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HomeMy WebLinkAboutAgreements/Contracts - Public WorksGRANT COUNTY COMMISSIONEIFS AGENDA MEETING REQUEST FORM (Must be submitted to the Clerk of the Board by 12:00pm on Thursday) REQUESTING DEPARTMENT: PUBLIC WORKS REQUEST SUBMITTED BY: SHILO NELLIS CONTACT PERSON ATTENDING ROUNDTABLE: SAM GASTRO CONFIDENTIAL INFORMATION: ❑YES ® NO DATE:05/23/2024 PHONE:509-754-6082 TO AGREED ORDER, IN THE MATTER OF REMEDIAL ACTION BY: GRANT COUNTY AND THE CITY OF EPHRATA If necessary, was this document reviewed by accounting? ❑ YES ❑ NO ❑ N/A If necessary, was this document reviewed by legal? ❑ YES ❑ NO ❑ N/A DATE OF ACTION: �- ZS�� DEFERRED OR CONTINUED TO: APPROVE: DENIED ABSTAIN D1: S&:�41 D2: D3: ' 4 fi yp iii' 'y c �) S 4/23/24 BAgreement /Contract DAP Vouchers ❑Appointment /Reappointment DARPA Related El Bids /RFPs /Quotes Award ❑Bid Opening Scheduled El Boards /Committees El Budget ❑Computer Related ❑County Code ❑Emergency Purchase ❑Employee Rel. 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[]Tax Levies ❑Thank You's ❑Tax Title Property ❑ WSLCB 1 im EMOO 11111111 111 W" inau mw 11 j 1 31 --------- STATE OF WASHINGTON DEPARTMENT OF ECOLOGY AMENDMENT NO 3 TO AGREED ORDER, IN THE MATTER OF REMEDIAL ACTION BY: GRANT COUNTY AND THE CITY OF EPHRATA If necessary, was this document reviewed by accounting? ❑ YES ❑ NO ❑ N/A If necessary, was this document reviewed by legal? ❑ YES ❑ NO ❑ N/A DATE OF ACTION: �- ZS�� DEFERRED OR CONTINUED TO: APPROVE: DENIED ABSTAIN D1: S&:�41 D2: D3: ' 4 fi yp iii' 'y c �) S 4/23/24 STATE OF WASHINGTON DEPARTMENT OF ECOLOGY In the Matter of Remedial Action by: Grant County & The City of Ephrata TO: Grant County PO Box 37 Ephrata, WA 98823 AMENDMENT NO. 3 TO AGREED ORDER No. DE 3810 I. AMENDMENT Agreed Order (Order) No. DE 3810 dated January 30, 2007, as amended on November 26, 2012 and January 19, 2016, is hereby amended to incorporate the information and requirements contained in this Amendment. This Amendment is issued pursuant to the Model Toxics Control Act (MTCA), RCW 70A.305.050 (1) and, except as indicated below, does not replace or change any of the existing requirements of the Order, which shall remain in effect. This amendment only applies to the County. The City has not agreed to comply with the requirements for remedial actions within this amendment to the Order. However, the City remains a PLP and is a signatory to the Order and the first two amendments. V. FINDINGS OF FACT Section V (Findings of Fact) is amended by adding the following facts: (12) Amended Agreed Order No. DE 3810 entered into by Ecology, Grant County, and the City of Ephrata on January 19, 2016, required the potentially liable persons (PLDs), Grant County and the City of Ephrata, to complete an interim remedial action at the Site, which included a pilot study of multiphase extraction (MPE) in the P I zone, which was saturated and was first dewatered; a pretreatment facility and evaporation pond to manage the discharges associated with Amendment No. 3 to Agreed Order No. DE 3810 Page 2 of 5 dewatering and NIPE; and installation of new groundwater monitoring wells along the parcel boundary north of the original landfill. The findings from the interim remedial action completed in 2017 were detailed in the report: Parametrix, 2018 (February), Multi -Phase Extraction Pilot Test, Interim Remedial Action, Ephrata Landfill. (13) The Remedial Investigation was supplemented with installation of additional monitoring wells between 2019 and 2021 to further characterize the hydraulic properties and contaminant distribution in the P1, P2, and Roza water -bearing units. Seventy-six (76) new monitoring wells were installed. Additional hydraulic slug testing and groundwater monitoring was performed to inform the Site conceptual model. The monitoring well network now includes 143 wells. The data from the supplemental investigation is detailed in the report: Pacific Groundwater Group, 2022, Results of Phase I North End Supplemental Investigation, Ephrata Landfill REFS. (15) Evaluation of cleanup technologies in the updated Feasibility Study prepared for the Site identified multiphase extraction (MI'E) in the PI and P2 water -bearing zones at the location where the 2,350 drums were formerly buried on the Site. The evaluation of cleanup alternatives was updated to reflect the additional Remedial Investigation data and presented in the report: Parametrix Inc., 2022, Ephrata Landfill Remedial Investigation and Feasibility Study Completion, October 31, 2022. VI. ECOLOGY DETERMINATIONS Section VI (Ecology Determinations) is amended by adding the following: 17. Ecology has determined that the pilot test of the MPE system in the PI water - bearing zone was successful at removing contaminant mass in groundwater and vapor in the vicinity of the drum source area. However, Ecology has not been able to determine whether Amendment No. 3 to Agreed Order No. DE 3810 Page 3 of 5 expansion of the MPE system into the P2 water -bearing zone would be effective as an aspect of the final remedy, because MPE pilot testing was previously completed only within the P I water - bearing zone. 18. Based on results of the MPE interim action and supplemental groundwater investigation as specified above, Ecology is requiring Grant County to perform the interim actions described in the Scope of Work and the Schedule of Deliverables and Actions, attached as Exhibits A and B. 19. Based on all information known to Ecology, Ecology has determined that the interim actions required herein are necessary to reduce a threat to human health or the environment by substantially reducing one or more pathways for exposure; to correct a problem that may become substantially worse or cost substantially more to address if the remedial action is delayed; or are needed to provide for completion of the remedial investigation/feasibility study or design of the cleanup action in accordance with the Washington Administrative Code (WAC) Chapter 173- 340-430(1). Performing the interim action will result in a partial cleanup of the Site and is consistent with WAC 173-340-430. 20. Ecology believes that the additional work to be performed as an interim action is in the public interest. V11. WORK TO BE PERFORMED Section VII (Work to Be Performed) is amended by adding the following actions: E. Grant County shall furnish all personnel, materials, and services necessary for, or incidental to, the planning, initiation, completion, and reporting of the interim actions summarized below and further detailed in the Scope of Work (Exhibit A) and Schedule of Deliverables and Actions (Exhibit B). • Prepare and submit for Ecology's review and approval draft and final versions of an Interim Action Work Plan that outlines the planned restart operation of the Amendment No. 3 to Agreed Order No. DE 3810 Page 4 of 5 existing pilot system in the P I water -bearing zone after making necessary repairs and updates, and continue seasonal operation until MPE system expansion begins. • With Ecology approval, implement the final approved Interim Action Work Plan for the existing P I water -bearing zone. • Prepare and submit for Ecology's review and approval draft and final versions of an Interim Action Work Plan that outlines the planned operation of an expanded MPE system in the P 1, P2, and Roza water -bearing zones. • With Ecology approval, implement the final approved Interim Action Work Plan for the expanded MPE system. • Evaluate and identify, as appropriate, groundwater monitoring to evaluate MPE system performance and impacts on groundwater quality in the P 1, P2, and Roza water -bearing zones. • Complete an assessment of natural attenuation of the Site contaminants of concern (CDCs) in groundwater, including geochemical parameters, for evaluation of downgradient biotic and abiotic attenuation of contaminants. Exhibits A and B are incorporated by reference and are an integral and enforceable part of the Order. The work to be performed is to conduct additional interim actions. Grant County shall commence work and thereafter complete all tasks in Exhibit A in the time frames and framework provided in Exhibit B unless Ecology grants an extension in accordance with Section VIILK, or unless provided otherwise in the Order. Each Element of Exhibit A shall be implemented and completed in accordance with MTCA (Chapter 70A.305 RCW) and its implementing regulation (Chapter 173-340 WAC) as amended, and all applicable federal, state, and local laws and regulations. Amendment No. 3 to Agreed Order No. DE 3810 Page 5 of 5 VIII. TERMS AND CONDITIONS OF ORDER Section V111 (Terms and Conditions of Order) is amended by replacing the applicable language in the identified sub -sections as follows: A. Public Notices (replace in whole) Agreed Order No. DE 3 810, Amendment Nos. 1, 2, and 3 to the Order have been the subject of public notice and comment pursuant to WAC 173-340-600. D. Designated Project Coordinators The project coordinator for Ecology is: Kristin Beck Department of Ecology Eastern Regional Office 4601 N Monroe Spokane, WA 99205-1295 The project coordinator for Grant County is: Sam Castro,, C.P.0 Public Works Director 124 Enterprise Street SE Ephrata, WA 98823 Effective date of this Amendment: Exhibit A Scope of Work EXHIBIT A SCOPE OF WORK PURPOSE The work under this Amendment No. 3 to Agreed Order No. DE 3 810 (AO) involves conducting Interim Actions at the Grant County Ephrata Landfill site (Site) for the treatment of groundwater and soil gas contaminated with volatile organic compounds (VOCs) and non -aqueous phase liquid (NA'L)• . A remedial action implemented prior to completing the Cleanup Action Plan is an interim action and must be implemented in accordance with WAC 173-340-430, the AO, and its amendments. Interim actions: 1. are technically necessary to reduce a threat to human health or the environment by eliminating or substantially reducing one or more pathways for exposure to a hazardous substance; 2. correct a problem that may become substantially worse or cost substantially more to- address if the remedial action is delayed; or 3. are needed to provide for completion of the remedial investigation/feasibility study or design of the cleanup action. The Washington State Department of Ecology (Ecology) has determined that these interim actions can be designed and implemented in a manner that does not foreclose any other reasonable alternatives for the final cleanup action that may be required for the Site. The Grant County shall coordinate with Ecology and provide progress updates and draft deliverable review to Ecology during the development of the deliverables associated with this work and during implementation of the interim actions. Grant County shall keep Ecology informed of any significant changes and of any issues or problems as they develop during the performance of the interim actions. Grant County shall prepare electronic copies of the agency -review draft deliverables and submit them to Ecology for review. After incorporating Ecology's comments on the agency -review draft deliverable and after Ecology approval, Grant County shall prepare and submit an electronic copy and one hard copy of the final deliverable. Electronic files shall be submitted in their native file format and, for files that can be saved as such, Adobe (.pdf) format. Schedule compliance will be based on submittal of electronic files!, with transmittal of hard copies within 2 weeks following electronic submittal. Once approved by Ecology, Grant Countywill implement the work according to the SCHEDULE OF DELIVERABLES AND ACTIONS (Schedule) (Exhibit B). Page 1 of 9 Exhibit A Scope of Work TASKS AND DELIVERABLES The Scope of Work (SOW) is divided into seven major tasks: Task 1. Operation of Existing PI Infrastructure Task 2. Interim Action Work Plan (IAWP) Task 3. Multi -phase Extraction (MPE) System Expansion Task 4. Pilot Testing Task 5. Interim Action Progress and/or Completion Report (IAPR, IACR) Task 6. Interim Action Monthly Performance Reports Task 7. Groundwater Monitoring Reports Task 1. Operation of Existing PI MPE System Grant County shall begin operation of the existing PI MPE system to implement MPE while the IAWP is developed. The following subtasks shall comprise this task: 1. Development of an existing P I system work plan for the repairs and replacements, monitoring and sampling, and health and safety, requirements needed to restart and operate the existing MPE system. This work plan should be commensurate with the amount of work occurring, and should reference the original work plan, operation and maintenance (O&M) manual, and other documentation related to the 2017 pilot testing as necessary to outline the planned operation of the system and any changes that will be made. 2. Reinstall well pumps, repair pipes, and restart the existing MPE system. Commence ongoing system operation, maintenance, monitoring, and sampling during the months of April through October until the system needs to be shut down to allow for construction of the expanded MPE system, as outlined in Task 3 below. Task 2. Interim Action Work Plan Grant Countyshall prepare an IAWP prior to implementation of the pilot tests. An agency -review draft IAWP will be submitted for Ecology review and approval. The IAWP will be prepared with detail commensurate with the work to be performed and in accordance with WAC 173-340-430 and will include, as appropriate: * Description of the interim actions including their purpose, general requirements, and relationship to the proposed (final) cleanup action; 0 Summary of relevant information from site investigations or previous interim actions that are relied upon in the IAWP, such as existing MPE system construction records and O&M manuals, well installation data, groundwater elevations, contaminant concentrations, and groundwater screening levels applicable to the interim action; Page 2 of 9 Exhibit A Scope of Work • Preliminary engineering design and construction information, as applicable, in accordance with WAC 173-340-400; • An O&M plan developed in accordance with WAC 173-340-400(4)(c), to the extent feasible using the existing O&M manual, and representative operation and control strategies for planned new facilities and equipment; • Identification of potential treatment waste streams, including consideration of any reagents that might be used, their potential concentrations, applicable waste management regulations, and waste management procedures; • Health and Safety Plan (HASP) that meets WAC 173-340-810 requirements; • Sampling and Analysis Plan (SAP) and Quality Assurance Project Plan (QAPP) that meets WAC 173-340-820 requirements. The SAP/QAPP should include sampling components for protection and performance monitoring that would be included in a Compliance Monitoring Plan (CMP) in accordance with WAC 173-340-410, including any additional groundwater sampling needed to fully inform a natural attenuation analysis for the dissolved phase plume; • Identification of any necessary permits required prior to MPE system expansion, and substantive requirements of law or regulation for which MTCA creates a permit exemption. The IAWP shall detail the following: 1. Proposed Well Layout for Extraction and Soil Vapor Extraction (SVE) and/or Venting Outline the expansion area of the MPE system, including description of the wells used for extraction, the process for determining the effects of SVE or venting on radius of influence, and planned steps for optimization after MPE system expansion. Describe the steps for identifying wells to be tested for venting (admitting air into the extraction zone to increase the subsurface gas flow toward extraction wells). 2. Expansion and/or Replacement of WE Infrastructure Summarize preliminary plans to expand the existing WE infrastructure, such as piping, fittings, pumps, transducers, building size, electrical power supply capacity, and any other %--1 ancillary systems so that the system can accommodate the estimated needs for additional pilot tests. The MPE system shall be designed for at least 5 years of annual seasonal operation from approximately April through October in the PI!P P2, and Roza aquifers. Page 3 of 9 Exhibit A Scope of Work 3. Assessment of Prior Pilot Test Recommendations Outline how the recommendations in the previous pilot test report (Parametrix and Pacific Groundwater Group 2018) will be implemented, including any changes resulting from well network expansion and/or additional monitoring since the previous test. The prior recommendations included: • Above ground design considerations; • Equipment upgrades; • Operation processes to enhance MPE operation and SVE effectiveness; and • Updates to liquid and vapor treatment trains. 4. Outline of Expected Pilot Study Sequencing Present an outline of the pilot study test sequence. The following pilot test sequence may include: • Sampling and gauging PI water -bearing zone wells prior to any dewatering; • P I zone dewatering without vacuum; • Water level monitoring; • Periodic liquid treatment train sampling; • Application of vacuum to PI wells; • Periodic vapor treatment train sampling at the start of PI zone vacuum application; • Evaluation of MPE system vacuum influence; • Startup and testing of the P2 zone system concurrent with ongoing operation of the PI zone system; • Evaluation and subsequent application of MPE to the Roza water -bearing zone by following the general sequence outlined above, concurrent with ongoing operation of the P I and P2 zone systems. 5. Assessment of Treatment Train Capacity and Cost Assess the capacity of the treatment system components to ensure that the system is capable of treating the full MPE system flow; and propose modifications to the system if needed to ensure reliable seasonal operation for at least 5 years. 6. Preliminary MPE System Expansion Design Information Describe preliminary engineering design updates to the existing system plans and specifications, including: Page 4 of 9 Exhibit A Scope of Work • Treatment system description; • Outline of the process for adjusting vacuum pressure used in the system; • Estimate of groundwater and vapor extraction rates; • System inlet and outlet concentrations and estimated treatment efficiency; • Identification of generated waste streams and waste management processes; • Identification of treatment byproducts, their concentrations, any regulatory requirements applicable to the byproducts, and any necessary management requirements. 7. Groundwater Monitoring Plan Outline planned groundwater monitoring to be completed during the interim actions to assess system impacts to groundwater. The groundwater monitoring plan shall reference the SAP and QAPP whenever possible to reduce redundancy. Task 3. Multiphase Extraction System Expansion Grant Countyshall develop plans, specifications, and estimates (PS&E) for expansion of the MPE system consistent with the approved IAWP and state law. PS&E shall include applicable engineering design and construction information, as specified in WAC 173-340-400, including a construction schedule and personnel roles and responsibilities. Grant County shall provide the draft PS&E at the thirty (30), sixty (60), and ninety (90) percent design completion levels for Ecology review and comment. Grant County shall obtain Ecology's approval of the final PS&E prior to advertisement for bids. Grant Countyshall notify Ecology of the notice to proceed, substantial completion, and beneficial occupancy dates. The required construction schedule shall be consistent with the Schedule (Exhibit B). Grant County shall solicit bids and administer the construction contract consistent with the applicable requirements of the Revised Code of Washington (RCW) and Washington Administrative Code (WAC). Grant County shall submit construction documentation to Ecology following substantial completion in accordance with the Schedule. Construction documentation shall include O&M manuals provided by the contractor, record drawings, and an updated O&M Plan developed in accordance with WAC 173- 340-400(4)(c). Task 4. Pilot Testing Grant Countyshall conduct pilot tests consistent with the approved IAVvT for the duration of the Page 5 of 9 Exhibit A Scope of Work interim actions. Grant County shall conduct full system pilot testing for at least 2 years, or longer if required by Ecology, ending the pilot testing when approved by Ecology. Full system pilot testing means dewatering and vapor extraction from all extraction wells, monitoring, and sampling from approximately April through October (extraction season) and monitoring and sampling only from approximately November through March (off season) in accordance with the IAWP. Task 5. Interim Action Progress and/or Completion Report Grant County and its technical consultant will develop an Interim Action Progress Report (IAPB) following completion of Tasks 1-3 and after the first two years of full system pilot testing (Task 4). The IAPB shall include, but not be limited to: • A summary of the work completed, any deviations from the work plan(s), vapor monitoring results, and relevant groundwater monitoring results; • A summary of MPE system performance, mass recovery and treatment system efficiency for the first two years of full system pilot testing; and • Assessment of the MPE system performance, including any recommendations to improve system performance. Grant Countywill develop an Interim Action Completion Report (IACR) following completion of Tasks 1-3 and after Ecology determines that pilot testing (Task 4) is complete. Should Ecology determine that the pilot testing is complete after the first two years of full system operation, the IACR will replace the IAPB. Should pilot testing continue for more than two years, the IAPR will be developed as described above and the IACR will address additional data and analysis starting with the third year of full system operation until the pilot testing ends. The IACR shall include, but not be limited to: • A summary of the work completed, any deviations from the work plan(s), vapor monitoring results, and relevant groundwater monitoring results; A summary of MPE system performance, mass recovery and treatment system efficiency for two or more years (through the end of testing) of full system pilot testing; and • Assessment of the MPE system performance, including any recommendations to improve system performance. .Task 6. Interim Action Monthly Performance Reports By the 151 of the month following the effective date of this Agreed Order Amendment and Page 6 of 9 Exhibit A Scope of Work thereafter through the end of the interim actions, Grant Countyshall submit a Monthly Performance Report to Ecology that details: 1. Site -related activities that have taken place during the reporting period, including progress on upcoming deliverables; 2. Detailed description of any deviations from required tasks not otherwise documented in project plans or amendment requests; 3. Any proposed changes to the tests described in the Existing P1 System Work Plan or IAWP, along with rationale; 4. Detailed description of any deviations from the Scope of Work (this exhibit) and Schedule (Exhibit B) during the reporting period, and any planned deviations in the upcoming reporting period; 5. For any deviations in schedule, a plan for recovering lost time and maintaining compliance with the Schedule (Exhibit B); 6. All raw data (including laboratory analyses) received during the previous month together with a detailed description of the underlying samples collected; 7. Summary results of field measurements and monitoring, including: o Cumulative records of liquid and vapor flow through the treatment system; o Calculated liquid and vapor phase treatment efficiencies where treatment system inlet and discharge concentrations are available; o Volume of phase -separate NAPL in the oil -water separator; o System operating parameters including vacuum, well vapor train valve positions, and well pump cycle counts; 8. Summaries of system performance metrics and statistics; 9. Summaries of extraction network metrics and statistics; 10. Estimates of VOCE NAPL mass removed from groundwater and vapor; and 11. A list of deliverables for the upcoming reporting period, if different from the Schedule (Exhibit B). Task 7. Groundwater Monitoring Reports Grant Countywill produce semiannual groundwater monitoring reports that incorporate, but are not limited to, the following: Summary tables of all groundwater monitoring data for the sampling period; A brief summary of statistical results and/or any statistical trends for the monitoring period and since 2017; Page 7 of 9 Exhibit A Scope of Work • A copy of potentiometric surface maps for each groundwater monitoring event that occurred during the monitoring period; • A summary of groundwater flow rate and direction, including analysis of any changes in flow rates or direction due to recent NVE system operation; • A summary of geochemical parameters, including cation -anion balances and trilinear diagrams, as appropriate; and, • An updated evaluation of system operation with respect to groundwater monitoring data; contaminant fate and transport; contaminant mass removal rates in groundwater; natural attenuation of indicator hazardous substances in groundwater; and/or exposure pathways, if applicable. Grant County or its contractors shall submit all sampling data generated under this AO to Ecology for entry into Ecology's electronic data management system in accordance with WAC 173-340-840 and Ecology's Toxics Cleanup Program relevant policies. Validated data is required to be in Ecology's electronic database within 30 days of submittal of the associated semiannual groundwater monitoring report. 0 Page 8 of 9 Exhibit A Scope of work REFERENCES Parametrix and Pacific Groundwater Group. 2018. Multi -Phase Extraction Pilot Test Interim Remedial Action Ephrata Landfill. Prepared by Parametrix, Seattle, WA. February 2018. Page 9 of 9 Exhibit B Schedule of Deliverables and Actions EXHIBIT B SCHEDULE OF DELIVERABLES AND ACTIONS The schedule for deliverables and actions described in Amendment No. 3 to the Agreed Order (AO) and Scope of Work (SOW) is presented below. References to days in the schedule are calendar days. If the submission date of any item or notification required by this schedule occurs on a weekend, state, or federal holiday, the date for submission of that item or notification is extended to the next business day following the weekend or holiday. When the start date of dewatering (i.e., for restart of the existing multiphase extraction [MPE] system or startup of the expanded system) would be after September I based on the sequence and time intervals, in the table below, the start date will be postponed to the following April 1. Where a deliverable due date is triggered by Ecology notification, comments, or approval, the starting date for the period shown is the date the potentially liable persons (PLPs) receive such notification, comments, or approval. Where triggered by Ecology receipt of a deliverable, the starting date for the period shown is the date Ecology receives the deliverable. Modifications to this schedule will be granted in accordance with the process described in Section VIII K of the original Agreed Order,, dated January 30, 2007. Task Deliverables/Actions Completion Times I Submittal of Ecology- 30 days following the effective date of review draft of Existing P I Amendment No. 3 to AO No. DE 3 810 System Work Plan Begin operation of Existing 4.5 days after Ecology approves the Existing P I P I System System Work Plan; restart the system and continue seasonally as described in the SOW until shutdown is required at the time of MPE expansion. 2 Submit Ecology -review 120 days following the effective date of draft Interim Action Work Amendment No. 3 to AO No. DE 3 810 Plan (IAWP) for MPE expansion Submit the proposed final 30 days following receipt of Ecology comments draft IAWP and comment on Ecology -review draft IAWP response summary Submittal of the final IAWP 7 days after receipt of any final Ecology to Ecology comments and/or approval of the proposed final IAWP 3 Submit Ecology -review 120 days after Ecology approval of the IAWP draft 30% plans, specifications, and estimates _(PS&E) for MPE Page 1 of 2 Exhibit B Schedule of Deliverables and Actions Task Deliverables/Actions Completion Times 0 expansion Submit Ecology -review 90 days after receipt of Ecology comments on draft 60% PS&E the 30% PS&E Submit Ecology -review 60 days after receipt of Ecology comments on draft 90% PS&E the 60% PS&E Start MPE expansion 4 months after receipt ofEcology comments on construction (notice to the 90% PS&E ceed date) Substantially complete 6 months after notice to proceed date. MPE Expansion construction (substantial completion) Submit contractor -provided 60 days after substantial completion operation and maintenance (O&M) Manuals, Construction Record Drawings, and Updated O&M Plan to Ecology 4 Start the expanded pilot 30 days after substantial completion tests End the pilot tests After at least 2 years of full system pilot testing, and with Ecology approval 5 Submit Ecology draft 90 days after 2 years of full system operation Interim Action Progress (replaced by completion report if Ecology Report (IAPR) notifies the PLDs that pilot testing can end) Submit -proposed final 30 days after receipt of Ecology comments on IAPR to Ecology the draft IAPR Submit final IAPR to 7 days after receipt of any final Ecology Ecology comments and/or approval of the proposed final IACR Submit Ecology -draft IACR 90 days after Ecology notifies the PLPs that the pilot testing can end Submit pro -posed final 30 days after receipt of Ecology comments on IACR to Ecology the draft IACR Submit final IACR to Ecology 7 days after receipt of any final Ecology comments and/or approval of the proposed final IACR 6 Interim Action Monthly Performance Reports Due to Ecology on the 15' of month following the effective date of Amendment No. 3 to AO No. DE 3810 7 Groundwater Monitoring Semi-annual reports submitted within 60 days Reports of the end of each extraction season and each off season Electronic data submittal to 30 days following submittal of the associated 1 Ecology I semi-annual groundwater monitoring report Page 2 of 2