Document ZJrNeDKZvd9jG0xBbzQ5BY3OJ

NEBRASKA Good Life. Great Environm ent DEPT. OF ENVIRONMENTAL QUALITY Pete Ricketts. Governor Ms. Mary Peterson, Director U.S. Environmental Protection Agency Region VII Superfund Division 11201 Renner Blvd. Lenexa, KS 66219 RE: NDEQID: Program ID: Subject: West Highway 6 & Highway 281 Site 85059 NEN000704738 Non-Concurrence Determination for OU 2 Proposed Plan Dear Director Peterson: The Nebraska Department of Environmental Quality (NDEQ) has reviewed the Proposed Plan, dated August 2017, for Operable Unit 2 (OU 2) of the West Highway 6 & Highway 281 Site (Site). Based on our review, the Department does not concur with the selected remedial alternative G3 (Groundwater Recovery, Treatment and Discharge at Leading Edge of Plume). This determination is based on the following reasons: 1. The selected G3 remedial alternative has an estimated restoration time frame of 30 years versus an estimated restoration time frame of 16 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 Headquarters' goals 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. 2. The Department estimates that the selection of Alternative G3 would increase the State's future Operation & Maintenance obligations to approximately $3,627,000 more than would be incurred by the selection of Alternative G4. Should you have any questions regarding this decision, please contact Land Division Administrator David Haldeman at 402/471-4219 or Remediation Section Supervisor Mike Felix at 402/471-2938. Thank you for your consideration in this matter. Y BD170DM372fl cc: Preston Law, EPA Brian Zurbuchen, EPA Pam Houston, EPA joe Patterson, City of Hastings David Wacker, City of Hastings Department of Environmental Quality PO. Box 98922 1200 N Street, Suite 400 Lincoln, Nebraska 68509-8922 Sierra Club v. EPA 18cv3472 NDCA d e q .n e .g o v Tier 10 Sim Macy, Director office 402-471-2186 fax 402-471-2909 ndeq.moreinfo@nebraska.gov ED 002061 00116120-00001