From: BAYUK Dana
Sent: Tue Oct 21 13:47:44 2014
To: 'Rob Ede'
Cc: Bob Wyatt; Patty Dost; Ben Hung; Taku Fuji; John Edwards; John Renda; Carl Stivers; Sarah Riddle; Sean Sheldrake; Lance Peterson (petersonle@cdmsmith.com) (petersonle@cdmsmith.com); Scott Coffey (coffeyse@cdmsmith.com); JOHNSON Keith; GAINER Tom; LARSEN Henning
Subject: RE: Updated "3Q14" GW Monitoring Program - w TPH added (Oct. 2014 mods.)
Importance: Normal
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.
Environmental Consultants
434 NW 6th Avenue, Suite 203
Portland, Oregon 97209-3651
Phone: 503.796.0717 * Facsimile: 503.227.2209