From: Susan Hansen
Sent: Mon Jul 17 12:56:00 2017
To: HAFLEY Dan
Cc: GRABHAM Cheryl; 'POULSEN Mike'; DECONCINI Nina; SEIDEL Paul
Subject: RE: Floragon Dip Tank Area
Importance: Normal
Dear DEQ,
Could you clarify if this is only about cleanup on the Floragon brownfield? It is Bear Creek Recovery's understanding that Bear Creek is contaminated on the east side of Molalla Ave - i.e. on the Avison Mill One brownfield as well as on Floragon. If this is only going to address the contamination in the creek on Floragon, what is to prevent dioxin contamination from continuing via the upstream contamination from Avison Mill One brownfield? Is any mitigation being planned for the upstream part of Bear Creek to match the Floragon effort and if not why not?
Susan Hansen
Bear Creek Recovery
-----Original Message-----
From: dan.hafley@state.or.us
Sent: Fri, 14 Jul 2017 22:10:55 +0000
To: foxglovefarm@inbox.com
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 24th to answer any questions and discuss timing and location for a public meeting.
Respectfully,
Dan Hafley