From: GREENBURG Michael J
Sent: Tue Sep 11 09:53:48 2018
To: 'RICHERSON Phil'
Subject: RE: TriMet WPCF Permit #103083 - Drywell Closure Notification Reminder
Importance: Normal
Phil this approach seems reasonable to me but this is obviously your show.
From: Krzeminski, Michael <KrzeminM@TriMet.org>
Sent: Tuesday, September 11, 2018 9:42 AM
To: 'RICHERSON Phil' <Phil.Richerson@state.or.us>
Cc: 'Rick Wadsworth' <RWadsworth@parametrix.com>; 'GREENBURG Michael J' <Michael.J.GREENBURG@state.or.us>
Subject: RE: TriMet WPCF Permit #103083 - Drywell Closure Notification Reminder
Phil,
Attached are the results of the UIC sediment sampling that Parametrix conducted to support the UIC closure activities. A summary of the results is presented below:
· During the investigation activities 4 additional UICs were found (bringing the site total up to 24 UICs). These new drywells were previously identified as sedimentation manholes, but turns out they were the original drywells that became plugged at some point, so a new drywell was installed about 15-20 feet away and was joined to the old one via an overflow pipe. We kept the same number as their counterpart drywell, but labeled them as A/B (i.e. DW-2A and DW-2B).
· All 24 sediment samples were analyzed for TCLP RCRA 8 metals, and those 9 drywells where petroleum impacts were observed in the field (DW-9, DW-11A/B, DW-12A/B, DW-13, DW-14, DW-15, and DW-20) were also analyzed for NWTPH-Dx. As you can see in the table, all the Dx results exceed the Diesel RBC for residential leaching to groundwater (9,500 ppm), and in many of those same drywells, the 20x conversion factor for cadmium exceeds its default background level (0.63 ppm). These impacted drywells are mostly located in the southwestern portion of the site that has been used for bus parking all these years.
· Based on these results we are proposing the following: In the 9 drywells where sediment samples exceed applicable RBCs, after sediment removal and cleaning is completed, we will collect another set of samples from the native soils beneath each of these drywells and analyze for total RCRA metals and Dx. This would be indicative of any potential worst case in-place concentrations. Using this data we can then determine is further evaluation is still warranted. Please let us know if DEQ agrees with this approach.
· Decommissioning activities are slated to begin next week, but will only include the 7 UICs located in the NW portion of the site (DW-2A/B, DW-3, DW-4, DW-5, DW-8, and DW-18), where impacts were not detected. The other drywells will be decommissioned in step with the phased construction schedule.
I have also included Mike Greenburg on this email, as he is our PM for the Powell Garage ECSI site (#6113), and we want to ensure that all activities we conduct during the redevelopment meet the Cleanup Program requirements as well, given that obtaining an NFA for the site is a primary objective here.
Please let us know your thoughts.
Thanks,
Mike Krzeminski
Manager, Environmental Services at TriMet
4012 SE 17th Avenue, Portland, OR 97202
Office: 503-962-2472
Cell: 971-284-4204
From: RICHERSON Phil <Phil.Richerson@state.or.us>
Sent: Tuesday, August 28, 2018 11:24 AM
To: Krzeminski, Michael <KrzeminM@TriMet.org>; 'RICHERSON Phil' <Phil.Richerson@state.or.us>
Cc: 'Rick Wadsworth' <RWadsworth@parametrix.com>
Subject: RE: TriMet WPCF Permit #103083 - Drywell Closure Notification Reminder
Hello Mike and Rick,
If you are testing the sediment for petroleum hydrocarbons, it would be appropriate to compare the results to DEQ’s Risk-Based Concentrations for residential soil leaching to groundwater for Diesel Range Organics (9500 mg/Kg) and Gasoline Range Organics (31 mg/Kg).
If TPH concentrations exceed those RBCs, please let me know because additional investigative work would probably be warranted.
If metals concentrations in the sediment exceed Portland Basin background metals in soil (available here: https://www.oregon.gov/deq/FilterDocs/cu-bkgrmetals.pdf ), please let me know because additional investigative work might be appropriate.
If the TPH RBCs are not exceeded, the metals concentrations do not exceed background levels, and there are no other indications of potential contamination, then no additional work would be required.
I hope that helps. Let me know if you need further clarification.
Thanks,
Phil
From: Krzeminski, Michael <KrzeminM@TriMet.org>
Sent: Tuesday, August 28, 2018 9:49 AM
To: 'RICHERSON Phil' <Phil.Richerson@state.or.us>
Cc: 'Rick Wadsworth' <RWadsworth@parametrix.com>
Subject: RE: TriMet WPCF Permit #103083 - Drywell Closure Notification Reminder
Thanks Phil,
To me the term chemical spill is a bit vague.
The site has been a bus yard since the late 1960s, well before the term BMP even existed. I have opened most of those drywells, and many have obvious petroleum odors and light sheens inside them. I believe in these instances, Parametrix will also be analyzing for petroleum hydrocarbons as well. Is that correct Rick?
I agree if there is floating product, or TCLP metals indicated that sediments were hazardous waste, that would warrant us involving DEQ, but are you OK not having further follow-up for low-level petroleum impacts?
Thanks for helping to clarify.
Mike
From: RICHERSON Phil <Phil.Richerson@state.or.us>
Sent: Tuesday, August 28, 2018 9:40 AM
To: Krzeminski, Michael <KrzeminM@TriMet.org>
Subject: RE: TriMet WPCF Permit #103083 - Drywell Closure Notification Reminder
Hello Mike,
Thank you for the update. If the sediment in the drywells to be decommissioned is being sampled only for the RCRA-8 metals by TCLP to determine if it needs to be managed as a hazardous waste, I don’t really need to be involved in that determination. However, if you find evidence of a chemical spill during the closure, please pull me into the conversation at that point to help determine appropriate sampling requirements.
Thanks,
Phil
~~~~~~~~~~~~~~~~~~~~~~~~
Phil Richerson
UIC Senior Hydrogeologist
Oregon Dpt Environmental Quality
800 SE Emigrant, #330
Pendleton, OR 97801
541.278.4604
From: Krzeminski, Michael <KrzeminM@TriMet.org>
Sent: Tuesday, August 28, 2018 9:26 AM
To: 'RICHERSON Phil' <Phil.Richerson@state.or.us>
Cc: 'Rick Wadsworth' <RWadsworth@parametrix.com>
Subject: TriMet WPCF Permit #103083 - Drywell Closure Notification Reminder
Hey Phil,
As noted in our 2017-2018 Annual Underground Injection Control (UIC) System Report, we will be decommissioning all 20 of the existing UIC systems at our Powell Garage Operations Facility (9800 SE Powell Boulevard, Portland, Oregon). Pertinent details (as excerpted from the annual report) are outlined below:
Existing Drywell Decommissioning
Facility: Powell Garage Operations Facility
TriMet UIC numbers: DW-1 through DW-20
DEQ UIC numbers: 10176-47 to -54, 10176-55 to -64, and 10176-280 to -282
Details: The Powell Garage property will be completely redeveloped with a new maintenance facility. The construction activities will be completed in several phases, and are slated to begin in August 2018 and continue through the Fall of 2020. All 20 of the existing UICs will be decommissioned during the course of the project, but will be done so in phases along with the construction schedule. All decommissioning work will be done in accordance with our UIC System Management Plan. The work will be overseen by Parametrix, who will prepare a UIC Decommissioning report upon completion of the project.
New Drywell Installation
TriMet UIC numbers: DW-1 through DW-17.
DEQ UIC numbers: DEQ has not yet assigned numbers to these planned UICs.
A total of 17 new UICs will be installed in phases during the Powell Garage redevelopment project.
The first few drywells will be decommissioned starting in September 2018, in step with the planned earthwork activities at the site, and it is anticipated that the earthwork will be completed in phases through December 2019, so all drywells should be decommissioned by that time.
Right now Parametrix is sampling sediment from all of the drywells to be decommissioned. Would you like to review the sampling data before we proceed with decommissioning? If any additional investigation or cleanup may be warranted by DEQ, we want to take care of that ahead of the construction activities.
Thanks,
Mike Krzeminski
Manager, Environmental Services at TriMet
4012 SE 17th Avenue, Portland, OR 97202
Office: 503-962-2472
Cell: 971-284-4204