQUEST:

1. Require an Engineer for all phases of the pipeline replacement as originally requested on March 28, 2016.

2. This comment should extend to the current QAPP revision and the CAG formally requests that it do so.

2. Changing requirements due to winter’s approach

It was stated that the RMU believes it is "more important" to get this done before winter; however, the claim that the project must be hurried due to winter’s approach is assuaged in Cotter’s response to the Department on July 8th showing the pipe manufacturer’s claim that the work can be done in sub-zero weather using specific precautions and methods:

“Please refer to the pipe manufacturer’s recommendations for fusing and installing HDPA pipe under these conditions or the cold weather guidance in ASTM F 2620, Standard Practice for Heat Fusion Joining of Polyethylene Pipe and Fittings.”

Obviously, neither Cotter nor the pipe manufacturer considers winter’s approach as an emergency necessitating the department to allow Cotter to proceed without the full protection of a professionally engineered pipeline replacement.

In fact, Cotter’s letter of July 8th states that water is not accumulating in the sump area and expects this to be the case during the drier months. This statement by Cotter suggests they have additional time to produce a more detailed Engineer’s plan for the pipeline replacement. The pipeline has been leaking for at least six years. The CAG believes that a few more months delay in order to use proper engineering for the entire project should make little difference in the larger scheme of things.

CAG 2nd REQUEST: Do not relax the March 28th requirements due to viewing approaching winter as an emergency situation.


3. Feeder Lines and Leak Testing

A. 25-year-old Feeder Lines:

Cotter’s spill report of August 3, 2016 reported a leak from a feeder pipeline that “… conveys discharge from Cotter 1 recovery sump to the main SCS pumpback pipeline,” which broke due to being punctured by a sharp rock that was embedded above the feeder line. It is the CAG’s understanding that the feeder pipelines are approximately 25-years old. The report goes on to say that “Cotter maintains a pressure monitoring system on the SCS pumpback line that deactivates the pumps in the event of a sudden, large pressure drop.” However, the leak was not detected because a back flow preventer isolated the feeder line from the main pressure monitoring system causing the leak not to be detected. Cotter further stated that they will only "… consider moving this device during the SCS pipeline replacement, which will incorporate the feeder line into the pressure monitoring system." [our emphasis] Simply “considering” curing the issue of 25-year-old pipes with back flow preventers causing leak detection to be unnoticed is unacceptable.

CAG 3rd REQUEST:

1. The CAG requests surveyed locations and maps of all feeder lines and associated measured contaminants for the entire reach of the SCS Pumpback Pipeline.

2. Replace all feeder line pipes during this pipeline installment, thus enabling new pipe to be joined with new pipe.

3. Incorporate all feeder line pipe back flow preventers into the pressure monitoring system.

4. Not only should the SCS Pumpback Pipeline replacement be professionally engineered, but the entire pipeline and all feeder lines should be as well.

B. LEAK TESTING: Cotter’s July 8, 2016 response to CDPHE comments on proposal:

10. Leak testing should be performed in accordance with PPI guidance and based on requirements by a Professional Engineer.

COTTER’S RESPONSE: Cotter’s proposed leak testing method by pressurization is standard industry practice and will test the line well above the anticipated pressures. Cotter’s January 8, 2016 amended proposal states that the operating pressure will be 119psi; however, that pressure is at a 450-gpm flow rate, which is over 200 gpm more than the 2015 maximum. Therefore, the test pressure (150% over operating or 180 psi) is very conservative, and the need for an engineer to design the leak test is unnecessary.

CAG COMMENT: Pressures that will occur during future remediation are unknown; however, Cotter alluded to the pipeline being used for future remediation purposes:


"Cotter’s pipe selection is very conservative and provides for future potential pumping, as site remediation moves into the groundwater remediation phase."

Processes for remediation have not been determined. This statement precedes any facts in evidence that the pipeline and its installation requirements will meet CERCLA requirements.

In light of Cotter’s one paragraph answer to CDPHE’s question on leak testing and in light of the 17-page highly-detailed Plastics Pipe Institute Guidance for Field Hydrostatic Testing Of High Density Polyethylene Pressure Pipelines; Owner’s Considerations, Planning, Procedures and Checklists NT-46/2013a, the CAG’s concerns and the RMU’s March concerns are valid.

Cotter states that their plan is to “keep the upper 20% to 30% of the entire pipeline exposed, after embedment, during the 72-hour operational pipeline test and pressure test.” The CAG is concerned that it is a mistake to not visually view the entire length of the pipeline during leak testing. The guidance from PPI states:

Very long test sections may incorporate a large number of mechanical and flanged connections, which must be checked for leakage. The longer the test section becomes, the harder it is to locate a leak or to discriminate between a leak and other effects such as entrapped air being dissolved into solution under pressure. Prior to testing execution, a pre-assessment should be made as to what the recorded pressure versus time curves should look like, and how to read or interpret the actual recorded pressure data, so that acceptance or corrective action can be taken by experienced, trained, and qualified operators.

Has the test plan manual been approved, circulated to all operators, and understood by all participants in pre-test safety and quality meeting? (sign-in sheet) • Are some bolted joints going to be left exposed for visual inspection and possible re-torquing during or after testing? • If desired, is compacted embedment and trench fill going to be placed so that certain specified joints, fittings, service connections, or valves are exposed, in accordance with the owner’s test plan?

https://plasticpipe.org/pdf/tn-46-guidance-field-hydro-test-hdpe-pressure-considerations.pdf

This quote is but a small citation from a very complex document which regards the carrying of highly-contaminated liquids as a “special application.” This installation and leak testing is certainly not “routine maintenance.”

CAG 4th REQUEST: Require Cotter to follow the PPI Guidance for leak testing, as well as a leak detection plan designed and overseen by a Colorado Registered Professional Engineer. This is necessary in order to ensure that this exposure pathway is eliminated and additional soil and groundwater contamination are not occurring below the pipeline.


III. CAG FEEDBACK ON THE “ADVISORY” PROCESS

The CAG has time and again witnessed Cotter Corporation’s recalcitrance to take proper action in a timely manner. The CAG has watched as this manipulation works to Cotter’s benefit. At the same time, the CAG has been urged to supply our comments in a 15-day period. In contrast, Cotter has strung this project along and now claims that winter is approaching and the pipeline must go in quickly, despite having had over 10 months of discussion with the RMU and 6-years of leaking pipes that we know about. The CAG believes this is a blatant attempt to circumvent proper procedure.

Again, Cotter’s contradictory stances and downplaying of this project’s importance appear to the CAG as demonstrative of Cotter’s lack of respect and reveals a true intent for cost savings at the expense of thoroughness around a pipeline that could be used for decades of groundwater remediation.

The recent announcement that Cotter could proceed with only a professionally engineered plan for soil compaction has seriously set back the CAG’s trust in the entire CAG process. Thus we write imploring you to hold Cotter to a strict standard at the outset of the remediation process.

The CAG believes this is no time for leniency; all of the facts point against it, and we urge the RMU and the EPA to continue in the strong stand for proper installation of the new pipeline by a Professional Engineering firm.

The CAG requests that these comments be posted on the CDPHE/Cotter website.

Thank you,

Community Advisory Group Members

Attachments: March 28, 2016, Letter from CDPHE to Cotter Corp. July 8, 2016, Letter from Cotter Corp. to CDPHE February 1, 2016 CAG Pipeline Comments August 14, 2016 CAG Pipeline Comments cc: USEPA Mark Aguilar; Rob Stites; Jasmin Guerra; Shaun McGrath CDPHE Monica Sheets; Warren Smith; Dr. Larry Wolk

4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe

John W. Hickenlooper, Governor | Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer

March 28, 2016

Mr. Stephen J. Cohen, PG

Cotter Corporation

P.O. Box 1750

Cañon City, Colorado 81215-1750

Re: Proposal to Replace the Soil Conservation Service (SCS) Pumpback Pipeline

Dear Mr. Cohen,

This letter acknowledges receipt of your original written proposal dated December 17, 2015, including your

amended written proposal dated January 8, 2016, regarding replacement of the SCS pumpback pipeline. In your

proposal, you reported your intention to replace 3,500 linear feet of SCS pumpback pipeline due to a pipeline

break on December3, 2015, as described in your spill report dated December 8, 2015.

While your proposal indicates a general outline for removal and replacement of 3,500 linear feet of the SCS

pumpback pipeline, upon CDPHE and U.S. EPA (the Agencies) review, including the CAGs review, we have

concluded that your proposal is limited and lacks sufficient technical detail to thoroughly and completely outline

the replacement approach. Thus, Cotter is required to provide additional information and address agencies

comments and concerns as outlined below:

Your proposal presents a limited outline of technical approaches but does not represent an engineering-

based work plan. There are portions from the past SCS Pumpback Pipeline Final Construction Report –

November 2008 (FCR) referenced in the letter proposal, but overall it is unclear if Cotter intends to follow

the detailed technical approaches from your past pipeline projects or provide new engineering plans. If

Cotter intends to utilize past engineering documents then that intent should be declared in your letter

proposal. Additionally, while the FCR is referenced in the proposal it is a construction completion report

that summarizes work completed according to previous plans. Typically engineering work plans precede

FCRs and include scope of work statements, construction plans, specifications, and criteria for a

contractor to implement and control work as requested. The FCR mentions that such a work plan was

created by the S.M. Stoller Corporation in August 2007; however, it is not specifically cited in the FCR or

the letter proposal.

Regardless, due to the nature and potential consequences of the work involved, the Agencies request this

proposal/scope of work be designed and sealed by a Colorado Registered Professional Engineer. In

addition, many of our other concerns and comments listed below would be addressed by submitting an

engineering-based scope of work/proposal.

Text references are made that 3,500 linear feet of pumpback pipeline are to be replaced between the

downstream valve pit (downstream terminus) and the upstream valve pit (upstream terminus) endpoints.

Figure 1 of the proposal shows the pipeline location and endpoints. However, it appears that the map


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scale of 1-inch equals 1,000 feet is incorrect if the pipeline endpoints and alignment are correctly

labeled.

The Agencies request that Cotter produce a map outlining the location of the entire SCS pumpback

pipeline, including the identification of the area of the pipeline replaced during the 2008 installation, the

current proposed 3,500 linear feet of pipeline, and other identifying site features.

The Agencies request to review (and/or have included in a revised engineering-based proposal) the flow

calculations to confirm that the design basis, assumptions, and calculations are adequate and correct.

The Agencies are concerned about “sags” in the pipe potentially creating settlement traps. Therefore,

the Agencies request to review the Plan and Profile drawings, including information on cleanouts, high

point vents, pipe restraints, and backflow prevention.

Potential for frost heave and seismic displacement should be considered when designing the pipe system,

in addition to understanding the site slopes/topography, geology, site-specific soil types, and frostline

along the new installation. A Professional Engineer’s design should incorporate these considerations.

Potential issues regarding welding and cold weather should be considered. The Plastic Pipe Institute (PPI,

2015) guidelines have comprehensive cold weather welding instructions that should be utilized, if

necessary.

Page 2, Paragraph 3 – This paragraph describes the reference to stable soil as presented from the PPI

guidelines for simple installation procedures. Cotter considers the soils along the proposed pipeline to be

stable based on the presented arbitrary definition. Information and samples gathered from the last

pipeline installation support should be referenced if they support a simplified installation process. In

addition, since this proposed pipeline replacement is located in a separate area from the previous SCS

pumpback pipeline replacement, a minimum of three soil samples in the area of the current SCS

pumpback pipeline replacement should be collected and analyzed to verify support for a simplified

installation process.

While there may be sufficient native soils on site that are suitable for bedding, it is the Agencies

understanding and experience that over-excavating by 6-inches and placing suitable material will provide

a more uniform bedding. This is preferable in many areas and should be incorporated throughout the

proposal.

Leak testing should be performed in accordance with PPI guidance and based on requirements by a

Professional Engineer.

Page 2, Paragraph 2 – This paragraph states the removal of the existing pipeline will be performed and

that subsequent installation of new pipeline will be made pursuant to recommendations from the PPI.

The PPI document as referenced presents “guidelines” and not “recommendations”. The use of the term

recommendations may infer that the PPI has been specifically consulted for the pipeline installation at

Cotter. Additionally, Cotter should provide and/or specifically reference past work at the site directly.

Previous engineering work plans and construction reports, if applicable, could be used as supporting

information for engineering this pipeline replacement, in addition to a Professional Engineer’s stamp.

The Agencies request information on the Leak Detection methods being proposed, including a detailed

outline of how the Leak Detection system will be designed, monitored, and maintained during installation

and beyond.

Page 3, Pipeline Construction – This section describes pipe installation by the welding of five, 50-foot long

sections of pipe together to form 250-foot sections. The description of the pipe installation sequence into


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the trench is unclear. Are the 50-ffot sections welded outside of the trench then placed into the trench

as 250-foot sections? How are the 250-foot sections welded once completed? The FCR provides a better

description in Section 4.1 – Installation of the previous pipeline installation; however, it appears the

entire pipeline was completed prior to placement in the trench. Details of the proposed 2-inch leak

detection wells should be illustrated in relationship to the pipeline trench.

Page 4, Leak Testing – This section describes performing a test weld prior to pipeline installation and

pressure testing after embedment installation. Following production of a test weld the results of the

destructive test should be used for visual inspections of all pipe welds and documented by the project

engineer. Also, it is assumed that during the pressure testing the upper 20 to 30% of the pipeline after

embedment will remain exposed for the entire length of the pipeline alignment for visual inspections

during the pressure testing process. Please clarify if this is a correct assumption.

Page 3, Bedding, Paragraph 1 – This paragraph describes the general grading of the pipe trench bottom

and that the pipeline will be installed directly on the prepared trench bottom. What method is planned

to obtain a “prepared trench bottom”? Compaction is cited in Figure 2 of the proposal (Installation

Schematic), however, a criterion is not provided. Additionally, two types of bedding materials proposed

are native soils and pea gravel. Are the native soils to be screened to ensure the particle size criteria are

met and what mechanical screening method would be utilized?

Page 3, Pipe Embedment, Paragraph 1 – This paragraph describes using embedment material consisting of

granular backfill currently stockpiled at the Cotter mill and shown in Figure 3 of the proposal. The same

particle size limit of three-quarter inch should apply to the granular backfill as for the native soils. Figure

3 could benefit from a photo scale for reference. Are the native soils to be screened to ensure the

particle size criteria are met and what mechanical screening method would be utilized for the minimum

6-inch lift above the pipe and the embedment?

Page 4, Trench Backfill, Paragraph1 – This section describes final backfill of the trench along the pipeline

alignment. The last sentence of the paragraph states that backfill compaction will be performed once

every 1,000 feet of pipeline installed. This should state that “backfill compaction testing” will be

performed. Compaction of trench materials is expected for the entire length of pipeline alignment. It is

unclear what the standard lift intervals are planned beyond 6-inch and 12-inch beyond the top of the

pipeline. How are native excavated materials for final backfill to be screened for unsuitable size

materials during lift placement? Are mechanical screening methods going to be utilized in the field, e.g.

ALLU Pipeline Paddlers™ pipeline material screening equipment or equivalent?

The following are items listed in the Polyethylene Piping Systems Field Manual for Municipal Water

Applications (M&I Division, 2009 Edition) and are general good practices for HDPE pipeline installations,

with which an experienced contractor and certified installer would be familiar. A Professional Engineer

might also note and include these items in a stamped engineered plan.

o Vibratory placement can cause severe disturbance to the bedding and liquefaction of the

surrounding soils.

o If HDPE is stored in direct sunlight and installed in cold or cool soil, considerations should be given to allowing the pipeline to reach temperatures near the soil temperature prior to installation and welding.

o Proper care of the joints is critical to prevent leaks. Joints should be entirely free of dirt, contaminants, water or any other material prior to fusion. If temperatures are at or around 32 degrees Fahrenheit, pipe ends should be pre-heated prior to fusion. If conditions are windy, this can cause unacceptable temperature variations and joint contamination during fusion. In order to eliminate this possibility, a shelter could be used to protect the fusion heater plate and the pipe plugged to prevent blow through.

o To ensure proper Quality Assurance at the site, a datalogger can be used. A datalogging device can be attached to the hydraulic fusion machines to record the critical areas of the butt-fusion process. This data can be reviewed before allowing the joint to be buried to make sure the


of 4

proper fusion procedure was followed by the operator. This information can be downloaded to a PC as a permanent record of the joints on a particular project.

The proposal should include the names and qualifications of contractors, project engineers, etc. and their

roles in each phase of the project (i.e., pipeline installer’s familiarity with butt-fusion joining techniques,

etc.).

The proposal should indicate a general schedule for removal of the existing system and duration for the

construction, pressure testing, and anticipated date the new SCS pumpback pipeline will be operable.

The proposal should include descriptions on how the pumpback system will be operated and maintained

after the new pipeline is installed.

During removal of the existing pipe and construction of the new line, does Cotter have means to collect

and return water from the SCS pumpback sump?

Overall general request for this proposal and all future proposals/requests – Please include a copy of any

key reference material Cotter refers to in this proposal and all future proposals/requests. Providing this

information as part of the submittal package will ensure that the Agencies have the appropriate reference

material on hand to verify portions of Cotter’s request; are referencing the correct material; and are

efficient in the review process.

Cotter is required to provide us with a revised proposal for review that addresses our comments, concerns and

request for additional information listed above in this letter. In your revised proposal, please reference the Mail

Control Number 589631.

If you have any questions regarding this letter, please contact Alissa Schultz at (303) 692-3324 or

[email protected], or me at (303) 692-3403.

Sincerely,

Jennifer T. Opila, MPA

Radiation Program Manager

Hazardous Materials and Waste Management Division


mailto:[email protected]

@ cot:t:er

[EMAIL DELIVERY]

.July 8, 2016

Ms. Jennife r T. Opila, MP A

Radiation Program Manager

Hazardous Materials and Waste Management Division

Colorado DepaJ1ment of Public Health and Environment

4300 Cherry Creek Drive South

Denver. CO 80246- 1530

Re: Response to Agency Comments Regarding Cotter Corporation (N.S.L.)'s Amended Pipeline Proposal. Mail Control Number 589631

Dear Ms. Opila:

By lettcr dated March 28, 2016, the Colorado DepaJ1mcnt of Public Heal th aJld Environment

(CDPHE) transmitted its comments regarding Cotter Corporation (N.S.L.)' s ("Cotter") pipeline

replacement proposal. This letter contains Cotter' s responses to the CDPH E's comments. OUf

responses will be presented by tirst reiterating the agency's comments (in bold ) foll owed by Cotter' s response.

Discussions below use the terms "upstream" and "downstream" to denote sections of the

pipeline, The upstream section of the pipeline is the subject of the December 2015 and January

2016 pipeline replacement proposa ls. The downstream section of the pipeline was the subject of

the 2008 pipeline replacement.

1. Your proposal presents a limited outline of technical approaches but does not represent an engineering-based work plan. There are portions from the past SCS Pumpback Pipeline Final Construction Report - November 2008 (FCR) referenced in the letter proposal, hut overall it is unclear if Cotter intends to follow the detailed technical approaches from your past pipeline projects or provide new engineering plans. If Cotter intends to utilize past engineering documents then that intent should be declared in your letter proposal. Additionally, while the FCR is referenced in the proposal it is a construction completion report that summarizes work completed according to previous plans, Typically engineering work plans precede FCRs and include scope of work

Cotter Corporation Calion City M ill, P.O. Box 1750, Canon City, CO 8 1215~ 1750 USA

Te lephone 17191 275-7413 Fax (7191 275,1669


Ms. Jennifer T. Opila. MPA

July 8, 2016

Page 2

statements, construction plans, specifications, and criteria for a contractor to implement and control work as requested, The FCR mentions that such a work plan was created by the S.M. Stoller Corporation in August 2007; however, it is not specifically cited in the FCR or the letter proposal. Regardless, due to the nature and potential consequences of the work involved, the Agencies request this proposal/scope of work be designed and sealed by a Colorado Registered Professional Engineer. In addition, many of our other concerns and comments listed below would be addressed by submitting an engineering-based scope of work/proposal.

RESPONSE: Cotter has utili zed celtain aspects of the cited Stoller report to develop its proposal: however. most of the installation procedures were developed ti'om the Plastic Pipe Institute's ("PPJ' s") recommendations for a simplitied installation. Cotler notes that Stoller's linal construction report was not signed and sealed by an engineer. Coller determined that this pipeline proposal does not require an engineer's seal because of the following:

• Cotler considers thi s project to be a routine maintenance issue;

• Cotler is proposing a robust pipeline material; and

• The proposal is conservative with respect to the materials. pipe size, and installation (burying vs. surface installation).

One aspect of the installation, for which Cotter is seeking engineering oversight and approval is soi l compaction. Cotler considers soil compaction to be critical to the longevity of the proposed pipeline. Therefore. we have contracted with Kumar & Associates. Inc. to provide

geotechnicai testing for the project. Kumar & Associates, Inc., will provide licensed engineers to approve the soil compaction required for this project. A soil compaction report wi II be stamped and sealed by an engineer.

2. Text references are made that 3,500 linear feet of pumpback pipeline are to be replaced between the downstream valve pit (downstream terminus) and the upstream valve pit (upstream terminus) endpoints. Figure 1 of the proposal shows the pipeline location and endpoints. However, it appears that the map scale oft-inch equals 1,000 feet is

incorrect if the pipeline endpoints and alignment are correctly labeled.

RESPONSE: Cotter has surveyed the pipeline alignment using its GPS equipment. As a general reference, the topographic profile has been provided as Attachment I. For its tinal report. Cotter will contract with a professional land surveyor to survey locations and elevations of the pipeline to ensure that. proper slopes are maintained in the pipeline and to create a precise location map.

20 16-07-08 Response to Pipeline Comments - SJC


Ms. Jennifer T. Opila. MPA July 8. 20 16 Page 3

3. The Agencies request that Cotter produce a map outlining the location of the entire SCS pumphack pipeline, including the identification of the area of the pipeline replaced during the 2008 installation, the current proposed 3,500 linear feet of pipeline, and other identifying site features.

RESPONSE: Cotter fails to see how providing a map of the entire pipeline actually affects

the proposal for replacing the upstream 3,500 feet of pipeline. A drawing of the actual project

has been provided in Cotter's in itial and amended proposals. Furthennore, as stated in the

response to Item 2. Cotter will provide precise pipeline location drawings in its final report.

Therefore. no other drawings are necessary.

4. The Agencies request to review (and/or have included in a revised engineering-based proposal) the flow calculations to confirm that the design basis, assumptions, and calculations are adequate and correct.

RESPONSE: The current upstream pipeline is primarily 6-inch, Schedule 80. polyvinyl

chloride (PVC) pipe. The inner diameter of this pipe is 5.761 inches. and the wall thickness

is 0.432 inch (hnps:lltlexpvc.com/Reference/PVCPipeSize.shtml) (see AttacJmlent 2). By

comparison. the high density polyethylene (HOPE) proposed for fut ure upstream pipeline is

PE4710. DRll. which has an inner diameter of6.96 inches and a wall thickness 01'0.784

inch (200 psi) rating (see Attachment 3).

Cotter selected a larger diameter pipe wi th a larger wall thickness, without anticipating

higher pressures. Because the ditference in cost was minimal , Cotter purchased a pipe that

affords the pipeline a higher factor of safety . Cotter' s factors of safety are based on the

proposed pipe pressure rating (200 psi) and pressure calculations using the Hazen-Williams

Equation. which is as follows:

4.52 * Q 1.85 P d = -::-:-;;;---';-;-;;:;

C1.85 * d4.87

Pd = triction head loss in feet of water per 100 feet of pipe (psi waterl l 00 tt. of pipe)

c = Hazel1- Williams roughness coeftic ient

q = volumetric flow rate (gpm)

d = inside hydraulic diameter (inches)

Assuming 3,500 feet of pipeline length , 6.96-inch hydraUlic diameter (same as geometric

diameter tor circular pipe), a Hazen-Williams roughness coefticient of 140 (see Attachment

20 t 6-07-08 Response to Pipeline CO l11l11ents - SJC


Ms. Jennifer T . Opila. MPA

J uly 8. 2016

Page 4

4). and a tlow rate of350 gpm, the pressure drop wi ll be 6.75 psi over the upstream 3.500-foot pipeline section . Furthermore. the downstream 3,500 teet of pipeline replaced in 2008 consisted of 6-inch ORII . HOPE pipe (5.35-inch irUler diameter). The pressure drop over thi s length of pipe is 24.3 psi. Considering a static pressure head of 70 psi, the total ca lculated pressure for the upstream pipeline sect ion at a flow rate of350 gpm is 101.05 psi. whi le the pressure rating is 200 psi. This calculated pressure incorporates a conservati ve now rate of 350 gpm compared to the actua l maximum Ilow rate in 2015 of 240 gpm. As demonstrated above. Cotter's pipe selection is very conservative and provides for tuture potential pumping. as site remediation moves into the groundwater remediation phase.

5. The Agencies are concerned about "sags" in the pipe potentially creating settlement traps. Therefore, the Agencies requcst to review the Plan and Profile drawings, including information on clean outs, high point vents, pipe restraints, and backflow prevention.

RESPONSE: Cotter will utilize a professional land surveyor to measure the elevation of the pipeline to demonstrate that it was insta lled wi th proper slopes. This information will be provided in an installation report. Cotter does not intend to utilize restraints. cleanouts. or vents; however. Cotter wi ll provide the locations of check valves.

6. Potential for frost heave and seismic displacement sho uld be considered when designing the pipe system, in addition to understanding the site slopes/topography, geology, site

specific so il types, and frostline along the new installation. A Professional Engineer's design should incorporate these considerations.

RESPONSE: Cotter will be burying the pipeline to a depth that ensures that 42 inches offi ll cover the pipeline instead of burying the pipeline to a total depth of 42 inches. Therefore. issues of fi'eezing and frost heave wi ll not be an issue. The agencies' request for seismic studies, geologic studies. and more detailed topographic studies are not warranted for this project. Because the new pipeline wi ll be along the same alignment as the current pipeline, our current understanding of the aforementioned issues is sufticient to install the pipeline without additional studies that add cost without additional benefit.

7. Potential issues regarding welding and cold weather should be considered. The Plastic Pipe Institute (PPI, 2015) guidelines have comprehensive cold weather welding instructions that should be utilized, if necessary.

RESPONSE: Plastic Pipe Institute 's presents information regarding cold-weather welding in Technical Notes 27, Question 35 states. as follows (Attachment 5);

20 16-07-08 Response to Pipe lin e Comments - SJC


Ms. Jen ni fe r T. Opila. MPA July8.201 6 Page 5

Q. 35 Can HDPE pipe be fused and installed in sub-zero weather conditions? Yes, but the operator and fusion machine must be protected from the wind, moisture or blowing snow so that the heater plate uniformly heats the ends of the pipes. Please refer to the pipe manufacturer's recommendations for fusin g and installing HOPE pipe under these

conditions or the cold weather guidance in ASTM F 2620, Standard Practice for Heat Fusion Joining of Polyethylene Pipe and Fittings. For situations in which weather conditions prohibit fusion joining, mechanical connections should be considered.

Cotter does not intend to install the pipeline in cold weather. However. if thi s should occur. Cotter wi ll send its welders for additional training in cold weather welding.

8, Page 2, Paragraph 3 - This paragraph describes the reference to stable soil as presented from the PPJ guidelines for simple installation procedures. Cotter considers the soils along the proposed pipeline to be stable based on the presented arbitrary definition. Info/'mation and samples gathered from the last pipeline installation suPpo/·t should be referenced if they support a simplified installation process. In addition, since this proposed pipeline replacement is located in a separate area from the previous SCS pumpbaek pipeline replacement, a minimum of three soil samples in the area of the cun'ent SCS pumpback pipeline replacement should be collected and analyzed to verify support for a simplified installation process.

RESPONSE: Cotter's assertion that soil s are stable is not only based on the Plastic Pipe InstitUle' s definition. but also on test pits excavated by Cotter and inspected by EPA. and the documented 2008 downstream pipeline replacement. Soils along the alignment are sutliciently competent to hold a near veJiical 4-foot wall , and fIeld inspections show that

soils are primarily sandy. FUJihennore, our experience with repairing the current upstream pipeline clearly indicates that the so il s are stable. Therefore. no additional soi l testing is required.

9. While the/'e may be sufficient native so ils on site that are suitable for bedding, it is the Agencies understanding and experience that over-excavating by 6-inches and placing suitable material will provide a more uniform bedding, This is preferable in many areas and should be incorporated throughout the proposal.

RESPONSE: Cotter disagrees with this statement. PE47 10, ORll pipe is sufficiently robust that over-excavation is not required. Furthermore, our experience with less robust HOPE pipe installed on the ground surface indicates that thi s pipe will function we ll under various types of ground surfaces. Cotter's proposal is also consistent with installation of the

20 16-07-08 Response to Pipeline Comments· SJC



July 8,2016 Page 6

downstream pipeline section. Attachment 6 is a picture of the installation with the pipeline placed directly onto the tinished excavation bottom.

10. Leak testing should be performed in accordance with PPI guidance and based on requirements by a Professional Engineer.

RESPONSE: Cotter's proposed leak testing method by pressurization is standard industry practice and wi II test the line well above the anticipated pressures. Cotter's January 8, 2016 amended proposal states that the operating pressure will be 119 psi; however, that pressure is at 450-gpm flow rate, which is over 200 gpm more than the 2015 maximum. Therefore, the test pressure (150% over operating or 180 psi) is very conservative, and the need for an engineer to design the leak test is urmecessary.

11. Page 2, Paragraph 2 - This paragraph states the removal of the existing pipeline will be performed and that subsequent installation of new pipeline will be made pursuant to recommendations from the PPL The 1'1'1 document as referenced presents "guidelines" and not "recommendations". The use of the term recommendations may infer that the PPI has been specifically consulted for the pipeline installation at Cotter. Additionally, Cotter should provide and/or specifically reference past work at the site directly. Previous engineering work plans and construction reports, if applicable, could be used as supporting information for engineering this pipeline replacement, in addition to a Professional Engineer's stamp.

RESPONSE: Regarding a Professional Engineer's stamp, Cotter observes that the installation report for the downstream section of pipeline replaced in 2008 was not stamped by an engineer. While the Plastic Pipe Institute's document provides guidelines, this organization is the expert in the propel1ies and performance ofHDPE pipe. Consequently. their guidelines are sufticient for a satisfactory installation of the pipeline. Furtheml0re. Cotter' s experience with surface installations ofHDPE pipelines indicates that this material is very robust and that our proposal for burying the pipeline is very conservative. Therefore, we disagree with the need fo r an engineer's stamp, except for compaction testing. as stated above.

12. The Agencies request information on the Leak Detection methods being proposed, including a detailed outline of how the Leak Detection system will be designed, monitored, and maintained during installation and beyond.

RESPONSE: Cotter installed a pressure monitoring system on the current pipeline that deactivates pump back system in the event of a leak. This system proved etTective during the

2016·07-08 Response to Pipeline Comments - SJC


Ms. Jennifer T . Opila, MPA

July 8, 2016

Page 7

pipeline failure of December 3, 2015. In the event of a small leak that does not trigger the pressure monitoring system, small diameter standpipes will be installed adjacent to joints in the pipe at approximately 250-ft intervals. A hydraulic barrier will be placed on the downgradient side of the standpipe to trap water. Cotter personnel will inspect these standpipes weekly to ensure that slow leaks are detected in a timely manner and that Cotter can quickly tind the leak source.

13, Page 3, Pipeline Construction - This section describes pipe installation by the welding of five, 50-foot long sections of pipe together to form 250-foot sections. The description of the pipe installation seq uence into the trench is unclear. Are the 50-foot sections welded outside of the trench then placed into the trench as 250-foot sections? How are the 250-foot sections welded once completed? The FCR provides a better description in Section 4.1 - Installation of the previous pipeline installation; however, it appears the entire pipeline was completed prior to placement in the trench. Details of the proposed 2-inch leak detection wells should be illustrated in relationship to the pipeline trench.

RESPONSE. Cotter will revise the proposal to more clearly state the pipeline installation method. Cotter's contractor will construct the pipeline on the ground surface adjacent to the excavation. Once the entire pipeline is assembled, it will be placed into the excavation starting 11'om one end and moving along the pipeline to the other end.

14. Page 4, Leak Testing - This section describes performing a test weld prior to pipeline installation and pressure testing after embedment installation. Following production of a test weld the results of the destructive test should be used for visual inspections of all pipe welds and documented by the project engineer. Also, it is assumed that during the pressure testing the upper 20 to 30% of the pipeline after embedment will remain exposed for the entil'e length of the pipeline alignment for visual inspections during the pressure testing process. Please clarify if this is a correct assumption.

RESPONSE: Cotter will use the test weld section for visual inspections of all pipe welds, which will be documented by Cotter's construction inspector. Cotter will be keep the upper 20% to 30% of the entire pipeline exposed. after embedment. during the 72-hour operational pipeline test and pressure test. Only after successful completion of the pressure test and operational pipeline test, will Cotter back till the pipeline excavation.

15. Page 3, Bedding, Paragraph 1 - This paragraph describes the general grading of the pipe trench bottom and that the pipeline will be installed directly on the prepared trench bottom. What method is planned to obtain a "prepared trench bottom"? Compaction is cited in Figure 2 of the proposal (Installation Schematic), however, a

20 16-07-08 Response to Pipeline Comments - SJC


Ms. Jennifer T. Opila, MPA

July 8. 2016

Page 8

criterion is not provided. Additionally, two types of bedding materials proposed arc

native soils and pea gl·avel. Are the native soils to be screened to ensul'e the particle size

criteria are met and what mechanical screening method wonld be utilized?

RESPONSE: Cotter intends to use the finished bottom of the trench excavation for the

bottom. Cotter does not intend to compact the bottom pursuant to any criteria. but will

compact the bottom where necessary for providing a level surface for installation. Specific

compaction requirements for the trench bottom are not necessary considering the wall

thickness of the pipe and its rigidity, which is consistent with the 2008 downstream pipeline

construction (see Attachment 4). Regarding soil backfilL the proposal presents a maximum

grain size for the soil backtill. as pm1 of the embedment which will be native soil s with a

maximum grain size of 0.5 inch.

16. Page 3, Pipe Embedment, Paragraph 1 - This paragraph describes using embedment

material consisting of granular backfill currently stockpiled at the Cottel' mill and

shown in Figure 3 of the proposal. The same particle size limit of three-quarter inch

should apply to the granular backfill as for the native soils. Figure 3 could benefit from

a photo scale for reference. Are the native soils to be screened to ensure the particle size

criteria are met and what mechanical screening method would be utilized for the

minimum 6-inch lift above the pipe and the embedment?

RESPONSE: Our contractor possesses screens that can siti out unwanted particles to ensure

that our particle size requirements are met. The granular backfill does not contain particles

greater than 0.75 inches.

17. Page 4, Trench Backfill, Paragl'aph 1 - This section describes final backfill of the trench

along the pipeline alignment. The last sentence of the paragraph states that backfill

compaction will be performed once every 1,000 feet of pipeline installed. This should

state that "backfill compaction testing" will be performed. Compaction of trench

materials is expected for the entire length of pipeline alignment. It is unclear what the

standard lift intervals are planned beyond 6-inch and 12-inch beyond the top of the

pipeline. How are native excavated materials for final backfill to be screened for

unsuitable size materials during lift placement? Are mechanical screening methods

going to be utilized in the field, e.g. ALLU Pipeline Paddlers™ pipeline material

screening equipment or equivalent?

RESPONSE : The proposal will be conected to state that compaction testing will be

performed once per every 1,000 feet of pipeline installed. Trench backfill will be installed in

2016-07-08 Response to Pipeline Comments - SJC



July 8. 2016

Page 9

12-inch lifts beyond the two lifts discussed above. until the ground surface is reached. Cotter's proposal will be revised to reflect this clarification.

18. The following are items listed in the Polyethylene Piping Systems Field Manual for Municipal Water Applications (M&I Division, 2009 Edition) and are general good practices for HDPE pipeline installations, with which an experienced contractor and certified installer would be familiar. A Professional Engineer might also note and include these items in a stamped engineered plan.

o Vibratory placement can cause severe disturbance to the bedding and liquefaction of the surrounding soils. o If HDPE is stored in direct sunlight and installed in cold or cool soil, considerations should be given to allowing the pipeline to reach temperatures near the soil temperature prior to installation and welding. o Proper care of the joints is critical to prevent leaks. Joints should be entirely free of dirt, contaminants, water or any other material prior to fusion. If temperatures are at or around 32 degrees Fahrenheit, pipe ends should be pre-heated prior to fusion. If conditions are windy, this can cause unacceptable temperature variations and joint contamination during fusion. In order to eliminate this possibility, a shelter could be used to protect the fusion heater plate and the pipe plugged to prevent blow through. o To ensure proper Quality Assurance at the site, a datalogger can be used. A datalogging device can be attached to the hydraulic fusion machines to record the critical areas of the butt-fusion process. This data can be reviewed before allowing the joint to be buried to make sure the propel' fusion procedure was followed by the operator. This information can be downloaded to a PC as a permanent record of the joints on a particular project.

RESPONSE: Cotter offers the following responses:

I. The materials at the bottom of the trench or on the sidewalls are not now. nor will they be saturated and cohesionless. Therefore, liquefaction will not be an issue.

2. Cotter and its contractor are well aware of the expansion/contraction associated with HDPE pipe installation. Furthermore. Cotter's contractor and construction oversight manager have been trained and certitied in the specitic welding machine to be used for this project as well as other HDPE pipe installation procedures.

3. Same response as No. 2. Cotter' s training discussed above addressed procedures for cold-weather installation ; however. Cotter is not anticipating installing the pipeline in cold weather.

4. Cotter is renting a high-quality welder. which is equipped with a data logger.



Ms. Jennifer T . Opila. MPA

July 8. 2016

Page 10

19. The proposal should include the names and qualifications of contractors, project

engineers, etc. and their roles in each phase of the project (i.e., pipeline installer's

familiarity with butt-fusion joining techniques, etc.).

RESPONSE: For all phases of work Kessler Reclamation Company (Kessler) will be

excavating the current pipeline and installing the new one. Kessler has undeltaken many

remediation and conventional construction projects at Cotter's Canon City facility and other

Cotter locations and has completed many pipeline construction projects. Kessler has also

installed most of the HDPE pipelines at the Canon City facility and other Cotter facilities .

Furthermore. Kessler has been trained and celtified on the pmticular welding machine to be

used for this pipeline. as well as other aspects of HDPE pipe installation. Kumar &

Associates will be conducting all compaction and soils tests for all phases of the project.

Kumar & Associates are licensed professional geotechnical engineers in the State of

Colorado and have the requisite experience to complete this project.

20. The proposal should indicate a general schedule for removal of the existing systcm and duration for the construction, pressure testing, and anticipated date the new SCS

pump back pipeline will be operable.

RESPONSE: Because a schedule depends entirely upon the agency approval date tor this

proposal, a precise schedule cannot be determined. However, installation ofthe new pipeline

would require approximately 3 weeks. alter which pressure testing would occur tollowed by

a 72-hour test run all while the pipeline is exposed. After testing. Cotter will backtlll the

excavation.

21. The proposal should include descriptions on how the pumpback system will be opel'ated

and maintained after the new pipeline is installed.

RESPONSE: After completion, the pumpback system will be operated in the same manner

it is now. Three pumps (set at ditJerent water elevations) will transfer water through the

pipeline to the water distribution pond and eventually to the primary impoundment. A

pressure monitoring system will be utilized as leak detection in the same manner it is tor the

cnn-ent pipeline. Standpipes will be monitored weekly to detect leaks that are too small to trigger the pressure system shutoff switches that deactivate the line.

22. During rcmoval of the existing pipe and construction of the new line, does Cotter have

means to collect and return water from the SCS pumpback sump?



Ms. Jennifer T. Opila, MPA

July 8. 2016 Page II

RESPONSE: Cotter does not intend to pump water ii'om the SCS during construction.

Instead. Cotter will plug the drain lines that go into the sump. Pumping will resume once the pipeline is in place. At this point in time. the SCS is pumping less than I gpm, which means

that no surface water is entering the sump and groundwater intlow is very minimal.

Therefore. plugging the drains during the drier months will have no impact on groundwater

recovery.

23. Overall general request for this proposal and all future proposals/requests - Please include a copy of any key reference material Cotter refers to in this proposal and all future proposals/requests. Providing this information as part of the submittal package will ensure that the Agencies have the appropriate reference material on hand to verify portions of Cotter's request; are referencing the correct material; and are efficient in the review process.

RESPONSE: Cotter agrees to comply with this request. and has attached reierence

materials.

The above discussion presents ollr responses to the CDPHE's comments. Once Cotter receives

tinal approval of its responses irom CDPHE. Cotter will provide a revised a proposal that

memorializes Cotter's commitments and requirements specitied in these and any iuture comment responses. Cotter appreciates your attention to this matter.

If you have any questions regarding our responses, please contact me.

Sincerely.

Stephen J. Cohen. PG

Mill Manager

Cc: Mark Aguilar

Alissa Schultz Ken Mushinski

Craig Harlin

Jim Cain

Document Control

Attachments: 1 - Pipeline Topographic Proiile




July 8. 2016

Page 12

2 - PVC Pipe Sizes

3 - HOPE Pipe Sizes

4 - Hazen-Williams Roughness Coefficients

5 - Plastic Pipe Institute. TN-n. Frequently Asked Questions 6 - Pictures of 2008 Pi peline Installation



CAG Pipeline Comments 2016-02-01: Page 1 of 5

From: Cotter/Lincoln Park Community Advisory Group To: Jennifer Opila, State Unit Leader Date: February 1, 2016 Re: Stage I - Public Comment on Cotter Corporation’s Amended Proposal to

Replace SCS Pumpback Line The CAG members thank you for the opportunity to submit Comments. GENERAL COMMENTS: In preparation of these comments, we thank Marcus Griswold of SKEO for research, answering CAG questions, and offering advice. We also thank two of our CAG members for their life experience which aided the CAG’s understanding: Bill Matthews, a previously certified pipe welder who worked in the field on similar projects for many years; and, Michael Stiehl, who had exposure to similar issues as a previous Fremont County Commissioner and citizen active in the State. The CAG members appreciate very much Cotter’s decision to replace the pipeline which experienced breaks and spills eight times between November 2010 and December 2015. Even though Fremont County will not be allowed to permit the installation of the pipeline as it is entirely on site at the Cotter property, we trust that CDPHE and the EPA will ensure that all engineering protocols are followed. If a more detailed plan for the project is submitted to the agencies, a certified professional with expertise in this type of installation should submit a report with any findings or recommendations that will be made available to the public. The pumpback system and pipeline plays a critical role in protecting off-site community groundwater from on-site contaminated groundwater. The regulatory agencies handling of this project will be crucial in gaining community trust going forward into the RI/FS and Remedial phases of the superfund cleanup. Request: The CAG requests that Bill Matthews and one other member be permitted to observe at some point during each phase of the pipeline replacement. Request: Require Cotter to create a map showing the location of the entire pipeline, including identification of the 2008 installation, and include identifying site features. Based on the best of our knowledge, the CAG members offer the following comments and requests, and we look forward to your response.



SPECIFIC COMMENTS: 1. Contractors: The proposal does not name contractors working for Cotter on this

project. We were told at the Jan 14, 2016 CAG that Kumar & Associates would perform compaction tests, but it is unclear from the proposal as to who will be performing the other phases of work.

Request: Include in the proposal all names and qualifications of contractors, and their roles in each phase of the project.

2. Engineered Plan and Design: Superfund policy and Section XI, item 57 of the Administrative Settlement Agreement and Order on Consent between Cotter, EPA and CDPHE do not require local, State, or federal permits (except what’s required under the license) for any action conducted entirely on-site. Both do require Cotter to comply with all applicable State and federal laws and regulations, especially those more stringent than federal laws. However, it is of concern that relevant laws known as ARARs (Applicable and Relevant or Appropriate Requirements) have yet to be developed for this site. We also note that the 2008 Stoller as-built report, the specs to be used again for this project, did not appear to be a stamped engineer’s plan or design. Given the above, based on feedback from the Colorado Board of Licensure for Architects, Professional Engineers and Professional Land Surveyors, Marcus Griswold of SKEO was told that the replacement of the pipeline would likely require an engineering stamp, especially addressing the following two items:

a. The design and installation of the pipeline appears to constitute the State’s definition of “the practice of engineering” specified in Section 12-25-102(10)(a) of Colorado Revised Statutes. b. Due to the concentration of uranium and molybdenum reported in the July 2015 analysis of water from the pipeline, a Professional Engineer would need to certify that the system is not a danger to the public, as required in Board Rule 3.1.1 under the State Board of Licensure for Architects, Professional Engineers and Professional Land Surveyors.

In 2008, the Stoller Corporation did prepare a “Site-Specific Health and Safety Plan” for the overall project. Stoller’s report states, “The work was performed in accordance with the health and safety plan and Occupational Safety and Health Administration and Mine Safety and Health Administration trenching rules.”

The CAG is also of the opinion that the community would benefit from access to the pipeline installation plan, in addition to the submitted proposal, which would provide information on erosion and sediment control, air/soil monitoring, health and safety, and the guidance Cotter will follow.

Request: The CAG members agree with Bill Matthews that a stamped

engineered plan and design should be developed to satisfy the general goal to



protect human health and the environment at this site. This is especially necessary due to the nature of its purpose, to prevent migration of contaminated groundwater off-site, and due to the length of time it may have to be in service.

3. Trench Depth and Frostline: Potential for frost heave and seismic

displacement should be considered when designing the pipe system. Cotter’s proposal does not include slopes or site topography, though the Stoller 2008 plan does. Having access to topographic maps could assist in understanding the rationale for the pipeline design.

We were told at the CAG by Steve Cohen of Cotter that the total depth of the trench will be 42”. Pueblo County has adopted a depth of 48 inches to be “one foot below the frost line” which is 6” deeper than Cotter’s plan (https://prbd.com/faq.php) [see #7 under Plumbing FAQs]. Bill Matthews was told by the City of Canon City that their water lines have a minimum of 42 inches of soil cover over the pipe. It would be of benefit to the community if an engineered plan and design confirmed the proposed depth of the trench. The CAG members believe that during the design and installation process the frost line and soil type should be studied thoroughly to assess the potential for expansion and contraction around the pipeline. While HDPE is more tolerant of expansion and contraction than PVC pipe, a combination of bad welds and contraction/expansion could cause joint leaks. In addition, both Bill Matthews and Michael Stiehl voiced the opinion that the terrain, geology, and possible expansive soils in the area where the new pipe will be installed does not appear to be identical to the area of the 2008 installation. Request: For all of the above reasons, the CAG again believes there is a need for a stamped engineered plan and design for this project based on studies of site specific soil types, geology and frostline along the new installation.

4. Bedding Beneath the Pipe: We were told at the January 14th CAG meeting that Cotter will not be placing any bedding material beneath the pipe, but will use the native soil encountered unless any rocks or a pit is discovered. Michael Stiehl voiced the opinion that there should be bedding material according to the International Pipeline Institute. Mr. Cohen disagreed and believes the installation instructions for the pipe is sufficient. Michael Stiehl responded that those instructions are not specific to this particular site. Also, Bill Matthews reported that he was told by the City of Canon City that they used a minimum of 6” of bedding beneath their pipe installations.

Request: Require Cotter’s proposal to include an engineer’s opinion on the above, based on a study of the soils and geology in this specific area where the new pipe will be installed.

5. Pipeline Installer Qualifications: The current pipeline proposal would benefit from documentation citing the qualifications of the pipeline installer and their familiarity with butt fusion techniques. This information is from the Plastic Pipe



Institute’s TN-42 Recommended Minimum Training Guidelines for PE Pipe Butt-Fusion Joining Operators for Municipal and Industrial Projects (2009).

Request: Require the above information in Cotter’s proposal for pipeline replacement.

6. Welding and Cold Weather: Bill Matthews voiced a concern about welding

being done during cold weather. Note that many of the prior leaks occurred as a result of couplers breaking or becoming loose. For example, the September 8, 2014 leak occurred when the welding at the joint connecting two pipes loosened (September 8, 2014 email from Cotter, John Hamrick, to Jennifer Opila at CDPHE). Cotter’s proposal does not mention any considerations regarding recommended temperatures or weather during welding of the pipe.

Request: Require Cotter to make this determination backed by a qualified

engineer and pipe welder. We recommend that the project not be conducted during cold weather.

7. Additional Items to consider: The following items were found in the

Polyethylene Piping Systems Field Manual for Municipal Water Applications, M&I Division 2009 Edition:

a. Vibratory placement can cause severe disturbance to the bedding and liquefaction of the surrounding soils. b. If HDPE is stored in direct sunlight and installed in cold or cool soil, considerations should be given to allowing the pipeline to reach temperatures near the soil temperature prior to installation and welding. c. Proper care of the joints is critical to prevent leaks. Note that many of the prior leaks at the Site occurred as a result of couplers breaking or becoming loose, as mentioned in paragraph #6 above. Joints should be entirely free of dirt, contaminants, water or any other material prior to fusion. If temperatures are at or around 32 degrees Fahrenheit, pipe ends should be pre-heated prior to fusion. If conditions are windy, this can cause unacceptable temperature variations and joint contamination during fusion. To eliminate this possibility, a shelter could be used to protect the fusion heater plate and the pipe plugged to prevent blow through. The optimal temperature of the fusion plate is 425 degrees Fahrenheit. d. To ensure proper Quality Assurance at the site, a datalogger can be used. A datalogging device can be attached to the hydraulic fusion machines to record the critical areas of the butt fusion process. This data can be reviewed before allowing the joint to be buried to make sure the proper fusion procedure was followed by the operator. This information can be downloaded to a PC as a permanent record of the joints on a job.



Request: Again, an engineer’s stamped design and plan would provide much more detail than Cotter’s current proposal, which might include items suggested above.

8. Monitoring and Maintenance:

a. As recommended in the proposal, having a leak detection system is a positive step to assessing pipe failure. The community would benefit from a more detailed description of how the leak system will be monitored and documented. The Plastic Pipeline Institute also recommends the audio technique for monitoring leaks, which listens for the sound emitted as the fluid flows irregularly through an unplanned opening in the pipe, (Plastic Pipe Institute, 2009. PPI-TN27: Frequently asked questions. HDPE pipeline for water distribution and transmission applications). b. Pump system: The pipeline and pumps act as a single system and could be addressed as such. More specifics could be provided on the operations and maintenance plan for the pipeline and pump as a system. For instance, the recent silting in of the pump also included rusting of the pump. We recommend regular cleaning and maintenance of the pump, preferably by a mechanical engineer. Request: Require Cotter to include a more detailed description of how the leak system will be designed, monitored and documented. Also require Cotter to include more specifics on the day-to-day operations and the maintenance plan for the pipeline and pump system after it is installed.


TO: Jennifer Opila, Radiation Unit Manager

FROM: Cotter/Lincoln Park Superfund Site Community Advisory Group (CAG)

DATE: August 14, 2016

RE: CAG Additional Comments on Cotter Corporation’s (Cotter) Amended Proposal to Replace SCS Pumpback Line and SCS Pumpback System Maintenance

Thank you for the opportunity to submit additional comments on the replacement of the SCS Pumpback Line. Please find CAG comments on the system maintenance included as well.

GENERAL COMMENTS:First and foremost, the CAG members wish to thank CDPHE's Radiation Management Unit (RMU) for their excellent questions in the letter to Cotter dated March 28, 2016, regarding the SCS pipeline replacement proposal. We applaud and are encouraged by the depth of questions that were issued to Cotter for clarification, which were based upon standard industry requirements. We commend the Department for the direction in which the letter to Cotter took and hope that the Department will stand firm on their recommendations for proper pipeline installation.

Beginning December 17, 2015, nine letters have been exchanged between Cotter and CDPHE regarding the replacement and maintenance of the SCS pumpback line. The pipeline in question has failed many times since 2011; including a very recent failure of a feeder line, during warm weather, over the final weekend in July. Due to a series of failures, the CAG can only assume that this pipeline - along with all of its feeder lines - has extended beyond its use, or was installed incorrectly, and should be replaced in the manner that the Department alluded to in its March 28th letter. The CAG believes the requests made in this letter were not unreasonable and should be adhered to without further delay or discussion. The CAG submits these comments believing the intent of the March 28, 2016, letter from CDPHE to Cotter is not out of-the-ordinary and should be formalized and enforced forthwith.

SPECIFIC COMMENTS:The CAG's specific comments issue from CDPHE's letter to Cotter dated March 28, 2016, and Cotter's July 8, 2016, response.

1. The CAG concurs with CDPHE's requests to Cotter that:"… due to the nature and potential consequences of the work involved, the Agencies request this proposal/scope of work be designed and sealed by a Colorado Registered Professional Engineer." The CAG also believes that many of the comments by the Department would be addressed by Cotter's submittal of an 'engineer-based scope of work.'" [our emphasis]

REQUEST:The highest standard of professionally-engineered specifications be required


for the complete pipeline and replacement of all feeder lines and maintenance of the entire line. The CAG requests this in order to ensure that the cause for these ongoing spills is once and for all taken care of in an exacting and judicious manner.

2. The Agencies requested that "… Cotter produce a map outlining the location of the entire SCS pumpback pipeline, including the identification of the area of the pipeline replaced during the 2008 installation, the current proposed 3,500 linear feet of pipeline, and other identifying site features.

REQUEST:The CAG supports the Agencies' request for this map and asks that this map be submitted.

3. The CAG wants clarification regarding Cotter's statement that this pipeline will be used for site remediation in its response item #4 in the July 8, 2016, letter:"Cotter's pipe selection is very conservative and provides for future potential pumping, as site remediation moves into the groundwater remediation phase."

REQUEST:• The CAG requests answers as to how this line might be used for remediation

purposes in the future.• In light of this statement, the CAG firmly believes that the pipeline should be

professionally engineered. The CAG believes the pipeline should be built with reinforced pipe for long-term lifespan use.

4. The CAG agrees with CDPHE's request to "… review the Plan and Profile drawings, including information on clean outs, high point vents, pipe restraints, and backflow prevention."

REQUEST:The CAG asks that CDPHE's request be adhered to.

5. The CAG members do not object to the entire 3500' pipeline being assembled, then placed into the excavation as long as all of the proper conditions are met before and after transfer provided that the Professional Engineer believes this is the proper manner to lay the pipeline into the trench.

REQUEST:The entire pipeline should be pressure tested before and after placement in trench.

6. The CAG acknowledges that Cotter is proposing engineered, stamped and sealed soil compaction tests and supervision of Kumar & Associates as they are licensed professional geotechnical engineers who per their website have experience in large industrial projects:

"Kumar's in-house materials laboratory is accredited by the American Association of State Highway and Transportation Officials (AASHTO) and validated by the US Army Corps of Engineers (USACE), and is periodically inspected by CDOT. Our materials testing personnel are well qualified and have WAQTC, NICET, ACI, PTI, AWS, ICC (IBC), LabCAT and CDOT Materials Course Certifications."


However, the CAG has little confidence in Kessler Reclamation. The CAG was unable to locate any website for Kessler Reclamation, any mention of professional organizations to which it belongs, or any accreditations. Therefore, again the CAG respectfully requests that a professional engineer supervise this project.

REQUEST:The CAG finds Cotter's response confusing as to which company will be performing which duty. In light of Cotter's allusion to the fact that this pipeline might be used for remediation purposes, the CAG would like to better understand each companies' duties.

7. In light of the most recent spill over the final weekend of July 2016 of approximately 7,000 gallons due to leakage on the feeder line which is part of the SCS pumpback line. This spill was not due to a cold-weather incident and no reason was given for the break in the feeder line.

REQUEST: Therefore, the CAG requests that all feeder lines be replaced during this project. The CAG believes this would be a judicious time to replace all of the old feeder lines.

8. Finally, the CAG believes that the possibility of discharging the Upstream SCS Trench into the SCS Pumpback system could be handled by the same Professional who would be engineering the entire project.

REQUEST: • The validity of discharging the Upstream SCS Trench into the SCS Pumpback

System Maintenance proposal.• A comprehensive maintenance plan for this systems maintenance.

In addition to the above requests, the CAG wishes that our previous comments of February 1, 2016, remain under consideration.

CONCLUSION:In conclusion the CAG would like to commend CDPHE for their stance - in its entirety - in the March 28th letter and advise that the Agencies remain steadfast in the direction of this letter regarding these matters and proceed without further delay. The CAG has highlighted a few of the items in which we support the requests made by the Agencies; however, this should not be deemed as a complete list. We concur with all of the requirements that would issue from the demeanor of this letter. The standard that the Potentially Responsible Party (PRP) is held to on this project appears to the CAG as a harbinger of requirements for future projects.

The CAG members request that this Comment be placed on the Colorado Department of Public Health and Environment (CDPHE) website.

Thank you,Lincoln Park Superfund Site Community Advisory Group (CAG)
