07/31/2005 Farsad to Judge Shelton - Five Year Update
"The fact that these reduced concentrations remain above acceptable levels is attributable to
several factors. The parties originally estimated that the cleanup goal could be achieved with the
removal of 26,200 pounds of 1,4-dioxane. Obviously, this proved not to be the case since PLS
has already removed over 41,000 pounds of 1,4-dioxane. The disparity is likely due to both the
unanticipated contribution from the Unit E aquifer and simply the inexact nature of the
methodology used to estimate the contaminant mass. This unanticipated additional mass along
with the physical limits of the pump and treat technology in this geological setting have
prevented the parties from completing the cleanup within the five-year timeframe."
[excerpt from full report]
Farsad never mentions the problems with the northern transmission pipeline from Evergreen:
7/18/05 On behalf of Farsad, Laurel sent a note to Sybil that the (NTP) was shut down due to negative pressure.
7/18/05 Flowmeters were checked and calibrated to assure accurate flow readings between Evergreen and the Red Pumphouse.
7/20/05 PLS contacts FTC&H to consult about the pipeline pressure losses and options to address the situation.
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7/20/05 FTC&H begins researching vendors with capabilities to conduct video surveillance and pipeline inspections. FTC&H finds that small diameter of pipeline coupled with the length and depth limits number of companies capable of inspecting line.
7/21/05 FTC&H provides email to PLS with information on pipeline inspection companies. FTC&H continue to have discussions with PLS regarding options for camera surveillance and repair options.
7/22/05 PLS contacted Clean Earth to see if a camera could be sent into the NTP. Clean Earth responded that they would be willing to try as early as the following week.
7/25/05 Farsad had a telephone conversation with Sybil to update MDEQ on the situation.
7/25/05 The contractor (Clean Earth) ran a camera down the transmission line from the MDOT property. The camera would not advance any further than 100 feet.
7/26/05 The contractor (Clean Earth) first jetted the transmission line and then ran the camera down from the MDOT property for the second time to approximately 270-300 feet. Clean Earth informed PLS at that time, that they did not have the technology to advance further than what they had accomplished up to that date.
7/27/05 PLS contacted IRWS to ask if they were able to or if they were aware of any other companies with the capability of jetting and/or videoing the line. IRWS informed PLS that they would get back to PLS in a few days.
7/28/05 LB-1 and LB-2 were turned on briefly (approximately 1 hr) in order to clean the debris left by the jetting process.
[excerpt from 20051026-Pall-Response-deq-rrd-GS-TransmissionLineChronology_303315_7.pdf]
Court was updated on the issue 11/16/2005, informing court on plan to reline 6-inch horizontal well pipeline to use as transmission pipeline.