Revised Final Performance Monitoring Plan – Groundwater Source Control Measure
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Revised Final Performance Monitoring Plan – Groundwater Source Control Measure Premier Edible Oils Portland, Oregon Prepared for: MMGL LLC April 2017 www.erm.com The business of sustainability MMGL LLC. Revised Final Performance Monitoring Plan – Groundwater Source Control Measure Premier Edible Oils, Portland, Oregon April 2017 Project No. 0382181 Brendan Robinson, P.E. Program Director Kim Marcus, R.H.G. Partner Environmental Resources Management 1001 SW 5th Avenue, Suite 1010 Portland, Oregon 97204 T: 503-488-5282 F: 503-488-5142 TABLE OF CONTENTS LIST OF TABLES II LIST OF ACRONYMS III 1.0 INTRODUCTION 1 1.1 BACKGROUND 1 1.1.2 Groundwater Source Control Measure Development 2 1.2 REPORT OBJECTIVE 3 1.3 REPORT ORGANIZATION 3 2.0 GROUNDWATER MONITORING 4 2.1 PROPOSED MONITORING WELL LOCATIONS 4 2.2 GROUNDWATER CONCENTRATION PERFORMANCE EVALUATION CRITERIA 5 2.3 PERFORMANCE EVALUATION 7 2.4 GROUNDWATER ELEVATIONS 7 2.4.1 Water Level Data Filtering 9 2.5 GROUNDWATER SAMPLE COLLECTION AND ANALYSIS 11 2.5.1 Field Parameters 11 2.5.2 Analytical Parameters 12 2.5.3 Quality Control 12 3.0 ADAPTIVE MANAGEMENT PROCESS AND REPORTING 14 3.1 ADAPTIVE MANAGEMENT 14 3.2 PERFORMANCE MONITORING REPORTING 15 4.0 REFERENCES 16 LIST OF APPENDICES Appendix A – Sampling and Analysis Plan Appendix B - Quality Assurance Project Plan Appendix C - Analytical Methods for Petroleum Hydrocarbons, Washington State Department of Ecology, June 1997 LIST OF FIGURES Figure 1 Site Location Figure 2 GW SCM Layout Figure 3 Proposed Performance Monitoring Network Figure 4 Adaptive Management Flow Process Diagram LIST OF TABLES Table 1 Well Construction and Monitoring Summary Table 2 Proposed Analytes for Groundwater Sampling REVISED FINAL LIST OF ACRONYMS ERM ERM-West, Inc. FS Feasibility study GWBW Groundwater barrier wall GW SCM Groundwater source control measure JSCS Joint Source Control Strategy LNAPL Light non-aqueous phase liquid ODEQ Oregon Department of Environmental Quality PMP Performance Monitoring Plan RI Remedial Investigation RG Remediation Goal SCM Source control measure TZW Transition zone water USEPA United States Environmental Protection Agency WQS Water Quality Standard iii REVISED FINAL 1.0 INTRODUCTION On behalf of MMGL LLC as successor by merger to MMGL Corp. (MMGL), ERM-West, Inc. (ERM) has prepared this Performance Monitoring Plan (PMP) for the former Premier Edible Oils (PEO) facility located at 10400 North Burgard Way in Portland, Oregon (the site) (Figure 1). This PMP has been prepared pursuant to the Voluntary Agreement for Upland Remedial Investigation (RI)/Feasibility Study (FS) and Source Control Measures issued by the Oregon Department of Environmental Quality (ODEQ) and signed 6 March 2001 (ODEQ ECDVC-NWR-01-06) (Voluntary Agreement), and revised based on comments received from the ODEQ in a letter dated 8 March 2017. The purpose of this PMP is to present the monitoring requirements for the implementation of a groundwater source control measure (GW SCM) at the site. 1.1 BACKGROUND The site is an industrial property located on the Portland Harbor waterfront along the east bank of the Willamette River. The upland portion of the site has been used for a number of industrial operations since approximately 1940, including bulk petroleum storage, ship building, production of dry cell battery materials, and refining of edible oils. PEO operated the site from 1972 to 1997 for the refining of edible oils, such as palm and cottonseed oils, and packaging and shipping the oils for use in the processed food industry. PEO operations were discontinued in approximately 1996, and the remaining buildings are vacant. A number of environmental investigations have been performed at the site since 2001 under the ODEQ Voluntary Cleanup Program. The facility is bounded by the Willamette River on the south and west, exporting and metal recycling facilities to the east, and the Time Oil Co. Northwest Terminal (ECSI Site ID: 170) to the north. Detailed historical land use and potential contaminant of interest sources were presented in the Phase II Remedial Investigation Work Plan (Treadwell & Rollo, A Langan Company [Treadwell & Rollo] 2014) and are summarized in this section. ERM 1 MMGL CORP./0382181/APRIL 2017 REVISED FINAL 1.1.2 Groundwater Source Control Measure Development The Joint Source Control Strategy (JSCS) was developed by the ODEQ and the United States Environmental Protection Agency (USEPA) to identify, evaluate, and control sources of contamination that may impact the Willamette River in a manner that is consistent with the objective and schedule for the Portland Harbor Superfund Site RI/FS (ODEQ and USEPA 2005). The goal of the JSCS is to achieve timely upland source control to prevent the risk of significant recontamination after the Portland Harbor cleanup is complete. Based on the results of previous investigations, a GW SCM consisting of a slurry wall in conjunction with an oxygenation/biobarrier system has been determined as a feasible alternative for controlling the potential migration of light non-aqueous phase liquid (LNAPL) into transition zone water (TZW) and mitigating dissolved phase impacts to the Willamette River (Treadwell & Rollo 2014; ODEQ 2014a). The GW SCM consists of a groundwater barrier wall (GWBW) to physically separate the affected upland portions of the site from the Willamette River, and an upgradient oxygenation/biobarrier system to oxygenate the aquifer and promote degradation and stabilization of LNAPL and dissolved phase contaminants. The GW SCM is currently being implemented and the GWBW was installed in Fall 2015, as approved by the ODEQ and comments provided by the USEPA. The approximate GWBW alignment is shown on Figure 2. A detailed description of the GWBW installation was presented in the Groundwater Barrier Wall Construction Completion Report (ERM 2016). The installation of a GWBW is expected to significantly reduce the mass of contaminants leaving the uplands portion of the site and flow of oxygenated water under and around the GWBW will increase the current ongoing natural attenuation. An objective of GWBW is to provide a barrier to groundwater to allow for greater treatment on the upgradient side of the GWBW with the oxygenation/biobarrier system (the second phase of the GW SCM). A Pilot Study Workplan for the second phase of the GW SCM, the installation of the oxygenation/biobarrier phase, will be submitted under separate cover. ERM 2 MMGL CORP./0382181/APRIL 2017 REVISED FINAL 1.2 REPORT OBJECTIVE The objective of this PMP is to present the monitoring scope and rationale for evaluating the performance of the GW SCM in controlling the potential migration of LNAPL to TZW and mitigating any potential dissolved phase impacts to the Willamette River. 1.3 REPORT ORGANIZATION The remainder of the PMP is organized as follows: • Section 2.0 presents the information on the monitoring well locations, groundwater elevation and sample collection and analysis; • Section 3.0 presents the adaptive management process and reporting of performance monitoring results; and • Section 4.0 lists the references cited. ERM 3 MMGL CORP./0382181/APRIL 2017 REVISED FINAL 2.0 GROUNDWATER MONITORING Key long term objectives of the GW SCM are to control the potential migration of LNAPL into TZW and to mitigate potential dissolved phase impacts to the Willamette River. The proposed performance monitoring approach will consist of regular monitoring of the hydraulic and geochemical conditions in the vicinity of the GW SCM. The monitoring results will then be used to evaluate the performance of the GW SCM. 2.1 PROPOSED MONITORING WELL LOCATIONS The proposed performance monitoring well network will consist of a combination of existing and new groundwater wells. Clusters of wells with shallow and deep screen intervals will be installed to evaluate groundwater conditions (e.g. groundwater flow, LNAPL, and dissolved phase impacts) across the site and in the vicinity of the GW SCM. A total of 16 new groundwater monitoring wells are proposed to be installed. Proposed monitoring locations are shown on Figure 3 and construction details provided in Table 1. Actual locations and construction may be revised depending on accessibility and field conditions encountered. The monitoring wells in the vicinity of the GWBW will be used to evaluate horizontal and vertical flow adjacent to the GWBW. Additional upgradient wells will be used to evaluate site-wide groundwater flow conditions, LNAPL extent, and dissolved phase impacts to groundwater (Figure 3). Shallow wells will generally be constructed so that the well screen interval intersects the anticipated water table throughout the year (generally observed at 21 feet below ground surface). Deep wells will generally be constructed with the screen interval at or below the depth of the GWBW (35 feet bgs). Existing wells MW-26 and MW-27 were previously installed with a screened interval below the proposed depth of the GWBW (depths of 34 to 39 and 35 to 40 ft bgs, respectively) and will be incorporated into the performance monitoring program to evaluate groundwater conditions at the top of bank. ERM 4 MMGL CORP./0382181/APRIL 2017 REVISED FINAL 2.2 GROUNDWATER CONCENTRATION PERFORMANCE EVALUATION CRITERIA The purpose of the GW SCM is to protect ecological and human health receptors that are impacted by any contamination potentially passing from groundwater through the TZW (i.e. porewater) and into the surface water column in the Willamette River. The ODEQ has promulgated water quality standards (WQSs) for both aquatic protection and protection of human health (through ingestion of organisms and water) in the surface water column. EPA approved the WQSs on October 17, 2011, making these effective under the Clean Water Act. Additionally, EPA published Remediation Goals (RGs) in the Record of Decision for the Portland Harbor Superfund Site, dated January 2017 (USEPA 2017), for specific Remedial Action Objectives (RAOs) that are intended to be protective of the proposed sediment remedy for Portland Harbor Superfund site.