From: KENT Mavis D
Sent: Wed Mar 11 12:16:51 2009
To: 'Sarah Prowell'
Subject: RE: Streamlined TSA Reporting?b Importance: Normal
I would favor your option two below because although everything is on track more or less, we are becoming more active in making little changes so semi-annual would keep the site more updated overall. It sounds like each 1st and 3rd report would be semi-annual reports and also address the basic performance measures and include a historical data CD with the 1st semi-annual report. I would also like to have a running list of the interim approvals for modifications included in the semi-annual reports, as you have been including in the annual report.
If there seems to be something lacking as we go on, then we could discuss and make any necessary modifications.
So, let’s change the reporting from quarterly/annual/5 year, to quarterly/semi-annual/five year. I will print this email out and place it in the file as documentation of approval to modify the reporting procedure for the EMC project.
From: Sarah Prowell [mailto:sprowell@ix.netcom.com]
Sent: Wednesday, March 11, 2009 11:25 AM
To: KENT Mavis D
Subject: RE: Streamlined TSA Reporting?
Mavis,
The streamlining would include elimination of duplicate reporting (of what is no both quarterly and annual reporting). FYI, the parties spent >$90,000 jointly preparing last year’s annual report, through June 08 (excluding all subsequent/additional Upper TSA evaluation/memo costs). So the duplication of reporting is a very real cost burden.
(Since DEQ doesn’t have the opportunity to track remedy costs,…fyi, the parties spent about one million dollars last year,..mainly (about 70%) for upper TSA-related issued. So costs can escalate. I’m just looking for efficiencies.) Thanks.
From: KENT Mavis D [mailto:KENT.Mavis@deq.state.or.us]
Sent: Wednesday, March 11, 2009 11:08 AM
To: Sarah Prowell
Subject: RE: Streamlined TSA Reporting?
What do you see as eliminated in this streamlined approach?
From: Sarah Prowell [mailto:sprowell@ix.netcom.com]
Sent: Wednesday, March 11, 2009 11:03 AM
To: KENT Mavis D
Subject: RE: Streamlined TSA Reporting?
In concept, I would suggest the semiannual reports include a modified text format, blending quarterly and annual report topics for a streamlined but still adequate discussion of all the key performance elements. It would continue to report actions completed and planned, treatment and extraction performance, groundwater elevations and capture, and TCE concentrations and remediation progress. Recommendations would continue to be presented, along with what has been Annual Report Appendix A remedy criteria, monitoring schedule, and PWB monitoring schedule.
The semiannual reports would include many of the annual report figures and tables, but with semiannual data only. The historical VOC CD would be attached once a year, to the 1Q08 reports (through March 31).
The semiannual figures could include the following prior annual report figures (in 8 ½” x 11” format for easy pdf and printing):
Site Location and Lower TSA Remedy Zone delineation maps
Well location map(s)
Treatment System layout map
Groundwater elevation contours
TCE contours
Precip plot
Data logger hydrograph plots
Selected TCE plots, as/when appropriate
The semiannual report tables would include the key performance data (extraction rate, effluent compliance, water quality, water level, mass removal)
So the examples would be a blending of the prior quarterlies and the annual.
Sarah Prowell, R.G.
Prowell Environmental, Inc.
2216 SW Sunset Blvd.
Portland, Oregon 97239
Phone: 503/452-0972
Fax: 503/452-1427
sprowell@ix.netcom.com
From: KENT Mavis D [mailto:KENT.Mavis@deq.state.or.us]
Sent: Wednesday, March 11, 2009 10:16 AM
To: Sarah Prowell
Subject: RE: Streamlined TSA Reporting?
If you just tell me what one is a good example I can get it from the file.
From: Sarah Prowell [mailto:sprowell@ix.netcom.com]
Sent: Wednesday, March 11, 2009 9:55 AM
To: KENT Mavis D
Subject: RE: Streamlined TSA Reporting?
Thank you, Mavis. I’ll get that example to you later today.
From: KENT Mavis D [mailto:KENT.Mavis@deq.state.or.us]
Sent: Wednesday, March 11, 2009 9:55 AM
To: Sarah Prowell
Subject: RE: Streamlined TSA Reporting?
Give me an example of your option 2 below and I will compare the annual report with option 2. Then perhaps we could discuss. I am open to reducing the amount of paper and redundancy.
From: Sarah Prowell [mailto:sprowell@ix.netcom.com]
Sent: Wednesday, March 11, 2009 9:11 AM
To: KENT Mavis D
Subject: Streamlined TSA Reporting?
Hello Mavis,
I wanted to run a TSA Remedy proposal by you, to see if it would work for DEQ.
Since annual reports have been submitted for the last 10 years (for reporting periods ending March 31 1998 through March 31, 2008), with two of those being comprehensive Five Year Reports (2003 and 2008),…and since all areas (except maybe the western Upper TSA) are largely on track,… I’d like to propose streamlining the reporting process by eliminating annual reports, beginning this year. Information would continue to be reported quarterly by each party and also in a comprehensive Five Year Remedy Review Report (next one due 2013).
Option One:
This approach would include 3 quarterly data report submittals (2nd, 3rd, and 4th calendar quarters). They would look much like they have in the past,…with mainly just quarterly tabled data. The 1st data report would additionally include a summary of the year’s data and would be the equivalent of a streamlined annual report.
Option Two:
Reports for 2nd and 4th quarters would include quarterly updates, much like prior quarterly reports.
Reports for 1st and 3rd quarters would include semiannual updates, with additional selected figure/table/text elements (from the previous annual reports). With this approach, there would not be an annual update, but rather, two semiannual updates (similar to the Cascade TGA).
Could you let me know what you think about a streamlined reporting change for the remedy? Thank you. Sarah
Sarah Prowell, R.G.
Prowell Environmental, Inc.
2216 SW Sunset Blvd.
Portland, OR 97239
Phone: 503/452-0972
Fax: 503/452-1427
Email: sprowell@ix.netcom.com