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W <br />9'00003527 <br />d. Local opposition to the discharge was expressed during a public meeting and the <br />ESD public comment period. The effect of the discharge to the area was <br />reevaluated and the extraction rate was reassessed. It was determined that a phased <br />approach to the remedy under the ROD would be undertaken. This meant that the <br />on -site hotspots of the groundwater contaminant plume would be differentiated <br />from the off -site contaminant plume. The phased approach would allow the <br />reduced flow to be discharged to the drainage canals and would allow for the off - <br />post remedy to be reviewed. <br />1. During the first phase groundwater will be extracted from the hotspots (total <br />gpm 750) treated and discharged to the two drainage canals, thereby, allowing <br />for greater infiltration on the CHAAP property prior to migration to Silver <br />Creek. First phase groundwater monitoring and modeling will assess the <br />changing contaminant plume off post (shrinking shape and decreasing <br />concentrations). This will allow for the off post remedy to be reevaluated and <br />for an effective and appropriate solution to be put in place. <br />2. During the second phase of the remedy the off -post remedy will be <br />implemented. If the remedy for the off -post changes significantly (as defined <br />by 40 CFR Section 300.435 (b)(3)(ii) the ROD amendment process will be <br />followed. The ROD amendment process is required when; "...the differences <br />in the remedial or enforcement action, settlement, or consent decree <br />fundamentally alter the basic features of the selected remedy with respect to <br />scope, performance, or cost. To amend the ROD the lead agency, in <br />conjunction with the support agency..." shall; issue a notice of availability and <br />description of the change in a major local newspaper; make the amendment and <br />supporting documentation available for public comment for at least 30 days; <br />hold a public meeting during public comment period; keep a transcript of <br />comments received at both the public meeting and during the public comment <br />period; include response to comments as part of the final ROD amendment; <br />publish a notice of availability of the amended ROD in the local paper; and <br />submit the documents to the administrative record. <br />3. CHAAP is committed to including the public in the continuing assessment of <br />discharge to Silver Creek. Therefore CHAAP will enter into a Memorandum <br />of Understanding (MOU) with the EPA, NDEQ and CPNRD to formalize its <br />commitment to reassessment of the potential impact of discharge to the on -post <br />Drainage Canals, Silver Creek and the surrounding areas. Hall Co, City of <br />Grand Island, and Merrick County selected the Central Platte Natural <br />Resources District ( CPNRD) as their representative for this issue. <br />III. DEFINITIONS: <br />a. Cornhusker Army Ammunition Plant ( CHAAP) site is, as defined in the FFA, the <br />entire facility and the off -post contamination. <br />