From: Susan Hansen
Sent: Fri Jun 09 11:00:08 2017
To: HAFLEY Dan; DECONCINI Nina
Subject: FW: Floragon Dip Tank Area
Importance: Normal
Attachments: 1177 20170606 FFS Rpt.pdf; Dear Dan and Nina, To follow up on the phone call I just made to Dan (I left a message), we would like to see the two rules about dioxon referenced in the mitigation proposal. The consultant says that something changed but that DEQ is allowing them to use the old rule or standard. Why? We know this has lingered for THREE DECADES with no mitigation and now DEQ will allow what is likely a lesser mitigation based on lower standards? To claim lesser standards can be used is an insult to those of us who have questioned why no progress was made for THREE DECADES. This "project" should have to conform to the highest current standards. Please furnish the "old" and "new" standards so we can send our comments in protest of allowing this to as usual revert to the lowest standard possible. Susan Hansen Bear Creek Recovery -----Original Message----- From: dan.hafley@state.or.us Sent: Wed, 7 Jun 2017 20:20:40 +0000 To: foxglovefarm@inbox.com Subject: Floragon Dip Tank Area Susan – We just received a Feasibility Study (cleanup proposal) for the Dip Tank Area portion of the Floragon site. The document outlines a number of potential cleanup options to address dioxin contamination in shallow soil beneath existing paving. Cleanup options evaluated in the document include: a) removal of the highest levels of contaminated soil at the former dip tank locations, and augmenting existing paving in remaining areas; and b) complete removal and landfill disposal of contaminated soil. At the request of DEQ, cleanup options include habitat enhancement at two locations adjacent to Bear Creek. Habitat restoration, of course, will be an element of the future Bear Creek cleanup work independent of the Dip Tank Area cleanup. Work proposed by Avison representatives is a combination of soil removal, asphalt capping, and habitat enhancement adjacent to the creek. The “full removal” option is not recommended by Avison based on a variety of factors, , including the fact that contamination outside of the dip tank locations is not highly concentrated and is covered by existing paving, Existing paving would be augmented with an additional 2” of new asphalt, storm drains cleaned out, etc. As we have previously discussed, Dip Tank Area cleanup needs to proceed before Bear Creek work, to ensure that recontamination of the creek does not occur. We are hoping to complete Dip Tank Area work in late summer, which would set up final site work –Bear Creek cleanup – in summer 2018. Our review of the cleanup proposal will begin ASAP, and we hope to complete work this summer. I have attached a copy of the Feasibility Study for your consideration, and would point you to Section 9 (page 25) of the document which outlines the cleanup option recommended by Avison’s consultant. DEQ will review the document and identify a proposed cleanup action. After that, we plan to hold a public meeting in Molalla to discuss the proposed remedy, answer questions, and receive input before making a final cleanup decision. Hopefully this can all be done in time to complete Dip Tank Area cleanup in late September or early October before weather prevents work. At this point we are thinking about an early August public meeting, likely to be held at the library, coinciding with the start of a public comment period for the proposed remedy. We would be happy to work with you on arranging a meeting space, and will plan to prepare a press release and prepare meeting information for publication in the Molalla Pioneer. You thoughts are welcome. Respectfully, Daniel J Hafley, RG Senior Project Manager/Hydrogeologist Northwest Region Cleanup Section Oregon DEQ (503) 229-5417