Response to Comments Provided by Oregon Department of Environmental Quality for Dickson Site, Tigard 2-6-17

Feb 6

To: 'Tom Price'

CC: DANA Kevin

Mr. Price,

The Oregon Department of Environmental Quality received your comments on the proposed Conditional No Further Action determination for the Dickson Property in Tigard, Oregon. Your comments were incorporated into the “Staff Closure Memo” for the project, which can be accessed via the following web page:

http://www.deq.state.or.us/Webdocs/Forms/Output/FPController.ashx?SourceId=5929&SourceIdType=11

Specifically, we added additional information on the local groundwater to Page 2 of the memo to better explain the risks to groundwater. We also noted and responded to your comments on Page 7 of the memo.

We thank you for your comments and appreciate your interest in assuring that the project addressed all potential long-term risks to public health and the environment.

Kevin Dana

Cleanup Project Manager

Oregon Department of Environmental Quality

Northwest Region Office

700 NE Multnomah St., Suite 600

Portland, OR 97232-4100

Phone: (503) 229-5369

From: Tom Price [mailto:envtest@yahoo.com]
Sent: Sunday, February 05, 2017
To: DANA Kevin
Subject: Proposed Cleanup for Dickson Property Development, Tigard

Dear Mr. Dana:

I provided comments on11-1-16 for the project, I didn't hear back, please let me know if you issued a response to comments. Please send to me if available.

Sincerely yours, Electronic Review for the Environment, Inc., By: Tom Price, Director, P.O. Box 2756, Berkeley, CA 94702

www.envreview.org

Thomas Price <envtest@yahoo.com>

11/01/16

To: dana.kevin@deq.state.or.us

Dear Mr. Dana:

ELECTRONIC REVIEW FOR THE ENVIRONMENT, INC. has reviewed the summary information related for the proposed project and has the following comments:

1) The consolidation area is described as containing 10,400 cubic yards of pesticide-contaminated soil with up to 0.339 ppm DDE, 0.0898 ppm DDT, and 0.462 dieldrin which has a "geomembrane" fabric placed on top of it and covered with several feet of "clean" soil to prevent dermal contact. Since the cap of the consolidation as described does not appear to be impermeable to water, rainwater can reasonably be expected to seep through the contaminated soils and the contaminants can reasonably be expected to leach and impact groundwater resources. Was leaching of contaminants to groundwater considered? One possible solution would be to construct an impermeable cap over the consolidation area to prevent rainwater intrusion. The cap would need to be maintained and inspected periodically and a financial assurance mechanism would be needed for replacement of the cap after it got worn out. If an impermeable cap is not constructed, groundwater should be monitored.

2) Please require a revised document and another public comment period which addresses this issue.

Sincerely yours,

ELECTRONIC REVIEW FOR THE ENVIRONMENT, INC.

By: Tom Price

P.O. Box 2756

Berkeley, CA 94702