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Status of Sediment and Groundwater Remedies. Or… What’s up with that O&F Determination?. Last Annual Meeting Recap. The Road to Operation and Maintenance (O&M)
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Last Annual Meeting Recap The Road to Operation and Maintenance (O&M) • Measures initiated after remedy has achieved the remedial action objectives in the ROD, and has been determined to be Operational and Functional • Measures are designed to ensure the remedy remains protective of human health and the environment, and maintain the integrity/effectiveness of the remedy
Last Annual Meeting Recap EPA and DEQ Cooperative Agreement • Two year agreement describing activities and funding necessary for an O&F Determination • Target O&F determinations for both Sediment and Groundwater remedies by end of first year - September 30, 2010
Last Annual Meeting Recap O&F: Remedies are Performing as Designed Key Activities: • Water sampling, inspections (bathymetry, divers), groundwater monitoring, NAPL recovery and measurement • Sheen Characterization
Last Annual Meeting Recap Long Term Performance Monitoring - Brainstorming • Porewater monitoring only • SPME vs. “Traditional” • Inter-armoring and surface water data meets cleanup goals • Increases in porewater sampling would trigger additional assessment • Other sampling media - clams
Last Annual Meeting Recap Continue NAPL Recovery? • Why? ROD Requirements • When do we stop? Decline curve - recovery is asymptotic • Reassess how much can be recovered • Revisit previous recovery efforts, incl. 2006 ITE • Consider better recovery method than the current one
EPA and DEQ Decisions • September 30, 2010 is too soon for O&F Determination • Possible to make an O&F determination on the Sediment Remedy within cooperative agreement time frame, and • Consider differing the O&F determination on the groundwater remedy • Still recovering NAPL • Timing with the Portland Harbor ROD - 2013
EPA and DEQ Decisions Modified Cooperative Agreement activities • Scope more effective NAPL recovery system - draft design and cost • CA activity reassessment to shift funding to pay for NAPL recovery system design and construction • Reduce site inspections/meetings • Use Bathymetry data from 2009 Portland Harbor survey • Revisit site-wide groundwater monitoring plan • Final sediment cap sampling: SPME in October 2010
Road to O&F Realigned • O&F Determination for the Sediment Cap Remedy – September 30, 2011 • Long term O&M Plan • Modified DEQ and EPA agreements • NAPL recovery system constructed • Regulatory • Remedial Action Report • Five Year Review • Target O&F Determination for the Groundwater Remedy September 30, 2013