Memorandum

City of Lawrence

Municipal Services & Operations

TO:	Tom Markus, City Manager
FROM:	Sarah Graves, Project Engineer
CC:	Brandon McGuire, Assistant to the City Manager Aurora Shields, Environment, Science, Technology Section General Manager Andy Ensz, Utilities Engineer Dave Wagner, Director
DATE:	December 18, 2018
RE:	Update on Farmland Remediation Efforts with contracted consultant, GHD

Background

The City has been pursuing changes to the long-term environmental remediation project at the former Farmland Nitrogen Fertilizer Plant. Phase one of this effort, approved by the City Commission on April 3, 2018, includes professional services related to site study, analysis of alternative remediation strategies and regulatory approvals for alternative strategies prepared by the selected firm, GHD Inc.

The project scope, as proposed by GHD at the beginning of this year, includes data review, existing remediation systems evaluation, remediation alternative evaluation and recommendation, and community engagement. During the presentation of the selected consultant made by Municipal Services and Operations (MSO) Department in April of 2018, a project timeline was presented, and stated that City Staff would provide an update on the project by the end of the year.

Staff Action

Staff and GHD have worked continuously to produce a remediation alternative that may be presented to the Kansas Department of Health and Environment (KDHE). The first step in the approved contract with GHD included site data review and development of an updated conceptual site model. During the development of this static model, GHD and the City have encountered data gaps in historical information that have been collected on the site. To address these data gaps, the City Staff and GHD prepared a data gap study work plan that has been presented to and is under review by KDHE. KDHE has indicated the plan should be approved by February 2019. Upon approval of this work plan, City staff intends to provide an update to the City Commission along with an agenda item containing a change order to address the additional work.

Until this plan is approved and the data gap study has been performed, an alternative analysis and recommendation of remedial alternatives cannot be reasonably completed and presented to KDHE for review and approval.

In addition to the development of the conceptual site model, GHD and City staff have begun the process of closing the RCRA (Resource Conservation and Recovery Act) permit associated with the CRS (Chrome Reduction System) unit that has been entirely remediated since the City took ownership of the site. A certification of post closure care report, prepared by GHD, is also under review by KDHE.

The approximate schedule for the RCRA permit closure is below:

· 60 day review period by KDHE

o Following this review, KDHE will prompt us to send a permit modification request

· 30 days for preparation of the permit modification request

· 60 day public comment period

o Within these 60 days, a public meeting will be held regarding the permit closure

· 30-day allowance for KDHE to approve

The letter was submitted on November 16 to KDHE and is under their review. Following this timeline, the permit closure is estimated to be completed in May of 2019.