From: Leake, Benjamin

Sent: Wed Apr 13 15:23:51 2022

To: HOY Ray * DEQ

Cc: LACEY David J * DEQ

Subject: RE: Vigor Industrial LLC - Updated Monitoring and Performance Evaluation Report

Importance: Normal

Attachments: image001.png; image002.png; 2022.04.13_Vigor_2022 MPER_DRAFT EPA Comments.pdf;

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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

To: ray.hoy@deq.state.or.us

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