Programmatic Sequencing Clause Samples

Programmatic Sequencing. The appropriate sequencing of remedial measures at the Gasco Sediments Site is critical to maximize the effectiveness of the overall Portland Harbor Superfund Site remedy and minimize the potential for recontamination. Four distinct phases of work under Oregon Department of Environmental Quality (DEQ) and EPA direction are anticipated to occur in the following order (see Figure 2):  Groundwater/Non‐aqueous Phase Liquid (NAPL) Source Control (DEQ lead)  Upland Remedial Action (DEQ lead)  Gasco Sediments Site Final Sediment Remedy – Phased (EPA lead), design of which is the subject of this SOW  Portland Harbor Remedy (EPA lead) The groundwater/NAPL source control work needs to be completed first to prevent recontamination of any sediment remedy, and particularly sediment caps. Focused feasibility studies for the upland source control work have been completed, and a interim source control action is currently under design. The upland source controls will include a vertical barrier to NAPL migration and a groundwater extraction and treatment system. A NAPL extraction system may also be included in upland source controls, depending upon the findings of the planned NAPL Removal Pilot Program. These interim measures are expected to be part of an overall upland final remedy. Additional upland source control includes enhanced in‐situ bioremediation for chlorinated volatile organic compound (CVOC) impacts in the Siltronic source area. The Respondents will continue to work under DEQ oversight on upland source control actions related to the Gasco and Siltronic sites. The goal is for upland sources to be controlled to the greatest extent practicable before or during Site remedy implementation such that post remedy recontamination is not predicted and that in‐water RAOs can be achieved. The Gasco upland remedial investigation and risk assessment reports are currently being reviewed by DEQ and the upland feasibility study is in the preliminary planning phase. The upland feasibility study shall include evaluations of technologies and remedial alternatives to address upland soils, NAPL, groundwater, and stormwater. The remedial actions selected will be integrated with the Source Controls discussed above into an overall permanent remedy addressing all matrices and pathways posing risk at the Gasco and Siltronic upland sites. The goal is to implement the upland work prior to placement of the final Gasco sediment caps and dredge covers. The Siltronic Focused Feasibility St...