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Environmental Cleanup Site Information (ECSI) Database Site Summary Report - Details for Site ID 9, Floragon Forest Products Molalla - Town Mill

This report shows data entered as of June 19, 2018 at 10:40:52 AM

This report contains site details, organized into the following sections: 1) Site Photos (appears only if the site has photos); 2) General Site Information; 3) Site Characteristics; 4) Substance Contamination Information; 5) Investigative, Remedial and Administrative Actions; and 6) Site Environmental Controls (i.e., institutional or engineering controls; appears only if DEQ has applied one or more such controls to the site).  A key to certain acronyms and terms used in the report appears at the bottom of the page.

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Environmental Cleanup Site Information (ECSI) Database Site Summary Report - Details for Site ID 9, Floragon Forest Products Molalla - Town Mill

Site Photos
Click to View Photo Picture Date Caption Size
View Photo 11/09/2005 Avison Lumber - West Side Mills site location and area of historic operations in Molalla, Oregon. 86 Kb
View Photo 11/09/2005 1972 Aerial photograph of Avison Lumber - West Side Mills site. 43 Kb

General Site Information

Site ID: 9 Site Name: Floragon Forest Products Molalla - Town Mill CERCLIS No: 009045261
Address: 7th St. and S Molalla Ave. & Molalla Forest Rd. Molalla 97038
  County: Clackamas Region: Northwest
Other location information: The former Avison Lumber mills #4 and #5, currently owned by Floragon Forest Products, are located near the intersection of S. Molalla Avenue and S. Molalla Forest road in Molalla, Oregon. The site is situated west of S. Molalla Avenue, and straddles Bear Creek.
Investigation Status: Listed on CRL or Inventory
Brownfield Site: No NPL Site: No Orphan Site: No Study Area: No
Property: Twnshp/Range/Sect: 5S , 2E , 8 Tax Lots: multiple
  Latitude: 45.1413 deg. Longitude: -122.5838 deg.  Site Size: 111 acres
Other Site Names:
  Floragon Forest Products - Molalla (FFPM)
  Avison Lumber - Mills #4 & 5
  Avison Town Mill
  Avison Lumber - West Side Mills

Site Characteristics

General Site Description:
Site History: (11/9/05, CWH/SAP) The file material that is available for review at DEQ typically addresses the Avison Lumber mill business for historic operations that occurred on both sides of Molalla Avenue. Avison Mill #1 (ECSI #4014) is located in the vicinity of East 5th and Lola streets and, as of the date of this report, is currently active in DEQ’s Voluntary Cleanup Program (VCP).

The historic Avison West Side Mills operations, west of Molalla Avenue include former mills numbered #2, #4, and #5; resaw buildings #2 and #3; planers numbered #1, #2, and #3; kilns numbered #1, #2 and #3; the stacker building; the abandoned and encapsulated dip tanks; an area where an old log pond was once located; storage sheds; the Hyster shop; a glue laminating facility; and a sales office.

Crown-Zellerbach reportedly operated the mills from the late 1930s until they were purchased by Avison Lumber in 1956. There is limited file information on the Crown-Zellerbach operations, and the east and west side mills were not included in any available Sanborn Insurance maps (1921-1951). However, based on the USGS 7.5 Molalla topographic map dated 1954 (revised 1985), it appears that the Crown-Zellerbach operations were most likely at or near Mill #1 (ECSI #4014) on the east side and Mill #2 on the west side. It is also possible that the Avison operations were built over former Crown-Zellerbach buildings.

Floragon Forest Products, Inc. bought the Avison West Side Mills properties from Avison in 1998. Most site buildings have been dismantled, with only two former glue-lam buildings in the southern site remaining.

As of November 2011, site activity was confimed to a log storage and chipping operation in the northern site.

In March 2014, the southern portion of the site (Southern Parcels) remained vacant while a portion of the northern site (Northern Parcels) were partially occupied by log storage and chipping operations (Tillamook Fiber).
Contamination Information: Site formerly contained anti-sapstaining dip tanks containing pentachlorophenol (PCP). During investigation work completed by EPA, DEQ, and others in the 1980s and 1990s, PCP was detected in soil and water in dip tank vicinity, and in dip tank sludge samples. Dioxins were also detected.

In a 1983 BeaK Consultants investigation for Avison, PCP was detected at 50, 847 ug/L in a water samples collected from location SW8 in Bear Creek, downstream of the Mill #4 and #5 dip tanks. At the same location, 2,3,4,6-TCP was detected at 337,035 ug/L. High levels of PCP and TCP were also detected in soil samples collected near former dip tanks (location A2), and an "Off Travel Road" where PCP was detected at 1,186,020 ug/kg at location B1.

In a 1985 investigation completed by Radian for EPA's Office of Solid Waste, numerous samples were collected from sediment, soil, water, and dip tank sludge and analyzed for dioxin isomers. Numerous dioxin isomers were detected at low levels; EPA subsequently determined that, using a toxicity equivalence approach, detected levels were below the CDC action level (at the time) of 1 ug/kg 2,3,7,8-TCDD (for residential soil). It is unclear if impacts to ecological receptors were evaluated.

Hyster Shop Building: During an off-site survey of the site in May 2005, DEQ observed significant staining on the northeast corner of the Hyster shop building and around a grate in that area. The area near the grate is where steam-cleaning of mill trucks and equipment was performed. DEQ discussed some of their observations with Floragon’s consultant in May of 2005, who stated that the grate is an oil/water separator which is connected to the storm system – but such a connection has not been verified. Containers of various products including hydraulic oil were observed in the northwest corner of the Hyster shop. In addition, DEQ observed in a color (undated) aerial photograph of the property (believed to be from late 80s or early 90s) dark soil/gravel staining directly east of the Hyster shop in an area that is now paved. Based on the observations and historic use of the Hyster shop, this area presents a potential source of petroleum hydrocarbon contamination.

Drum storage area: During a May 2005 off-site survey DEQ observed several drums near a small building just south of the Hyster shop. No identifying marks were on the drums and they several appeared to be slightly damaged.

Mills #4 & #5: According to the “Description of Operations” on the Floragon website (no longer in existence), Mill #4 was a true “cutting” mill for processing large logs while Mill #5 processed smaller to medium sized logs and also went through a “very significant and expensive computer upgrade.” In addition, “a glue laminating facility was constructed in 1997, which consists of a finger jointer line, a radio frequency beam press and two cold set press lines with the capacity to produce engineered lumber and beams up to 72 feet in length.” And according to an April 22, 2005 article in the Molalla Pioneer, a glue lamination facility signed an agreement to lease Floragon’s “vacant mill near Molalla’s downtown” for production of “glulam construction beams and garage door headers.” The two former mill operations present potential sources of petroleum hydrocarbon and semi-volatile organic compound (SVOC) contamination.

Manner and Time of Release: Spills from dip tank; past operating practices (1978-1986).
Hazardous Substances/Waste Types: pentachlorophenol, tetrachlorophenol, dioxins, TPH, metals
Pathways: Surface Water- The nearest surface water is Bear Creek, which enters the site from the east and flows in a westerly direction through the southeast corner of the site. Bear Creek is a tributary of the Pudding River, which in turn enters the Molalla River near its mouth at the Willamette River. The Pudding River is listed as rearing and migration habitat for coho and spring-run chinook salmon, and winter steelhead and is cited as habitat for Pacific Lamprey. Chinook salmon and Steelhead are listed as a Federal threatened species. Coho salmon are listed by Oregon as a state endangered species and as a Federal species of special concern. Pacific Lampreys are listed as an Oregon State species of concern.

There are several drainage ditches running through the site or along the roadways adjacent to the site that empty into Bear Creek. Given the past documented history of detections of PCP and TCP in Bear Creek attributed to the site; existence or extent of any other contaminants such as petroleum or metals from the site; existing drainage pathways for site runoff to enter Bear Creek; and the unknown extent of existing soil and groundwater contamination on the site from past operations, there may be historic and ongoing impacts to Bear Creek from this site.

Update - 2011

Primary concern is exposure of site occupants and ecological receptors to dip tank area soil and sediment within Bear Creek on the site. Trespasser analysis by DEQ has shown that there is no significant risk associated with short-term exposure to site contamination.

Soil – Soil contaminated with wood-treating chemicals was documented by DEQ during the 1980s and, based on areas of staining observed by DEQ during 2005, it is also likely on-site soils are impacted by petroleum products. Past soil sampling showed extremely high concentrations of PCP, 2,3,4,5-TCP, 2,3,4,6-TCP, and 2,3,5,6-TCP in soils, with the highest being near the dip tank area where the investigation was primarily focused.

Site contamination from PCP and TCP congeners was shown to be present far beyond the dip tank area. The 1983 detection of PCP and TCP in the drainage ditch sediment and surface water in a ditch (sample E3) in the northwest corner and north areas, respectively, of the operation clearly shows that these chemicals were widespread across the site. Historic site remedial actions only addressed the worst areas of contamination and evaluation of potential soil impacts across the entire site has never been adequately completed.

Much of the site is paved, fenced, and posted with “no trespassing” signs; however, direct contact with hazardous substances in exposed areas of soil by on-site workers or future construction workers is a pathway of concern for the site.

Groundwater – The site lies above two aquifers that are separated by an “aquitard comprised of Troutdale conglomerate”. Depth to groundwater in the upper or water table aquifer is very shallow and serves as recharge to the Bear Creek. The confined aquifer is approximately 40 feet BGS. Properties within the City of Molalla are supplied city water from the Molalla River; however, there are approximately 333 private domestic wells within 1.5 to 2.0 miles of the site.

In the 1987 PA documents DEQ personnel noted that there was little to very low potential for contamination of deeper confined drinking water aquifers from PCP, TCP and dioxin compounds (J. Broad memo dated December 7, 1987). This view was due to the higher pressures of the confined aquifers and monitoring results from groundwater wells in the vicinity of the main area of known PCP/TCP contamination. Nonetheless, PCP was detected in at least one nearby well during the 1980 investigations.

The closest wells are located less than 0.5 miles away, to the south of the site, in an area of rural residential properties. Given that a complete analysis of all potential site contaminants has not been completed and the high density of domestic water supply wells in the area, groundwater remains a pathway of concern for this site.

Air – Since there are still some industrial activities occurring on the property, occupational workers are present on the site. Residential homes are located along the northeast corner and east side of the site. Since much of the site is not active at the moment and is within the City of Molalla’s urban growth boundary, future development for commercial and/or residential is likely. Any future development activity would present a dust inhalation exposure pathway to construction workers.

Given that a complete analysis of all potential site contaminants has not been completed the potential for inhalation of contaminated dust is a pathway of concern and further analysis is needed to address this exposure pathway.

2014 Update. Site characterization has been completed at the site, and a NFA issued for the Northern Parcels on March 4, 2014. A Level III Human and Ecological Risk Assessment is ongoing for the Southern Parcels which includes Bear Creek. Remedial action in the Southern Parcels is considered likely.
Environmental/Health Threats: March 2014

Northern Parcels - no threat based on current and likely future use for industrial or commercial purposes.

Southern Parcels including Bear Creek - elevated contaminants in soil and sediment represent potential risk to site users and wildlife. Results from Level III Risk Assessment pending.
Status of Investigative or Remedial Action: (1/10/94 KPD/SAS) Site Assessment recommends additional confirmation sampling to ensure that PCP and TCP are no longer present on the site in hazardous concentrations.

(6/5/01 DH/VCP) During VCP review of site files for adjoining Avison Mill #1 site (ECSI #4014), DEQ concluded that release of contaminants at Mills #4 and #5 had occurred, and contamination issues had not been fully investigated or resolved. The Mill #4 and #5 site was therefore referred to DEQ's Site Assessment program for further action under a medium to high priority.

(10/26/05 CWH/SAP) In January 2003, DEQ proposed the Mill #1 site (east of Molalla Avenue) for listing on the State’s Confirmed Release List (CRL) and Inventory. At that time, the CRL/Inventory listing letters identified the Mill #1 site as being DEQ ECSI site # 9. The 2003 CRL/Inventory listing was specifically intended to address known contamination at the Mill #1 site and not the West Side mill operations. As noted earlier, in November 2003, DEQ officially recognized the two sites as being separate and created a new clean-up site designation for the Mill #1 site, making it ECSI site #4014. As part of this work, DEQ’s files and ECSI database will be revised to accurately reflect DEQ’s listing actions for both sites.

(11/9/05 CWH/SAP) DEQ completed a Preliminary Assessment (PA) for the EPA in 1987 and EPA completed a Site Inspection (SI) in 1988. The EPA SI, performed by Ecology and Environment, Inc., collected nine groundwater, two surface water, one soil and three sediment samples and tested the samples for base/neutral/acid (BNA) extractable compounds and dioxin/furan homologs. The EPA SI concluded that the “site exhibits a low potential for any environmental or public health impact.” This conclusion was based on site investigation measurements of groundwater, soil, surface waters and sediments that showed no hazardous materials were detected at or above the detection limits for BNA and dioxin/furan compounds and the company’s adoption of new wood treating practices. However, it should be noted that the finding of a low potential impact was partly based on screening values established at the time of the PA and SI in the late 1980’s. For example, 1 ppm was the established screening value for dioxins in 1988, whereas current risk-based screening concentrations, represented by EPA Region 9 Preliminary Remediation Goals (PRGs), is 0.016 ppb for 2,3,7,8-TCDD (tetrachlorodibenzo-p-dioxin).

Data Gaps:

While there have been several evaluations of the Avison West Side Mill site, they have primarily focused on the wood treating operations and associated contaminants. There has not been a full evaluation of all operational components of the former lumber mill and possible associated contaminants.

The site should be evaluated for additional contaminants of concern such as petroleum hydrocarbons; volatile organic compounds (VOCs); semi-volatile organic compounds (SVOCs); polychlorinated biphenyls (PCBs); pesticide and fungicide compounds (primarily in lumber storage areas to the north and northwest; and metals. Investigation of these compounds should be performed on the upland site and in the drainage systems and Bear Creek.

There is one additional question raised by the past PCP/TCP investigations at the Avison West Side Mill site that, based on DEQ’s review, has never been fully addressed. In 1983 surface water and sediment samples were collected on the property, primarily in Bear Creek near the area where the 1% PCP-containing chemical was applied. See Attachment 5 – Figure A for a map of those sampling locations, which are identified as “SW” for surface water samples and “E” for sediment samples. Surface water sample SW5 was acquired in a drainage way in the northwest corner of the site, referred to in reports as the “West Ditch”, which would have drained an area where lumber was stored and well away from the anti-sapstain dip tanks. Both PCP and TCP compounds were detected in the SW5 surface water sample. Very high concentrations of several TCP isomers and PCP were detected in sample E3. Subsequent investigations following the 1983 measurements in this area did not evaluate possible upland sources of the measured contamination. A 1985 investigation by Radian did sample sediment in this drainage way – samples 8 and 9 – and there were no detections of phenol compounds above the detection limit of 0.5 ppm (mg/kg). However, several dibenzo-p-dioxin isomers were detected in sample 8 – but no detection of 1,2,3,4- or 2,3,7,8-TCDD. Additional investigation for sources of PCP, TCP, and dioxin/furan compounds, along with the other contaminants noted above on the upland areas that drain to the West Ditch is needed.

Recommendations: DEQ SA recommends that the Avison Lumber - West Side Mills undergo a Site Investigation (SI) to address the remaining site contamination questions and develop plans for additional remedial actions at the site. Further investigations should include evaluation and sampling, at a minimum, for the following areas:

1. The former log pond near Mill #2;
2. The abandoned dip tanks in the vicinity of the Resaw #2 building;
3. The results of remedial activities for the contaminated soils north of Bear Creek in the 1983 Beak report (including areas around Mills #4 and #5);
4. The dip tank system adjacent to Kiln #2 (that replaced the abandoned dip tanks);
5. Details on the tank sludge removals in 1992 and 1994 in DEQ’s HW database;
6. Upland areas in the northwest corner of the property that drain to the “West Ditch”;
7. Apparent contamination near the Hyster shop, including an inventory of the materials stored in the building;
8. The drum storage area in the vicinity of the former Planer #1 building;
9. The oil/water separator near the Hyster shop;
10. The AST fueling station;
11. Laboratory test results and other documentation for the decommissioning of USTs near the Hyster shop;
12. Verification that no degreaser stations with associated sumps were in any of the mill buildings;
13. Verification that there was no bone yard area where waste or scrap materials were stored;
14. Any other cleanup activities associated with the site including hydraulic oil releases;
15. The potential that oil was used as a dust suppressant on dirt roads or as a weed-killer; and
16. An assessment of potential releases related to the use of glues in site operations.

2011 Update

Remedial action is not necessary based on 2010 sampling results for soil and groundwater in the northern site. Significant risk was not identified. In the southern site, dioxins/furans, pentachlorophenol, and petroleum hydrocarbons are elevated in some locations. After Phase 2 sampling in 2012, a final risk assessment will be performed and the remedy selection process begun.

2012 Update

Additional sampling of sediment in Bear Creek clarified the nature and extent of dioxin/furan contamination on the Floragon site. Dioxins are present within creek sediment to the western property boundary, but decrease away from the former dip tank area. Initial risk analysis indicates that they do not pose a signfiicant risk to either on- or off-site creek users. A final phase of site sampling is expected to occur in late 2013.
Data Sources: 1) DEQ Investigation;
2) 1983 Beak Consultants Chlorophenol Investigation; SRI water sampling (1983 to 1987);
4) 1985 EPA/RAdian Investigation;
5) 1988 EPA CERCLA Preliminary Assessment;
6) 1996 Seminole Environmental UST Decommissioning;
7) 1998 Phase I Environmental Site Assessment (GeoEngineers);
8) 1998 Subsurface Investigation (Braun Intertec Corp.);
9) 2004 Phase I Environmental Site Assessment (NW EnviroSearch);
10) 2007 Limited Waste Disposal & Soils Cleanup and Native Soils Assessment (NW EnviroSearch);
11) 2007 Limited Waste Disposal & Soils Cleanup & Ground Water Assessment (NW EnviroSearch);
12) 2007 Final Remedial Investigation Proposal (AMEC);
13) 2008 Draft RI/FS Work Plan (AMEC).
14) 2009 Final RI/FS Work Plan (PNG).
15 2011 Phase 1Remedial Investigation Report (PNG).
16) Phase II Remedial Investigation Supplemental Groundwater Characterization Work Plan. PNG, February 1, 2013.
17) Phase II Remedial Investigation Supplemental Groundwater Characterization Report. PNG, May 29, 2013.
18) Floragon Ecological risk Assessment Status and Planning (tech memo). August 3, 2013.
19) Upland Area Human Health and Ecological Risk Assessment Report. EES, September 5, 2013.
20) Phase 2 Remedial Investigation June 2013 Monitoring Report. PNG, September 10, 2013.
21) Catch Basin Maintenance Cleanup Report, Floragon Property - Upland Area. EES, November 14, 2013.
22) Final Upland Human Health and Ecological Risk Assessment Report. EES, January 14, 2014.
23) North Ditch Cleanout Report. EES, January 17, 2014.
24) DEQ NFA (partial) for the "Northern Parcels" portion of the site; March 4, 2014.
25) Focused Risk Evaluation Summary, SE Corner Parcels. EES, October 2014.
26) Site-Specific Bear Creek Ecological Risk Bioaccumulation Model Results. Sound Ecological Endeavors, EES, PNG; February 18, 2015.
27) Work Plan Summary for NFA Approach and Chip-Seal Maintenance. PNG Environmental; September 15, 2015.
28) Remedial Investigation Report, former Dip Tanks/Bear Creek Area (5-Acre Study Area). PNG Environmental; October 31, 2016.
29) DEQ Record of Decision, Former Dip Tank Area

Substance Contamination Information

Substance Media Contaminated Concentration Level Date Recorded
DIOXINS Soil Up to 3.9 ppb  
PENTACHLOROPHENOL Soil To 1,186 mg/kg  
PENTACHLOROPHENOL Surface Water To 50 mg/L  
TETRACHLOROPHENOL,2,3,4,6- Soil To 337 mg/kg  

Investigative, Remedial and Administrative Actions

Action Start Date Compl. Date Resp. Staff Lead Pgm
Partial No Further Action  (Primary Action) 03/04/2014 03/04/2014 Daniel Hafley VCP
View Full Report Showing Action History

Key to Certain Acronyms and Terms in this Report:

You may be able to obtain more information about this site by contacting Daniel Hafley at the Northwest regional office or via email at If this does not work, you may contact Gil Wistar at (503) 229-5512, or via email at or contact the Northwest regional office.