Gershman, Brickner & Bratton, Inc., (GBB) believes a critical milestone is approaching in the Cessation Certification Status of the EPA additional Work for the Ordot Dump consent decree, with a report potentially being submitted to U.S. Environmental Protection Agency by mid-October.

Chris Lund, vice president of GBB said that initial investigations per the May 2025 joint Court report with USEPA are being finalized. He said this needs to be addressed before USEPA will entertain a cessation certification from the receiver.

"The status of the additional investigation since last month's board meeting are as follows: we have done our sample, at Monitoring Well-17. It was sampled on July 13, successfully, delivered to lab, and we have some ongoing data validation, which we recently got results back on. And we'll be communicating those results as they become available, which should be shortly. That was the last planned sample event of this initial investigation," Lund said.

According to Lund discussion and technical calls have been held regarding the status of the additional work for USEPA, he said updates are in progress.

"Also updating the groundwater monitoring program, but that doesn't have bearing on the EPA additional work and subsequent cessation certification effort," he said.

Lund said that preliminary results from the mid-July sampling event indicate that chloride levels were above background, groundwater quality or the upper prediction limit which is the highest level expected.

"However, I just want to say it's well below the maximum contaminant level. That's another level for drinking water quality. in groundwater. So, in general, I can say that the results for all the analytes, for both the June, the sample event before this one, and the July sample event, are consistent with the prior results that we did in the wet season. We did two sample events last year. that indicate that, really, only chloride is above the upper prediction limits. So, based on that, we're putting together our data. We're going to be providing it to the technical team, which we will have a call ... this week, the 27th. We have a call on Thursday. I will be presenting those results for the first time to the technical team," Lund explained.

He said that typically the technical team will review the results and answer back.

"We have a bi-weekly call every two weeks, but I want to move that up and maybe, hey, just look at these a week. Let's get an answer back right away. So, I'm going to ask for an additional technical call in a week so that we can get their comments back, if any," he said.

Lund said the goal is to get input and incorporate that into a final technical memorandum for the investigation requested by USEPA.

"Then that was sort of the document that I talked about last year, about a year ago, when I said, Hey, in about 13, 14 months, we're going to have results, and we're going to be putting together a technical report, and providing to USEPA, they're going to chew on that and give us comments back, and then the next step, at least, if there's a finding that no further action, no further testing is needed and that's sort of USEPA and Guam EPA. Then we'll be writing a certification cessation over the course of the latter half of September, and probably mid-October, we would have that into USEPA," he said.

He said the plan is dependent on the technical meeting and feedback from USEPA.

While the developments are consistent with estimates provided last month, Lund recognized that it is slightly delayed.

"We slid a month because we ... had some failed sample results in the early June, so we couldn't get that sample again until mid-July. So, we slid about a month. So, yeah, it's falling into mid-October when we'll have that report, or we'll have that certification of cessation into USEPA. Provided we've got these other check marks and okays on our technical memorandum, and the data, and that they're satisfied with the results, and that no further activity is warranted," Lund said. "Generally, I'm saying that's good news as far as the results that we got back for July."