From: BAYUK Dana
Sent: Thu Mar 10 17:20:18 2016
To: 'John Renda'; Rob Ede
Cc: Ben Hung; LARSEN Henning; POULSEN Mike
Subject: RE: Updated "3Q14" GW Monitoring Program - w TPH added (March 2016 mods.)
Importance: Normal
Attachments: RE: Gasco: Groundwater Quality Monitoring Data Report and Aqua Gard Memo; COMPREHENSIVE GW FRAMEWORK_NW Natural_01_14_16.xlsx; Good afternoon. I’ve reviewed the e-mail John sent yesterday, and concur with his summary of our recent discussions about modifying NW Natural’s groundwater monitoring program. Consequently, DEQ approves modifying the frequency of groundwater sampling from semi-annual to annual, and the removal of VPH/EPH from the list of sampling parameters for the monitoring wells specified in his e-mail. In addition, I’ve reviewed the data from monitoring wells MW-10-25 and MW-11-32 and approve discontinuing TPH sampling at these two installations. Given TPH is the only parameter being analyzed for, DEQ acknowledges MW-10-25 and MW-11-32 will be removed from the groundwater monitoring program. DEQ understands and acknowledges that the approved program modifications will be implemented by NW Natural during the semi-annual groundwater monitoring event scheduled for this month. DEQ’s approval to change the monitoring frequency for certain monitoring wells completes our review of the recommendations made by NW Natural in the “Groundwater Quality Monitoring Data Report, NW Natural Gasco Site,” dated July 17, 2015 (Monitoring Report). To facilitate the field schedule for the September 2015 monitoring event, DEQ provided an initial set of comments via a September 17, 2015 e-mail and attachment. For your information and reference, the September 17th e-mail is attached so monitoring program modifications related to DEQ’s review of the Monitoring Report are captured in a single document. DEQ’s approvals to discontinue sampling and analysis of VPH/EPH at certain installations, and the removal of MW-10-25 and MW-11-32 from the monitoring program responds to NW Natural’s proposals made during a conference call on February 19, 2016. DEQ requests that NW Natural’s portion of the draft “Comprehensive Monitoring Framework” table (attached) be revised consistent with this e-mail to document the modifications made to the groundwater monitoring program. The revised table should be submitted for DEQ review within 14-days of the date of this e-mail. Hope your days have gone well and feel free call me with questions about this e-mail or the attachments. Dana Mr. Dana Bayuk Cleanup Program Project Manager/Hydrogeologist Oregon Department of Environmental Quality Northwest Region 700 NE Multnomah Street, Suite 600 Portland, OR 97232-4100 E-mail: bayuk.dana@deq.state.or.us Phone: 503-229-5543 FAX: 503-229-6945 Please visit our website at http://www.oregon.gov/DEQ/ P please consider the environment before printing this email From: John Renda [mailto:jrenda@anchorqea.com] Sent: Wednesday, March 09, 2016 5:15 PM To: BAYUK Dana; Rob Ede Cc: HAFLEY Dan; Ben Hung Subject: RE: Updated "3Q14" GW Monitoring Program - w TPH added Dana – I understand from our phone conversation this afternoon that you are requesting that VPH/EPH be analyzed for MW-39F, MW-40F, MW-42F, and WS-47-183. Please note that while VPH/EPH analysis was already planned for MW-39F and MW-40F (as shown in the email chain below), VPH/EPH analysis was not planned MW-42F or WS-47-183. These wells will be analyzed for VPH/EPH this round (March 2016). There is one more outstanding item that is awaiting your feedback. On a call on 2/19/16, we requested that monitoring wells MW-10-25 and MW-11-32 (DNAPL wells that are only analyzed for TPH-Dx and –Gx) be dropped from the monitoring program. You said that you would review the data, but we are still awaiting feedback. Over the last couple weeks, we have had several phone calls and email exchanges, so I wanted to make sure I capture all the agreements. Below is a summary of my understanding. The attached email “re:VPH/EPH evaluation” documents removal of VPH/EPH testing from the following wells: MW-1-82 MW-2-61 MW-18-180 MW-19-180 MW-23-123 NWN-03-17 NWN-05-20 NWN-10-26 WS-8-59 MW-1-55 MW-2-104 MW-5-175 MW-22U MW-23U MW-41U NWN-08-30 WS-12-161 On a 2/19/16 Conference call, you approved the following list of wells to be moved from semi-annual to annual: MW-7-60 MW-8-29 MW-9-29 MW-10-61 MW-12-36 MW-14-110 MW-15-50 MW-15-66 NWN-1-20 WS-13-69 WS-13-105 WS-17-52 WS-17-94 And additionally drop the following two wells from the NW Natural monitoring program since Siltronic had picked up sampling. WS-21-112 WS-26-86 Please confirm that this is consistent with your understanding. John J. Renda, RG ANCHOR QEA, LLC 6650 SW Redwood Lane, Suite 333 Portland, OR 97224 Main 503.670.1108 x171 Direct 503.924.6171 Fax 503.670.1128 ANCHOR QEA, LLC Please consider the environment before printing this email. This electronic message transmission contains information that may be confidential and/or privileged work product prepared in anticipation of litigation. The information is intended for the use of the individual or entity named above. If you are not the intended recipient, please be aware that any disclosure, copying distribution or use of the contents of this information is prohibited. If you have received this electronic transmission in error, please notify us by telephone at (503) 670-1108. From: BAYUK Dana [mailto:BAYUK.Dana@deq.state.or.us] Sent: Tuesday, October 21, 2014 1:48 PM To: Rob Ede <robe@hahnenv.com> Cc: Bob Wyatt <rjw@nwnatural.com>; Patty Dost <pdost@pearllegalgroup.com>; Ben Hung <bhung@anchorqea.com>; Taku Fuji <tfuji@anchorqea.com>; John Edwards <jedwards@anchorqea.com>; John Renda <jrenda@anchorqea.com>; Carl Stivers <cstivers@anchorqea.com>; Sarah Riddle <sriddle@pearllegalgroup.com>; Sean Sheldrake <sheldrake.sean@epa.gov>; Lance Peterson (petersonle@cdmsmith.com) (petersonle@cdmsmith.com) <petersonle@cdmsmith.com>; Scott Coffey <coffeyse@cdmsmith.com> (coffeyse@cdmsmith.com) <coffeyse@cdmsmith.com>; JOHNSON Keith <JOHNSON.Keith@deq.state.or.us>; GAINER Tom <GAINER.Tom@deq.state.or.us>; LARSEN Henning <LARSEN.Henning@deq.state.or.us> Subject: RE: Updated "3Q14" GW Monitoring Program - w TPH added Good afternoon Rob. As you know, DEQ reviewed the revised table attached to your September 29, 2014 e-mail. The revised table incorporates total petroleum hydrocarbons (TPH) and TPH-fractions into the “integrated groundwater monitoring program” (integrated monitoring program) for the Gasco and Siltronic sites. The table was revised based on DEQ’s review of NW Natural’s September 5th version of the table and the telephone discussions you and I had on September 24, 2014. Based on our review of the table, DEQ: · Acknowledges that TPH and TPH-fractions have been incorporated into the integrated monitoring program consistent with our telephone discussions on September 24, 2014; and · DEQ approves the integrated monitoring program as revised. During a telephone call with you on September 29th, I provided NW Natural with verbal approval to conduct the third quarter 2014 event as revised. This e-mail provides written approval. DEQ understands that based on our verbal approval, NW Natural initiated sampling activities on October 1st and is committed to completing the work before the end of the month. DEQ also has the following comments on your September 29th e-mail that are intended to avoid potential future misunderstandings: · DEQ acknowledges that our telephone discussions regarding incorporating TPH and TPH-fractions into the integrated monitoring program for the third quarter 2014 event provided notification of the field work to be conducted. · Your e-mail indicates the third quarter event (September 2014) was delayed while final discussions occurred regarding incorporating TPH and TPH-fractions into the integrated monitoring program. DEQ notes that NW Natural did not conduct the June 2014 event for the same reason and to complete the Phase 1 – Step 5 test of the Alluvium water-bearing zone hydraulic control and containment system. · DEQ understands from your e-mail that NW Natural will review the third quarter sampling results and make recommendations for future events. The third quarter 2014 sampling event will be the first to include TPH and TPH-fractions. During the September 24th call, I informed you that given NW Natural has not previously analyzed groundwater for TPH and/or TPH factions, DEQ considers it premature to place restrictions on data collection and use after a single sampling event. This is consistent with our May 8, 2014 letter commenting on the Draft HERA Report. The May 8th letter indicates that DEQ would not delay the Revised HERA Report because of the lack of TPH and TPH-fractions groundwater data, but that these parameters should be added to the integrated monitoring program beginning in June 2014. Consequently, DEQ expects that sampling and analysis of these parameters will continue beyond the third quarter 2014 monitoring event. DEQ appreciates the work done to incorporate TPH and TPH-fractions into the integrated monitoring program. Please feel free to contact me questions regarding this e-mail and hope the rest of your day goes well. Dana Mr. Dana Bayuk, Project Manager NW Region Cleanup & Site Assessment Section Oregon Department of Environmental Quality 2020 SW 4th Avenue, Suite 400 Portland, OR 97201 E-mail: bayuk.dana@deq.state.or.us Phone: 503-229-5543 FAX: 503-229-6899 Please visit our website at http://www.oregon.gov/DEQ/ P please consider the environment before printing this email From: Rob Ede [mailto:robe@hahnenv.com] Sent: Monday, September 29, 2014 12:21 PM To: BAYUK Dana Cc: Bob Wyatt; Patty Dost; Ben Hung; Taku Fuji; John Edwards; John Renda; Carl Stivers; Sarah Riddle Subject: Updated "3Q14" GW Monitoring Program - w TPH added Importance: High Dana, As you requested during our September 24, 2014 telephone conversation I am providing on behalf of NW Natural a revision to the table previously provided to DEQ in e-mail correspondence dated September 5, 2014. The referenced table describes the locations and analyses to be conducted as part of the next groundwater monitoring event completed by NW Natural at the Gasco and Siltronic properties. As you are aware, this event was previously approved for implementation but was delayed due to discussions necessary subsequent to DEQ's request/requirement for collection of total petroleum hydrocarbon (TPH) data during this event, including gasoline-range (NW-TPH Gx); diesel- and oil-ranges (NW-TPH-Dx); and TPH fractions (WDOE VPH and EPH Methods). Based on our discussion yesterday, NW Natural has revised the previously provided table to include the following locations/analyses described by DEQ as being necessary for adequate spatial coverage. I. Incorporated NW-TPH-Dx; NW-TPH-Gx; WDOE EPH and WDOE VPH analyses to the following Gasco shoreline wells already scheduled for sampling during the next event:
II. Incorporated the following Gasco upland wells for sampling and NW-TPH-Dx and NW-TPH-Gx analyses (only) - no other analytes on the standard parameter list are proposed.
III. Incorporated NW-TPH-Dx, NW-TPH-Gx; WDOE-EPH and WDOE-VPH analyses to the following Siltronic shoreline wells:
Additionally, it is understood that once installed, new wells MW-39F, MW-40F, and MW-41F are to be sampled/analyzed for NW-TPH-Dx, NW-TPH-Gx; WDOE-EPH and WDOE-VPH; analyses that have already been incorporated into the Fill WBZ Trench SAP/QAPP, where installation and sampling of these wells is described.
Based on our discussion yesterday, NW Natural withdraws our September 5, 2014 statement that the TPH fractionization testing will be a one-time only occurrence. Instead, NW Natural will evaluate the usability of the TPH fraction data for risk assessment purposes after the data from this event are available, with recommendations for inclusion in a subsequent event to be made at that time. Further, and in light of the known limitations with regard to laboratory detection limits relating to the WDOE EPH and VPH Methods, NW Natural will evaluate the data once available and will make a determination as to how any such data will best be compared to screening levels presented by DEQ.
NW Natural plans to mobilize for the next sampling event as soon as possible after DEQ concurrence is received. Coordination with a pending "Phase 1 Step 6" test of the groundwater extraction system will be necessary so that the two activities do not interfere. As such, and depending on schedule, the groundwater monitoring event may be initiated prior to the Phase 1 Step 6 testing, but may need to be paused for the duration of the Phase 1 testing, to be completed as soon as possible after conclusion of the Phase 1 Step 6 testing.
We look forward to your written approval of the proposal for inclusion of TPH testing in the pending groundwater monitoring event, dated September 5, 2014, as amended by this response and the attached table.
Regards,
-Rob
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Rob Ede, R.G. * robe@hahnenv.com
Hahn and Associates, Inc.
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