FW: Floragon Dip Tank Area

From: HAFLEY Dan

Sent: Fri Jul 14 15:21:40 2017

To: DECONCINI Nina; SEIDEL Paul

Cc: POULSEN Mike

Subject: FW: Floragon Dip Tank Area

Importance: Normal

Nina and Paul –

This is very non-controversial remedy. Dioxin contamination in the Dip Tank Area is modest other than one hot spot area, and the area already capped with asphalt and concrete. The pending proposed remedy will address the single hot spot, the old stormwater system, improve the hardscape, and include upland habitat enhancement that is not required for protectiveness. Nevertheless, Susan may have concern with some aspect of the email below. My apologies in advance for being out of town next week, but we just reached the finish line on approving the FS and time is very limited to get to a ROD and implement the remedy in 2017. Mike Poulsen will be filling in during my absence next week and can respond to any immediate needs as necessary. Ideally, questions/concerns can be addressed after my return on the 24^th.

From: HAFLEY Dan

Sent: Friday, July 14, 2017 3:11 PM

To: 'Susan Hansen' <foxglovefarm@inbox.com>

Cc: SEIDEL Paul <SEIDEL.Paul@deq.state.or.us>; DECONCINI Nina <DECONCINI.Nina@deq.state.or.us>; 'POULSEN Mike' <mike.poulsen@state.or.us>; GRABHAM Cheryl <Grabham.Cheryl@deq.state.or.us>

Subject: RE: Floragon Dip Tank Area

Susan –

We have reviewed and commented on the Feasibility Study presented on Avison’s behalf for Dip Tank Area portion of Floragon. Some minor changes have been made, including clarification in text on values that are being used to identify soil hot spot concentrations (as requested). Both our former and current hot spot screening protocols were considered, and the most conservative used, resulting the identification of hot spot-level contamination at one of the former dip tank locations. We have begun preparation of a DEQ staff report outlining the proposed remedy for the Dip Tank Area. The proposed remedy will consist of the following:

· Removal of sediment from catch basins and associated storm sewer lines discharging to Bear Creek.

· Excavation and off-site disposal of contaminated (hot spot) soil in the vicinity of AB-06, where a dip tank was formerly located. An estimated 200 tons of soil would be removed, followed by confirmation sampling and excavation backfilling.

· Vegetation removal and asphalt re-paving over the existing hardscape surface throughout the Dip Tank Area, with the exception of where concrete foundations are present and competent.

· Preparation of a Contaminated Media Management Plan (CMMP) to address future contaminated soil management.

· Preparation and filing of a deed restriction prohibiting the use of the property for residential or other purposes (unless risk is re-evaluated), detailing the nature and extent of residual contamination, and requirements for cap inspection and maintenance.

· Habitat enhancement in two portions of the Dip Tank Area adjoining Bear Creek.

Our plan at present is to complete the DEQ staff report by mid-August, and hold public notice from September 1 through 30. Public notice would include a public meeting or meetings at a time and place that would work for Bear Creek Recovery and interested citizenry to discuss the proposed remedial action, ideally sometime in early September. We hope to issue a Record of Decision in early October, and weather-dependent, complete the work in October. This is all on a tight schedule, and work might slip to 2018 depending on how things progress. An important element of the process is, of course, making sure that there is adequate time for public input and discussion before a remedy for the Dip Tank Area is selected. If work can be completed in 2017, it would set the stage for final site work – cleanup of Bear Creek – in 2018.

Note that I will be out of the office this coming week, but back in starting on July 24^th to answer any questions and discuss timing and location for a public meeting.

Respectfully,

Dan Hafley