Brian Barone (Agency Rep - DC Dept. of Energy & Environment ) provided an update on the Dispute Resolution between USACE, DOEE, and Environmental Protection Agency. DOEE and EPA do not want to rely solely on Land Use Controls (LUCs) as a remedy for the Spring Valley Groundwater issue. The Dispute Resolution process has paused at Tier 2 while USACE and the Partners discuss potentially conducting additional groundwater data collection. USACE agreed to move forward with a new round of sampling as a data gap study to identify any areas that may require more information for an assessment of remedial options at the site. The Groundwater data is now several years old at this point, therefore any decision made on remediation approaches would be based on old data. DOEE wants to see new data ...
The Comprehensive Environmental Response, Compensation & Liability Act (CERCLA) site directives state that LUCs should not be the first and only way to remedy a problem. Other remediation options should be implemented, and there are several different technologies available. That's why DOEE wants to sample to determine current levels and utilize additional geochemical parameters to help decide on the best remedy ... The plan needs to include a remediation that is known to be effective. The worst thing to do is spend a lot of money and not conduct the research up-front and have zero result. At this point, DOEE believes that Institutional LUCs are not enough ...
Allen Hengst (audience member): Let's say they conduct the additional testing and perchlorate is over EPA's forthcoming new standard, which might very well be lower than 15 parts per billion ... The Army doesn't want to clean it up. They don't care what the level is, they don't think it needs to be cleaned up. So, you're headed for Tier 1 and then the lawsuit, I guess. Because USACE is never going to give in on this. It's not up to them. It's up to the Department of Defense and they have perchlorate sites all over the country that they don't want to clean up ... Right now the hazardous locations are based on 15 parts per billion. If the standard goes down to 10 or 5 or 2 — or like California where it's 1 part per billion — you're going to have a lot more wells that need to be tested ...
Barone: If the first round of sampling is completed and a new standard comes out, another round of sampling can be conducted. Barone does not believe anyone wants to get to the point where the Partners say, "this is all taken care of," and then a new standard comes out and testing must be resumed ...
Hengst: EPA is coming out with a new standard and your 15 parts per billion is going to be ancient history.
Greg Beumel (RAB Co-Chair): If it's ancient history, we have two people sitting in the room right now who will then direct us to the new standard, okay? ... The Army Corps cannot conduct a year’s worth of quarterly tests until they start them.
Spring Valley FUDS
RAB Meeting Minutes
March 12, 2019 (pgs. 3 - 5)
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