From: KENT Mavis D
Sent: Thu Sep 24 16:32:53 2009
To: 'Sarah Prowell'
Subject: 2009 Semiannual Report
Importance: Normal
Sarah, I have reviewed the 2009 Mid-Year Semiannual Performance Report and Pre-Closure Plan, dated September 7, 2009. The following are my comments.
1. Check some typos: Section 2.4 “Discharge”, Section 4.1 ROAs instead of RAOs, Section 4.2 second paragraph fifth line and instead of are, Section 5.3 first paragraph first and third lines both should be RW-1(?), Table 1-1 first line “December”, Figure 3-1 should have TGA after “Upper” and “Lower” and concentration for lower should be ug/l instead of ug/g. These are just what jumped out at me.
2. Section 4.2. In the first paragraph, I think “Final treatment” should be accelerated treatment because there will be additional treatment after bio-polishing that will be the passive wall at a minimum. As is, it sounds like all will be shut down with bio-polishing which I don’t think you mean. Also, could there be a statement that the accelerated treatment that consists of bio-polishing will work in concert with existing and ongoing treatment to reach the cleanup goals? In the second paragraph, add accelerated before treatment in the first line. If you don’t like accelerated then another descriptor is fine with me, just not final.
3. Section 4.3. In the first sentence, add “decision” before criteria are proposed.
4. Section 4.5. The schedule looks fine in terms of items but I am wondering why you have a whole year to do RAO conformance evaluation? Are you looking at the 3-year criteria after bio-polishing as the key to timing? If so, then that is ¾ of a year to do the conformance evaluation. Wouldn’t you be able to submit a request for termination of the order and certificate of completion at the end of 2013? If you feel comfortable with some leeway, I have no problem with the schedule and of course you can always take these steps earlier in keeping with the decommissioning criteria.
5. Section 5.1. I agree with the declaration that wells EX-2 through EX-6 and EX-39s meet the decommissioning criteria and can be scheduled for decommissioning.
6. Section 5.2. I agree with the declaration that wells EX-8, EX-11, and EX-12 meet the decommissioning criteria and can be scheduled for decommissioning. Also, I agree with the conclusion that well EX-7 does NOT meet the decommissioning criteria and that it will be retained for bio-polishing treatment.
7. Section 5.3. I agree the declaration that wells RW-1, EX-9, MW-30i, RW-3, MW-4a, MW-4b and MP-1 meet the decommissioning criteria and that they will be scheduled for decommissioning.
8. Section 5.5. I agree with that Shepard Spring surface water is demonstrated to be below cleanup criteria and has been to meet the “decommissioning” criteria and also meet the NPDES effluent concentrations for the Cascade permit as well as the concentrations that were evaluated for the North Cascade Property PPA where discharge of similar surface water was allowed to storm water channels. I request that you notify the City of Gresham that this water has met similar criteria to the Cascade North Property as well as the Cascade site NPDES effluent discharge limits and that you will be tying into your NPDES discharge line. Not sure if this would be an issue but it would be good to keep them informed.
Those are all the comments I have. I will be available to discuss this afternoon until about 5 pm. I will not be in the office Friday but will be back Monday morning.