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
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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
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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