From: KENT Mavis D

Sent: Thu Dec 10 16:18:48 2009

To: 'Chaput, Kenneth G'; Chris Kimmel

Subject: Boeing TGA Aquifer Remedy Completion Strategy

Importance: Normal

I have reviewed the TGA Aquifer Remedy Completion Strategy Plan, dated December 8, 2009. In general the document accurately reflects the conversations we had regarding identifying steps and timeline to reach completion of the Boeing TGA cleanup. This document proposes a scope for a remedy completion plan.

I have a couple of comments that can be addressed in the remedy completion plan. First, the overall purposes for preparing a plan would be to identify any additional measures that can be taken to accelerate cleanup above and beyond the specific remedial elements laid out in the site ROD, identify a projected timeframe to reach the site cleanup goals based upon the additional measures that would be proposed as well as the progress in ROD-specified cleanup measures, and to begin outreach to stakeholders so they are aware that Boeing is reaching a completion point in this long cleanup process.

Second, the project summary and agency-approved remedial measures needs to give a good summary of the progress made in cleanup according to the remedial elements in the ROD. There should be a statement indicating when the expected cleanup timeframe would be, in the absence of any other additional measures. This gets to the point of this strategy, to outline additional measures that can be taken to accelerate cleanup. For the DEQ memo that would be posted on the web page, I would like to present all of the cleanup work that has been done, before and under the order.

Third, for the persistent impacted areas and proposed remedy measures, it would be more consistent with language in the order and the purpose of the strategy to indicate “proposed additional measures”. It would be anticipated that taking additional measures would shorten up the total originally predicted cleanup time. Otherwise, proposed remedy measures may come to close to changing the remedy which could involve another bureaucratic step to explain significant differences with the ROD. It will also be good to point out that some of your additional measures would be considered green remediation, or measures that are less resource (electricity, for example) intensive than pump and treat.

Fourth, for the schedule, I wouldn’t expect you to target month and day but generally the year, like first half of whenever.

Fifth, for the outreach, it is not clear if you will develop the outreach plan or not. If you wish to, that will be fine with me. I am not sure the best timing for an initial fact sheet would be, but it might be after you get a sense of the significance of the degreaser location and any other persistent areas that need to be addressed. Mid-spring might be good, but at least a time when you can better forecast a timeframe for reaching cleanup goals.

Those are my thoughts on the strategy. I will be out of the office tomorrow, but back in on Monday. Submittal of this plan by early February is acceptable.