From: Susan Hansen
Sent: Wed Jul 19 08:41:39 2017
To: SEIDEL Paul
Cc: HAFLEY Dan; POULSEN Mike; DECONCINI Nina
Subject: RE: Floragon Dip Tank Area
Importance: Normal
Mr. Seidel,
My group Bear Creek Recovery is interested in it all - after all, it has been about THREE DECADES that DEQ has allowed dioxin to exist in our environment. We advocate for total mitigation and we find it beyond belief it has taken THREE DECADES to come up with even a faint hope of a plan.
Susan Hansen
Bear Creek Recovery
-----Original Message-----
From: paul.seidel@state.or.us
Sent: Wed, 19 Jul 2017 15:37:55 +0000
To: foxglovefarm@inbox.com
Subject: RE: Floragon Dip Tank Area
Ms. Hansen-
Thank you for the clarification. I see now that you are interested in the specifics of Bear Creek cleanup locations rather than sequencing of upland and in water project elements. I will need to wait for Dan to respond to this question on his return next week.
Respectfully,
Paul Seidel
Acting Manager, Northwest Region Cleanup Program
Oregon Department of Environmental Quality
700 NE Multnomah Street, Suite 600
Portland, OR 97232
503-229-5614
From: Susan Hansen [mailto:foxglovefarm@inbox.com]
Sent: Tuesday, July 18, 2017 5:30 PM
To: SEIDEL Paul <paul.seidel@state.or.us>
Subject: RE: Floragon Dip Tank Area
Hi,
When you say clean up of Bear Creek is proposed for next year, do you mean all of Bear Creek on both sides of S. Molalla Ave, where Avison Mill One contaminated the creek on the east side of S. Molalla Ave and the Floragon part on the west side of the road? Again, there is no point in cleaning up on side of the creek if the upstream part is still going to be contaminated. Susan
-----Original Message-----
From: paul.seidel@state.or.us
Sent: Tue, 18 Jul 2017 23:34:00 +0000
Subject: Floragon Dip Tank Area
Ms. Hansen –
Dan Hafley is out on leave this week, and he can provide you a more detailed response on his return, if needed. The DEQ team has explained that the proposed remedy is only for the dip tank area. This is the location where Dan indicates 200 tons of soil will be removed in his July 14, 2017 email (include below for reference). DEQ’s usual approach is to address contamination in source areas with higher levels to avoid potential recontamination by sites that drain to rivers, creeks, or wetlands. This is the case at Bear Creek. If we are able complete cleanup of the dip tank area this year, cleanup of Bear Creek will be planned for next year. If I have not addressed your question, or perhaps misunderstood, please let us know and will work to ensure we get you the information you are looking for.
We do not yet have detailed plans yet for the forthcoming Bear Creek cleanup, however, Dan can provide as much detail as is available on his return the week of the 24th. Thank you for your continued interest in this project.
Respectfully,
Paul Seidel
Acting Manager, Northwest Region Cleanup Program
Oregon Department of Environmental Quality
700 NE Multnomah Street, Suite 600
Portland, OR 97232
503-229-5614
From: Susan Hansen [mailto:foxglovefarm@inbox.com]
Sent: Monday, July 17, 2017 12:56 PM
To: HAFLEY Dan <dan.hafley@state.or.us>
Cc: GRABHAM Cheryl <cheryl.grabham@state.or.us>; 'POULSEN Mike' <mike.poulsen@state.or.us>; DECONCINI Nina <nina.deconcini@state.or.us>; SEIDEL Paul <paul.seidel@state.or.us>
Subject: RE: Floragon Dip Tank Area
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
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