From: SEIDEL Paul

Sent: Wed Aug 10 17:05:17 2016

To: Margaret Townsend; 'Kerry Rea'

Cc: William E. Gaar (weg@buckley-law.com); MANZANO Scott; WILLIAMS Robert K

Subject: Groundwater Investigation Work

Importance: Normal

Attachments: NextSteps.pdf;

Dear Margaret-

This email is a follow-up to our conversation of July 14^th, 2016. In particular, I followed up on your comment regarding ethylene dibromide (EDB) in groundwater. I understood from your comment that you were under the impression that the issue was addressed or resolved. To be absolutely certain, I checked the administrative record for the site, and there is nothing in the file that would indicate that DEQ concern regarding groundwater is resolved. Moreover, I have not received anything that would address the issue. You may be referring to a letter prepared by Rapid Soil Solutions, LLC prepared for Townsend Farms, dated 26 August, 2015. This letter discusses EDB detections in the Townsends Farms well. However, the discussion in this letter is not sufficient to address DEQs concerns with groundwater. Per our 2007 agreement, DEQ must agree with the findings and scope of work. I would encourage you to have your consultant meet with DEQ to define an appropriate scope of work to address the issue.

DEQ and Townsend Farms, Inc (TFI) have successfully worked together to complete the PPA for the former lot 11, and manage surface soils in the interim soil repository on lot 6. As described in our letter of March 16, 2016 (attached for convenience) DEQs interest is in proceeding on the remaining project elements, particularly groundwater. I would like to note these issues do not seem excessively complex, and if resolved could result substantial progress toward no further action (NFA) determination for the remaining site. However, as it is, without progress on the groundwater issue, it is unlikely the DEQ will participate in future PPAs.

Paul Seidel

Oregon Department of Environmental Quality

Northwest Region Cleanup

700 NE Multnomah Street, Suite 600,

Portland, OR 97232

Office: (503) 229-5614

Fax: (503) 229-6899

Email: seidel.paul@state.or.us