"file:///C:From: Jennifer Cline
Sent: Thu Apr 23 16:16:36 2015
To: Nicolas Lennartz
Subject: FW: Speaking points from last night
Importance: Normal
FYI
Jennifer Cline, P.E.
City of Molalla
Public Works Director
O: 503.759.0218
F: 503.829.3676
From: YELTON-BRAM Tiffany [mailto:YELTON-Bram.Tiffany@deq.state.or.us]
Sent: Thursday, April 23, 2015 4:12 PM
To: 'dhuff@cityofmolalla.com'; Jennifer Cline
Cc: HAFLEY Dan; DECONCINI Nina; WILLIAMS Karen
Subject: Speaking points from last night
Hello Dan and Jennifer
We did not walk through all of these last night but they are a nice summary of our interactions on TMDL implementation and the two cleanup sites. I thought you might like to have this information.
Floragon Forest Products site
· Located west of N. Molalla Avenue near downtown, with the property straddling Bear Creek.
· 100+ acre property where sawmills formerly operated, starting in the 1940s.
· Comprehensive soil, groundwater, and sediment investigation completed from 1980s to present.
· Chemicals including petroleum and metals found in soil, generally at low to moderate levels. Dioxins detected in soil and Bear Creek sediment near former dip tanks in southern site.
· DEQ has determined that contamination does not pose a risk to local residents.
· After localized cleanup of site ditches, DEQ issued a No Further Action determination for the northern 88 acres of the site in 2014.
· DEQ is considering a conditional NFA for the 16-acre SE Corner, which includes two large (vacant) industrial buildings. This would require capping a small area where dioxins exceed DEQ standards for industrial use.
· Investigation has identified elevated dioxins in a segment of Bear Creek near the former dip tank areas. A plan is in development for removal and restoration of the ditch segment, which require approval from Oregon DSL and the US ACOE. Work would occur in fall 2015 or 2016.
· The final area of concern is the former dip tank area, where dioxins are elevated in soil. The area is paved, so exposure risk is limited. A long term solution will be either removal or capping of contaminated soil.
· Updated fact sheets will be posted on DEQ’s website, and public comment solicited on remedy decision-making.
Former Avison Lumber (Mill #1)
· Located east of N. Molalla Avenue near downtown, north of Bear Creek and south of 5th Street.
· 54-acre property where sawmill formerly operated.
· Comprehensive soil, groundwater, and sediment investigation completed from 1980s to present.
· Chemicals including petroleum and chlorophenols found in soil and groundwater, primarily in the northern site near the former dip tanks. Soil removal actions completed in the 1985 and 1998 to address contamination near tanks. Groundwater contamination determined to be localized which does pose a risk or require action.
· In later investigation under DEQ (2000s) dioxins were detected in both the northern and southern site, the apparent source being dip tank operations. Contaminants migrated to the southern site via stormwater in drainage ditches. Dioxin sampling on adjacent residential properties determined that there is not a risk to residents.
· A remedy was selected by DEQ for the 25-acre northern site in 2008, consisting of capping that would be completed with site development. Temporary capping of the most significant contamination near the former dip tanks has occurred, with access limited by fencing. Final site development is pending.
· The southern site, while formerly used for agriculture, has been vacant for a number of years and includes wetlands. A low area containing elevated dioxins requires action, likely removal and/or capping. Wetland restoration/enhancement would be necessary. A segment of Bear Creek may require action.
· The boundaries of South Parcel remediation are currently being discussed. Work will require permitting (DSL and US ACOE) because of the presence of wetlands. Expected to occur in late 2015 or 2016.
·
Talking Points Plus –TMDL and NonPoint Source
City of Molalla –April 22nd
· What is a TMDL?
A Total Maximum Daily Load is an amount of a pollutant, like bacteria or solar heating, that a water body can assimilate and still meet water quality standards. For example, the Molalla River can receive a certain amount of solar radiation (heat) and still meet the temperature standard that protects spawning and rearing fish. Sources of heat to the river, other than permitted sources like treated wastewater, mainly come from lack of shade-producing vegetation and widening of the stream channel. Another example would be bacteria – the Molalla River can accept a certain amount of bacteria and still meet the water quality standard that protects people who have recreational contact with the water. Sources of bacteria include natural sources like wildlife, as well as eroded sediments from streambanks, runoff from agricultural fields, and urban stormwater.
· What is the City of Molalla's role/obligation/expectation under the TMDL?
The city is obligated to submit a plan that details how the city will reduce its sources of stream heating, bacteria, mercury, pesticides and iron, and to make a good faith effort to implement that plan and monitor its effectiveness. The city must also submit annual progress reports with a more comprehensive evaluation report every five years. The city must revise the implementation plan periodically if the city finds that the strategies outlined in the plan are not sufficient to reduce the city’s input of pollutants to the Molalla and Pudding Rivers and their tributaries.
· What is City of Molalla doing to demonstrate they are in compliance with their TMDL obligations (strategies/reporting requirements)?
The City is working with DEQ to comply with their municipal wastewater treatment plant permit. The city has submitted the beginning of a TMDL implementation plan by sending a cover letter in February 2012 acknowledging that they would implement the strategies and measures outlined in a table DEQ sent to the City of Molalla in October 2011. The city submitted a 2014 annual status report in December 2014. The 2014 status report indicates the city is:
· Mapping their stormwater system with a geographic information system
· Enforcing erosion control on new development sites with more than 50 cubic yards of soil added, removed or disturbed.
· Conducting an inflow and infiltration investigation
· Sweeping streets weekly
· Planting 40 new trees in city parks
· Measuring Molalla River temperature
· Establishing timelines with homeowners on newly annexed property to connect to city sewer
· Financially partnering with watershed groups working on restoration
· What is DEQ expecting moving forward?
DEQ has asked the city to submit additional information for the 2014 status report relating to strategies to reduce stream temperature. DEQ expects the city will submit a five year evaluation report by June 30, 2105 and a revised implementation plan by December 31, 2015.
Tiffany Yelton Bram
WQ Source Control Manager
Oregon Department of Environmental Quality
2020 SW 4th Ave., Suite 150
Portland OR 97201
Desk 503 229 5219
Mobile 503 975 0046
This spring, DEQ's Northwest Region Office will be moving to a new location - the 700 Lloyd Building at 700 NE Multnomah St., Suite #600, Portland, OR 97232. The target date for operating at the new location is May 18th, 2015.