FW Highlighted Recommendations for Review

From: KENT Mavis D

Sent: Thu Aug 30 17:07:32 2007

To: 'Sarah Prowell'

Subject: FW: Highlighted Recommendations for Review - 07 TSA Ann Rpt

Importance: Normal

Here are other items we discussed:

* Section 5.5.2, RPW-1(ds) is recommended to eliminate water quality sampling as it has been non detect since 1998 and other nearby wells provide necessary data, DEQ approves this recommendation

That is all I have with regard to recommendations and your identified text items.

I had a couple of items for Figures.

On Figure 2-4, should EW-10 be listed in the legend? If not then no change is necessary.

On Figure 4-4b, there is now an area of elevated concentration near the replacement wells MW-14R(ds,dg), and nearby extraction well EW-5 has occasional concentrations above 5 ug/l. We have discussed this previously, but this area may need some re-evaluation as to whether the plume margin is accurately depicted.

That is all I have for comments on the annual plan. We can talk further when I am in the office on Sept 4th, or after I return on Sept 11th.

Mavis D. Kent

Cleanup & Emergency Response Section

DEQ Northwest Region - East Side Office

1550 NW Eastman Parkway, Suite 290

Gresham, Oregon 97030

503-667-8414 X55008

503-674-5148 Fax

kent.mavis.d@deq.state.or.us

-----Original Message-----

From: Sarah Prowell [mailto:sprowell@ix.netcom.com]

Sent: Wednesday, August 01, 2007 12:37 PM

To: KENT Mavis D

Cc: Chris Kimmel

Subject: FW: Highlighted Recommendations for Review - 07 TSA Ann Rpt

Hello Mavis,

We’ll perform TSA annual monitoring this month and wanted to make sure we’re aligned with your approvals. Could you let us know if you approve the annual report recommendations (w/bulleted summary below) sometime in the near future? To keep things moving, we’ll go ahead and proceed in accordance with the monitoring recommendations in the interim, if that’s okay with you.

(The one “non-monitoring” recommendation is to pilot shutdown EW-8. We’ll wait for your reply before taking any action on that front.)

Also, FYI, the BOP-44(ds,dg,usg) well head modifications are in progress. The vertical “stick-up” extensions (about 14 feet) were constructed by Cascade Drilling last Saturday (July 28) under Gresham and Prowell oversight. Gresham’s construction contractors will proceed with fill and compaction during the next month or so. Then the drillers will return in September to construct the final well head completions. Given the 14 foot height and construction activities, it is not likely that we will have access to these wells for monitoring use until September,…at which time we’ll complete the “August” water level and quality monitoring.

Just let us know if you have any questions about the annual report recommendations or our plans to proceed in the interim.

Thanks very much. -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

From: Sarah Prowell [mailto:sprowell@ix.netcom.com]

Sent: Wednesday, July 11, 2007 2:30 PM

To: Mavis Kent (KENT.Mavis.D@deq.state.or.us)

Subject: Highlighted Recommendations for Review - 07 TSA Ann Rpt

Mavis,

The attached pdf file includes Section 5 (Recommendations) of the TSA annual report, with yellow highlights for text that proposes new actions for DEQ’s review, and if acceptable, approval. In summary, the new requests relate to:

· EW-8 pilot shutdown DEQ approved on 8/13/07

· Discontinuing all monitoring in eastern Upper TSA wells DEQ-1(ds), MW-29(ds), MW-41(ds), PMX-189/EW-10, and PWB-4(s) Approved

· Discontinuing all monitoring in SGA well PMX-202 Approved, duplicative of EMC-2(usg), main concern during PWB pumping, otherwise, upwards SGA gradient has been re established for baseline conditions protection of SGA

· Reducing water level monitoring from quarterly to semiannual for all monitoring and pilot shutdown wells. Approved based on 10 years of quarterly monitoring data that shows Aug (summer) and Feb (winter) contours are representative of all seasonal conditions, PWB contingency plan calls for water level monitoring in all wells if pumping extends 90 days or more providing a potential mid summer/winter data set

· Discontinuing data logger monitoring in 7 wells and continuing data logger monitoring in the 18 wells listed in the TSA remedy 2007 contingency monitoring program for PWB pumping events (see Appendix A). Approved

· Discontinuing all monitoring in the two deeper well screen intervals in BOP-70(ds-245, 275), while continuing to monitor the uppermost Upper TSA in BOP-70(ds-215) and BOP-71(ds). Approved, text indicates depths -245 and -275 will be available for future monitoring needs

· Reducing sampling frequencies in Lower TSA wells MW-8(dg), MW-16(dg)/EW-4, PWB-1(lts), and RPW-2 and CU2 equivalent well BOP-69(usg), per remedy criteria. Approved, concentrations are below 5 ug/l and stable or declining for at least two years

· Using purge sampling methods for future BOP-22(ds) and discontinuing diffusion bag sampling in this well Approved, flow conditions in this area are being evaluated

· Using purge sampling methods for BOP-60(ds) for reporting and contouring but also continuing vertically profiled diff bag sampling for one year to further evaluation VOC vertical distribution. Approved, the diff bag sampling data for vertical profile characterization is viewed as useful to the evaluation of flow conditions in this area

Also, the attached file shows minor text edits in two locations:

· One in the second paragraph of Section 5.2.1.1, deleting the erroneous statement that EW-5 has been converted to monitoring use (since this well remains in pilot shutdown mode, per your prior approval). Please make brief revision and provide replacement page

· And the other just to smooth the language, inserting that we are proposing pilot shutdown of EW-8, since the original text didn’t very clearly communicate this. No change needed here