Document 2bQO37kMe5ryq6Ldw3p49bn6

NEBRASKA Good Life. Great Environment DSPT. OF ENVIRONMENTAL QUALITY Memorandum To: Ed Chu, Deputy Regional Administrator, EPA Region 7 From: Jim Macy, Director, Nebraska PEQ Date: September 7, 2017 Fund-lead West Highway 6 & Highway 281 Superfund Site fmore familiarly referred tas the Dana Corporation Site, Hastings, Nebraska! issue: EPA region 7 has issued a Proposed Plan selecting a preferred remedial alternative for restoration of groundwater contamination with a longer restoration timeframe that wilt increase the State's operation and maintenance costs. EPA Region 7 is in the final stages of decision-making on this project. Proposed solution: Nebraska Department of Environmental Quality proposes to select a more aggressive groundwater remedial alternative to reduce the overall restoration timeframe, save approximately $3.6 million to the State in operation and maintenance costs and facilitate redevelopment and reuse of on-site and down gradient properties, Timeline: In 1999, Dana enrolled in NDEQ's voluntary cleanup program to identify the extent of soil and groundwater contamination beneath its facility. By 2003, Dana had installed and started operating a soil vapor extraction (SVE) system and a groundwater extraction and treatment (GET) system to address the contaminated soil and groundwater and continued operating these systems over the next couple of years. After unsuccessful attempts by NDEG. to get Dana to address contaminants that had migrated off the facility property, NDEQ, collected groundwater samples from private and public drinking water wells and detected Dana-related contaminants at levels of concern at numerous locations, Dana's unwillingness to address the off-site contamination led to NDEQ's request for assistance from EPA. Responding to NDEQ's request, EPA assumed the lead oversight role in 2005 and proposed the site to the National Priorities List (NPL) in September 2005. Shortly after, in Wlarch 2006, Dana declared Chapter 11 bankruptcy. The site was finalized on the NPL in April 2008. EPA initiated time-critical removal activities in July 2006 to continue operating and maintaining the existing GET and SVE systems. EPA also monitored water quality in private residentiai/business wells downgradieni of the facility and provided alternate water when the wells were found to be impacted above acceptable levels. In September 2006, EPA began remedial investigation activities. In September 2006, EPA filed a claim against the Dana bankruptcy and recovered approximately $2.1 million that is currently in a special account for the site. EPA recently finished the feasibility study and issued a proposed plan on August 15, 2017 to address the off-site groundwater contamination. A public meeting on the proposed plan was held on August 23, 2017. A record of decision (ROD) selecting the remedy will be completed by the end of September, 2017. The on-site existing GET and SVE systems will continue to be operated by the EPA Department o f Environmental Quality P.0. Box 98922 1200 NStreet, Suite 400 Lincoln. Nebraska 8409-8922 Sierra Club v. EPA 18cv3472 NDCA Tier 10 3`m MacX- D irector ornes 402-871 -21 So fax 402-4/1-2909 nOeq.nejreinfcY.Anebraskn.gov ED 002061 00116121-00001 removal program until a feasibility study, proposed plan and record of decision (ROD) are completed in the future. Background: The MDEQ Remediation Section has been in discussions with EPA regarding the potential remedial alternatives under consideration, groundwater extraction and treatment at the leading edge of the contaminant plume only (alternative G3) or groundwater extraction and treatment at mid-plume and leading edge of plume (alternative G4), NDEQ,'s preferred alternative is the mid-plume/leading edge alternative, mostly due to the decreased estimated cleanup time frame (16 years vs. 30 years for the leading edge-only alternative) and the estimated long-term cost savings of approximately $3.6 million to the State in future operation and maintenance costs. EPA's preferred alternative is the leading edge only alternative, G3, Until the week before releasing the proposed plan NDEQ thought that ERA would prefer mid-plume/leading edge, G4, but then found out that based on what EPA considers miscalculations in the draft comparative analysis of alternatives and focusing on the reassessment of several "balancing criteria" in that analysis, EPA now prefers leading edge only, G3. Briefly stated, EPA believes that when taken ail together, the balancing criteria for the two options essentially cancel themselves out. Therefore, in EPA's opinion, the sole remaining criteria Is the Present Value Costs associated with the alternatives: Leading Edge Only Extraction - $9,017,000 IVlid-pfume & Leading Edge Extraction - $12,757,000 In a letter dated August 21, 2017, NDEQ. did not concur with the EPA's preferred alternative. This determination was based on the selected G3 remedial alternative has an estimated restoration time frame of 30 years versus an estimated restoration time frame of IB years for remedial alternative G4 (Groundwater Recovery, Treatment, and Discharge at Mid-plume and Leading Edge of Plume). This selection is contrary to recent EPA Headquarters1goals and objectives of accelerating the pace of cleanups, quicker restoration time frames, and the facilitation and promotion of redevelopment and reuse of on-site and downgradient properties. NDEQ estimates (below) that the selection of Alternative G3 would increase the State's futu re Operation & Maintenance obligations to approximately $3,627,000 more than would be incurred by the selection of Alternative 64. G3 annual &M cost $241,000 X 20 yrs (we pay 100% for yrs 11-30) = $4,820,000 G3 monitoring cost $67,000 X 20 yrs = $1,340,000 G3 periodic cost = $107,000 63 total CM by State - $6,267,000 G4 annual O&M cost $373,000 x 6 yrs (we pay 100% for years 11-16) = $2,238,000 G4 monitoring cost $67,000 X 6 yrs = $402,000 G4 total O&M by Slat - $2,640,000 Difference between G3 and G4 = $6,267,000 - $2,640,000 ~ $3,627,000 Sierra Club v. EPA 18cv3472 NDCA Tier 10 ED 002061 00116121-00002 Mote; Figu ' I from EP Feasibility Study (July 2017) Figures 7.1 & 72 Sierra Club v. EPA 18cv3472 NDCA Tier 10 ED 002061 00116121-00003