Vigor-Portland_2022 MPER_2022-0228.pdf Please let me know if you have any problems with the download. From: Leake, Benjamin
Sent: Mon Nov 28 08:26:40 2022
To: HOY Ray * DEQ
Cc: LACEY David J * DEQ; ORR Jim * DEQ; Hanna, Laura
Subject: RE: Guilds Lake Yard SCE Addendum
Importance: Normal
Attachments: image001.png; image002.png; 20221128_Memorandum_EPA Comments_Guilds Lake_SCE Addendum.pdf; Microsoft Exchange Server;converted from html; Good Morning Ray, I hope you had a nice Thanksgiving. Please see the attached memo for finalized EPA comments on the Guilds Lake Yard SCE Addendum. Thanks, Ben Benjamin Leake, PMP Remedial Project Manager U.S. Environmental Protection Agency Region 10, Oregon Operations Office Office: (503) 326-2859 From: HOY Ray * DEQ <Ray.HOY@deq.oregon.gov> Sent: Monday, November 21, 2022 9:37 PM To: Leake, Benjamin <Leake.Benjamin@epa.gov> Cc: LACEY David J * DEQ <David.J.LACEY@deq.oregon.gov>; ORR Jim * DEQ <Jim.ORR@deq.oregon.gov>; Hanna, Laura <Hanna.Laura@epa.gov> Subject: RE: Vigor Industrial LLC - Updated Monitoring and Performance Evaluation Report Hi Ben, Thanks for the clarification on these items. I agree with your #7 and # 3 and think your edited comment looks good. Go ahead and prepare your finalized version. Ray Ray Hoy (he/him/his) Oregon Department of Environmental Quality NWR Clean-up Project Manager and Site Assessment Coordinator 700 NE Multnomah St., Suite #600 Portland, OR 97232 503 229-5069; 503 537-8718 cell From: Leake, Benjamin <Leake.Benjamin@epa.gov> Sent: Wednesday, November 16, 2022 5:05 PM To: HOY Ray * DEQ <Ray.HOY@deq.oregon.gov> Cc: LACEY David J * DEQ <David.J.LACEY@deq.oregon.gov>; ORR Jim * DEQ <Jim.ORR@deq.oregon.gov>; Hanna, Laura <Hanna.Laura@epa.gov> Subject: RE: Vigor Industrial LLC - Updated Monitoring and Performance Evaluation Report Hi Ray, Thanks for providing input on our comments. I agree with your suggestion on Primary comment #7. Upon reflection, it is more of a data presentation issue so I’ve moved it to TBC. I also took another look at Primary Comment #3. I do see that recent sampling of MW-42 has been non-detect for solvents. There were some modest exceedances there in 2016 (j-flagged), 2017, and 2018. The purpose of the comment was to ask for additional information on solvents, and since DEQ is planning to ask for that, I’m happy to rephrase my comment. This is what I’m proposing Section 2.4 of the SCE Addendum Report references the 2013 SCE Report conclusion that the COCs detected in groundwater are not migrating from the Site to the River. However, vinyl chloride and trichloroethene were detected at concentrations exceeding the JSCS SLVs in MW-8. MW-9 and MW-10 have not shown these same exceedances, but may not fully represent the extent of chlorinated solvents downgradient of MW-8. Provide additional empirical data and/or lines of evidence to best support this conclusion. Let me know if you have any concerns with that wording. Let me now if not too and I can finalize comments in a memo. Thanks, Ben Benjamin Leake, PMP Remedial Project Manager U.S. Environmental Protection Agency Region 10, Oregon Operations Office Office: (503) 326-2859 From: HOY Ray * DEQ <Ray.HOY@deq.oregon.gov> Sent: Wednesday, November 16, 2022 10:04 AM To: Leake, Benjamin <Leake.Benjamin@epa.gov> Cc: LACEY David J * DEQ <David.J.LACEY@deq.oregon.gov>; ORR Jim * DEQ <Jim.ORR@deq.oregon.gov> Subject: RE: Vigor Industrial LLC - Updated Monitoring and Performance Evaluation Report Ben, I’m commenting in order of progression, starting w EPA’s Primary Comments:
All TBC EPA comments DEQ agrees to keep and pass along to GL. Let me know if you have any questions
Thanks, Ray
Ray Hoy (he/him/his)
Oregon Department of Environmental Quality
NWR Clean-up Project Manager and Site Assessment Coordinator
700 NE Multnomah St., Suite #600
Portland, OR 97232
503 229-5069; 503 537-8718 cell
From: Leake, Benjamin <Leake.Benjamin@epa.gov>
Sent: Wednesday, April 13, 2022 3:24 PM
To: HOY Ray * DEQ <Ray.HOY@deq.oregon.gov>
Cc: LACEY David J * DEQ <David.J.LACEY@deq.oregon.gov>
Subject: RE: Vigor Industrial LLC - Updated Monitoring and Performance Evaluation Report
Hi Ray,
EPA reviewed the Vigor MPER report transmitted below and have prepared the attached draft comments. Please take a look at these and let me know if you’d like to discuss in any more detail prior to finalizing.
I think an approach similar to last year, where Vigor responded to DEQ and EPA comments rather than revising the MPER, seems reasonable. We have several comments that could be incorporated into a revision, if they were going to revise, but I would also be satisfied knowing that they would carry them forward to the next iteration of the report.
I didn’t make any distinction like that in the front matter of these comments, but am happy to once you decide which route you plan to go.
Thanks!
Ben
Benjamin Leake, PMP
Remedial Project Manager
U.S. Environmental Protection Agency
Region 10, Oregon Operations Office
Office: (503) 326-2859
From: Kate Snider <Kate.Snider@floydsnider.com>
Sent: Monday, February 28, 2022 9:24 AM
Cc: david.j.lacey@deq.state.or.us; Leake, Benjamin <Leake.Benjamin@epa.gov>; kathy.balogh@portlandoregon.gov; Alan Sprott (Alan.Sprott@vigor.net) <Alan.Sprott@vigor.net>; Gordon Erickson <Gordon.Erickson@vigor.net>; Adia Jumper <Adia.Jumper@floydsnider.com>
Subject: Vigor Industrial LLC - Updated Monitoring and Performance Evaluation Report
Hello Ray –
PLEASE CONFIRM RECEIPT.
In accordance with the Order on Consent issued by ODEQ, DEQ No. OPV-NWR-16-05, dated December 19, 2016, we are submitting the 2022 Monitoring and Performance Evaluation Report (2022 MPER) prepared by Floyd|Snider on behalf of Vigor Industrial LLC (Vigor) for its Portland facility, located at 5555 North Channel Avenue in Portland, Oregon. This report has been prepared in accordance with the Order on Consent and the 2020 Source Control Measures Monitoring Plan, as presented in Appendix G of the 2020 Revised Monitoring and Performance Evaluation Report.
The 2022 MPER can be downloaded from this link: Vigor-Portland_2022 MPER_2022-0228.pdf Please let me know if you have any problems with the download.
This electronic report transmittal satisfies the requirements in the Order on Consent. Additionally, two hard copies of the 2022 MPER will be sent to you by mail later this week.
I am submitting the report as your new primary point of contact at Floyd|Snider. Consistent with the email that Corey Wilson sent to you on February 16, unfortunately Corey is no longer with Floyd|Snider, as he has taken a position with Vulcan Real Estate in Seattle. Our team will provide continuity in consulting services for Vigor – and I will be your point of contact going forward.
I would like to request a virtual meeting with you, Ray, to introduce myself and walk through this 2022 MPER and review its conclusions. My assumption is that this would be helpful to you in your review. Please let me know your availability for such a meeting between March 7-18.
The 2022 MPER concludes that no further contingency SCMs are needed for the Group N-Series, Group M, Group Pier C, Group Pier D, and Group P - the weight of evidence evaluations for these basins determined that all appropriate and reasonable stormwater SCMs have been implemented to prevent sediment recontamination and unacceptable risk to in-water receptors from stormwater.
In addition, as presented in the report, Vigor is completing construction of Phase I stormwater infrastructure improvements in Groups G and M1 and completing design of Phase II stormwater infrastructure improvements for Group LD1-B. The Phase I and Phase II contingency SCMs will send approximately 20.6 additional acres to the existing detention tanks and EC system. Phase I completion is targeted for June 2022. Phase II completion is targeted for December 2023. We will continue to provide project updates in quarterly progress reports.
We look forward to meeting with you soon to review this material.
All best,
Kate
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