December 30, 2011
David Johnson
Peninsula Iron Works
6618 N. Alta Avenue
Portland, OR 97203
RE: Portland Harbor Source Control Evaluation at Peninsula Iron Works property at 6618 N. Alta Avenue
Dear Mr. Johnson,
The Department of Environmental Quality (DEQ) Cleanup Program, Portland Harbor Section conducted a review of file information and related studies for parcels owned by Peninsula Iron Works at 6618 N. Alta Avenue in Portland, Oregon, and determined that further assessment of the potential transport pathways of contaminants from your facility to the river is needed.
The file review was performed under Oregon’s Environmental Cleanup Law Oregon Revised Statutes (ORS) 465.245 and under an agreement DEQ entered into with the U.S. Environmental Protection Agency (EPA) in 2001. That agreement assigned DEQ the responsibility for controlling current and future upland discharges threatening the Portland Harbor Superfund site. The purpose of DEQ’s work is to identify, evaluate, and control upland sources of contamination so those sources do not pose unacceptable risk to receptors in the river or a recontamination threat to future in-river cleanup actions.
The process for controlling these sources is detailed in the EPA/DEQ Joint Source Control Strategy1 (JSCS). The JSCS calls for DEQ to identify, evaluate, and control sources of contamination that may impact the Willamette River in a manner that is consistent with the objectives and schedule for the Portland Harbor Superfund site remedial investigation and feasibility study.
To implement this strategy, DEQ is currently working with many property owners in the Portland Harbor area to take immediate measures to ensure stormwater discharges, groundwater discharges, bank erosion and other potential contaminant pathways are adequately characterized and controlled to prevent contamination of the river. In many cases, this work will go beyond existing applicable discharge permit requirements2 that may exist at a site.
DEQ recently reviewed sediment data collected in the vicinity of your facility and, based upon elevated concentrations of Portland Harbor contaminants of concern in the sediments, determined that source control evaluations will be needed at several upland facilities and City stormwater outfalls discharging into this area.
DEQ requests that you enter into an agreement with our Voluntary Cleanup Program to undertake a remedial investigation and, if necessary, source control measures to ensure any discharges from your site to the river are managed to prevent or reduce the amount of contaminants getting into the river. Enclosed are two copies of the Voluntary Cleanup Agreement to cover the costs of DEQ’s review of investigation and/or cleanup activities performed for Peninsula Iron Works, and any additional investigation/cleanup activities that may need to be performed. To initiate this agreement, you will need to sign both copies and return one copy and the $5,000 deposit check made payable to the Department of Environmental Quality.
Please respond to this request by January 31, 2012. If we do not receive a reply by that date, DEQ will consider exercising our authority to issue an order for conducting a source control investigation.
Please contact me at 503-229-6825, if you have any questions or would like to meet to discuss the Voluntary Cleanup oversight process. We look forward to working with you.
Sincerely,
Jim Anderson, Manager
Portland Harbor Section
cc: Keith Johnson, DEQ NWR Cleanup & Site Assessment Manager
Alex Liverman, DEQ Portland Harbor Stormwater Coordinator
Attachments:
Portland Harbor Agreement and Statement of Work (2 copies)