Contaminated Media Management Plan South Waterfront Lot #3 ...

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Contaminated Media Management Plan South Waterfront Lot #3 Portland, Oregon Prepared for Portland Development Commission December 29, 2010 15683-01

Transcript of Contaminated Media Management Plan South Waterfront Lot #3 ...

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Contaminated Media Management Plan South Waterfront Lot #3 Portland, Oregon Prepared for Portland Development Commission December 29, 2010 15683-01

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Contaminated Media Management Plan South Waterfront Lot #3 Portland, Oregon Prepared for Portland Development Commission December 29, 2010 15683-01 Prepared by Hart Crowser, Inc.

Richard D. Ernst, RG Principal

8910 SW Gemini Drive Beaverton, Oregon 97008-7123 Fax 503.620.6918 Tel 503.620.7284

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CONTENTS Page 1.0 INTRODUCTION 1 1.1 Purpose 1 1.2 Plan Organization 1 1.3 Limitations 2 2.0 BACKGROUND 2 2.1 Site Setting and Historical Use 2 2.2 Site Investigation Summary 3 2.3 Record of Decision 4 3.0 CONTAMINANTS OF CONCERN 5 4.0 CONTAMINATED MEDIA MANAGEMENT 5 4.1 Soil Management 6 4.2 Groundwater Management 11 5.0 HEALTH AND SAFETY REQUIREMENTS 12 5.1 Worker Safety 12 5.2 Health and Safety Plan 13 6.0 CLOSURE DOCUMENTATION 13 7.0 REFERENCES 14

FIGURES

1 Site Vicinity Map 2 Site Plan 3 Boring and Cross-Section Locations 4 Cross-Section A-A’ 5 Cross-Section B-B’ 6 Cross-Section C-C’ 7 Groundwater Analytical Results

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CONTENTS (Continued)

APPENDIX A SOIL DATA SUMMARY TABLES

APPENDIX B BUD ASSESSMENT

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ACRONYMS AND ABBREVIATIONS

bgs Below the ground surface BMPs Best management practices BUD Beneficial Use Determination Century West Century West Engineering Corporation CMMP Contaminated Media Management Plan COCs Contaminants of concern COPCs Contaminants of potential concern DEQ Oregon Department of Environmental Quality EES Easement and Equitable Servitude EPA Environmental Protection Agency ERM Environmental Resource Management HCID Hydrocarbon Identification HDPE High density polyethylene HSP Health and Safety Plan KM Kaplan-Meier NIOSH National Institute for Occupational Safety and Health OAR Oregon Administrative Rules OSHA Occupational Safety & Health Administration PAHs Polynuclear aromatic hydrocarbons PEL Permissible exposure limit PDC Portland Development Commission PPE Personal protective equipment PRGs Preliminary Remediation Goals RA Risk Assessment RBCs Risk-based concentrations RCRA Resource Conservation and Recovery Act RI Remedial Investigation ROD Record of Decision RSLs Regional screening levels SMA Soil management unit STEL Short term exposure limit SWLA Solid Waste Letter of Authorization TCLP Toxicity Characteristic Leaching Procedure TPH Total petroleum hydrocarbons TWA Time-weighted average UCL Upper confidence limit VOCs Volatile organic compounds

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CONTAMINATED MEDIA MANAGEMENT PLAN SOUTH WATERFRONT LOT #3 PORTLAND, OREGON

1.0 INTRODUCTION

This Contaminated Media Management Plan (CMMP) presents the protocols for managing contaminated soil and groundwater during future development of Lot #3 located within the South Waterfront Redevelopment Area of Portland, Oregon (Figure 1). This plan includes information on identification, response to, removal, temporary storage, transportation, and disposal of contaminated media. Health and safety issues and closure documentation are also described. The procedures described in this CMMP are consistent with Oregon Department of Environmental Quality (DEQ) rules and regulations and the Record of Decision (ROD) for the site (DEQ, 2004).

1.1 Purpose

The purpose of this CMMP is to provide site-specific information and guidance for the contractors that may encounter contaminated media during construction activities at Lot #3. During development of the site, construction workers may encounter contaminated soil at depth throughout the property. Groundwater could also be encountered in the deeper excavations, such as for elevator shafts and auger cast piles. The intent of this CMMP is to ensure that contaminated soil and groundwater, if encountered, can be properly managed.

1.2 Plan Organization

Subsequent sections of this CMMP are organized as follows:

Section 2 provides a description of the project site; a summary of previous environmental investigations and risk assessment, including a description of the nature and extent of soil and groundwater contamination and site risks; and the selected remedial action for the site.

Section 3 identifies the contaminants of concern at the site.

Section 4 describes procedures for management of contaminated media.

Section 5 presents a discussion of health and safety issues.

Section 6 describes closure documentation.

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Figures show the site and exploration locations, geological cross sections, and soil and groundwater data. Appendix A includes soil data summary tables, and Appendix B includes statistical analyses on the upper 10 feet of soil at the site. This CMMP is a revision of a prior CMMP prepared by Environmental Resources Management (ERM, 2004).

1.3 Limitations

This CMMP is intended only to provide procedures for identification and handling of contaminated media encountered during future development of Lot #3. Hart Crowser prepared this CMMP in accordance with generally accepted professional practices related to the nature of the work specified in the CMMP, in the same or similar localities, at the time this plan was prepared. This CMMP is for the specific application to the referenced project and for the exclusive use of Portland Development Commission (PDC). Future property owners or other entities may use this plan, but shall consider changes that may have occurred in environmental practices and regulations since plan preparation. No other warranty, express or implied, is made.

2.0 BACKGROUND

This section presents a brief description of the site, its history, its physical setting, and results of previous environmental activities.

2.1 Site Setting and Historical Use

The site is located within the South Waterfront Redevelopment Area of Portland, Oregon (Figure 1). It is bounded on the west by SW Harbor Drive, on the north by River Parkway and condominiums, on the south by a PGE substation, and on the east by SW Moody Avenue and the Residence Inn. Currently, Lot #3 consists of grass and bare ground and is not developed. The future land use of Lot #3 is not known at this time, but adjacent land uses may include multi-family residential (condominiums), commercial, or greenspace. Single-family residential development is not expected at the site nor is consistent with the land use assumptions presented in the remedial investigation and risk assessment (RI/RA) completed for the property (Century West, 2002). Historical use of Lot #3 included multiple sawmill operations, scrap steel storage, and use of the property associated with the former Lincoln Steam Plant (formerly located northeast of Lot #3). Fill material located beneath the site and on adjacent properties appears to include soil from the Pioneer Place excavation, wood waste, demolition debris, and other refuse. Some of the material used to

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fill the area may have included dredge spoils or wastes from nearby businesses. The thickness of the fill material is approximately 25 to 35 feet at the site. Beneath the fill material are native alluvial deposits approximately 30 to 60 feet thick and the Troutdale Formation, which lies approximately 58 to 92 feet below ground surface (bgs) at the site. Groundwater has been encountered at depths ranging from 13 to 25 feet bgs, but is usually approximately 20 feet bgs.

2.2 Site Investigation Summary

In October 2002, an RI/RA was completed for the Lot #3 (Century West, 2002). RI activities included soil borings, monitoring well installation, and collection of an extensive suite of soil and groundwater samples for characterization of the on-site fill materials. Explorations completed at the site are shown on Figure 2. Soil data indicate that the fill material has been contaminated with total petroleum hydrocarbons (TPH) as diesel and oil, polynuclear aromatic hydrocarbons (PAHs), and metals. Figures 3 through 6 present cross sections of the site, with soil results for TPH and total carcinogenic PAHs (naphthalene is not included in this total as it was considered non-carcinogenic in 2002). Appendix A also includes soil data summary tables. With the exception of the “black layer” and the slightly cleaner Fill Layer I (soils from the Pioneer Place excavation), contaminants appear to be randomly distributed across the site with no specific fill layer exhibiting higher concentrations or frequency of detection than another. There are no current source areas at the site and contaminants detected in the fill material are the result of debris from various historic practices. The highest concentrations of contaminants exhibited at the site were detected in the “black layer,” where concentrations of TPH and PAHs are generally one or more orders of magnitude higher than in the other layers. The “black layer” is a laterally extensive, discontinuous layer of black sandy material encountered on the central and southeastern portions of Lot #3 between 14 and 25 feet bgs. Pea gravel and slag were noted in some of the samples collected from the black material and a moderate petroleum odor was observed. Additional information regarding site geology and fill layers is included in Century West (2002). Shallow groundwater at the site has been contaminated with TPH, PAHs, and metals. PAH concentrations in the groundwater samples collected from several monitoring wells exceed the EPA Region IX preliminary remedial goals (PRGs) for tap water, applicable at the time of the RI/RA (current risk-based screening levels [i.e., DEQ, 2009] are lower). Figure 7 summarizes TPH and carcinogenic PAHs and TPH concentrations in groundwater.

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Concurrent with the RI, a RA was completed at the site to evaluate the potential risk to current and future site workers, construction workers, and/or residents potentially exposed to on-site contaminants. Unacceptable human health risk was identified for several potential exposure scenarios including excavation worker exposure to groundwater, construction worker exposure to deeper soil (below 10 feet), and residential/occupational worker exposure to deeper soils if soil below 10 feet is excavated and reused as surface fill. DEQ agreed with the conclusions of the RI/RA and subsequently prepared a focused feasibility study (DEQ, 2003). The DEQ-selected remedy for the site is an institutional control in the form of an Easement and Equitable Servitude (EES).

2.3 Record of Decision

The DEQ prepared a ROD for the site in January 2004 (DEQ, 2004) requiring that an EES be recorded for the site. The EES is the institutional control to preserve the groundwater use assumptions in the RA and how risks from groundwater and soil exposure must be mitigated during any future site work. The ROD provided a draft EES as an attachment for recording with Multnomah County as part of the real property record of deeds. This CMMP complies with this draft EES by presenting protocols for managing soil and groundwater that are generated during development activities. The ROD indicated that DEQ oversight would not be necessary for future construction activities, unless the developer proposed constructed or soil re-use options that were not consistent with the draft EES. The draft EES in the ROD generally states that:

No use shall be made of groundwater at the property, by extraction through

wells or by other means, which use involves consumption or other beneficial use of groundwater, unless it can be demonstrated to DEQ’s satisfaction that the groundwater use will not exacerbate site conditions.

Soil excavated from the upper 10 feet may be re-used on-site. However,

this soil does not meet the definition of “clean fill” as defined by Oregon Administrative Rules (OAR) 340-93 (Solid Waste, General Provisions) and may not be taken off-site unless it is disposed of at a facility to accept contaminated soil.

Excavation shall not be conducted more than 10 feet bgs unless it is conducted in a manner that complies with the applicable requirements of Occupational Safety and Health Administration (OSHA) guidance and regulations and:

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• Prevents worker direct contact exposure to groundwater, in or from an excavation;

• Uses engineering and health and safety protections to limit worker direct contact exposure to contaminated soil; and

• Results in disposal of any excavated site soil off-site at a facility permitted to accept contaminated soil.

Since issuance of the ROD in 2004, OAR 340-93 was revised in 2009 to include beneficial use of contaminated soil at an off-site location if such use is productive and will not create an adverse impact to public health, safety, welfare, or the environment. Beneficial use is documented by preparing a Beneficial Use Determination (BUD) pursuant to OAR 340-093-0260 to -0290 for DEQ approval. As documented in Appendix B, an assessment of soil data from the upper 10 feet indicates that it could be used as fill at an off-site commercial/ industrial property (this use, however, will still require a DEQ-approved BUD).

3.0 CONTAMINANTS OF CONCERN

Based on the RI Report, contaminants of concern (COCs) for soil and groundwater include carcinogenic PAHs: benz(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(k)fluoranthene, dibenzo(a,h)anthracene, and indeno(1,2,3-cd)pyrene. In addition, diesel- and oil-range TPH have been detected in soil and groundwater samples across the site at concentrations that pose a moderate concern. Metals, such as lead and zinc, in soil are also elevated above natural background concentrations. Figures 3 through 7 show the distribution of contaminants across the site.

4.0 CONTAMINATED MEDIA MANAGEMENT

The purpose of the CMMP is to address the management of contaminated soil and/or groundwater during site development as chemical contamination may be encountered within the project boundaries. PDC has made reasonable efforts to identify the type, locations, and concentrations of chemical compounds likely to be encountered during construction through completion of a RI (Century West, 2002). The report will be made available upon request. There is no warranty by PDC expressed or implied, that any information or data obtained from any source mentioned, is accurate or indicative of the subsurface soils or conditions that may be encountered in the project. In the event that development activities encounter chemical contamination significantly different than that identified in the RI or any other materials suspected of posing a threat

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to employees, the public, or the environment, the contractor should take the following actions.

Immediately cease all work activities in and around any area of the project where contamination has been encountered or discovered, and take appropriate measures in compliance with all applicable environmental laws to stop or minimize the immediate spread or release of any contamination.

In order to prevent rain or stormwater runoff from contacting the suspected

contamination, immediately place the appropriate control measures or devices on or adjacent to the affected area in such manner that does not disturb the site or the suspected contamination.

4.1 Soil Management

During development, excavation of soil will be required for building construction (e.g., foundations, underground parking) and utility installation. The process for managing excavated soil includes:

Classification of soil (soil units are described below);

Completing any necessary soil characterization activities, which includes collecting and analyzing samples;

Excavation, stockpiling, and loading of excavated soil;

Reuse or disposal of excavated soil; and

Documentation of soil management. Each of these process elements is described below. 4.1.1 Soil Classification In compliance with the assumptions of the ROD, two soil management units (SMAs) can be designated at the site. These SMAs include:

SMA-1: Upper 10 feet of soil (i.e., 0 to 10 feet bgs).

SMA-2: Deeper soil (i.e., below 10 feet bgs) that includes the “black layer.” Screening, characterization, and handling procedures of excavated soils will in general be consistent within each SMA. However, procedures will vary between the SMAs based on several factors, including variations in the type and magnitude of excavation work; availability of soil characterization data; expected

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contaminant conditions; and expected re-use of excavated soils as backfill within each SMA. SMA-1 soils are generally classified as materials with contaminant concentrations above clean fill criteria. In general, all soils at the site between the surface and 10 feet bgs are considered SMA-1 soils. Soil excavated from SMA-1 may be re-used on the site. However, it does not meet the definition of “clean fill” as defined by OAR 340-93, and may not be taken off-site unless it is disposed of at a facility that accepts contaminated soil (e.g., solid waste landfill or Solid Waste Letter of Authorization [SWLA] facility) or used as fill at an off-site location, such as a commercial/industrial property, pursuant to a DEQ-approved BUD. SMA-2 soils are generally soils within and near the “black layer”, which typically have concentrations of carcinogenic PAHs significantly above urban residential and occupational risk-based criteria. The designation of soil below 10 feet bgs as SMA-2 is based on the vertical and lateral extent of the “black layer.” Since the “black layer” is discontinuous across the site, ranges in depth from 14 to 25 feet bgs, and is not easily visually identifiable, the 10-foot-bgs criteria was selected as a conservative estimate. Therefore, all soils below 10 feet bgs are considered SMA-2 soils. Excavated SMA-2 soils must be disposed of at a solid waste landfill or other facility permitted to accept petroleum-contaminated soil. If excavation activities encounter chemical contamination significantly different than SMA-1 or SMA-2 soils or any other materials suspected of posing a threat, suspect materials will need to be appropriately characterized to determine the proper management protocols.

4.1.2 Soil Characterization Previous data are available to characterize SMA-1 and SMA-2 soils. However, additional samples will or may be obtained for chemical analyses for the situations described below. If samples are collected, the sample locations will be noted and recorded so that they can be described or plotted in site closure documentation. Samples should be submitted to an Oregon-accredited analytical laboratory for chemical analyses by Northwest methodology and EPA SW-846 methods, as indicated below.

Profiling of Contaminated Soil for Off-Site Disposal. Sampling will likely be required by the landfill or SWLA facility to obtain their approval for disposal. Existing data might be allowed, although landfill operators typically require more recent data (e.g., less than a year old) for profiling. Any facility receiving soil from the site should be contacted as to their requirements for acceptance.

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Representative samples of the contaminated soil will be collected, according to laboratory and analytical method specifications, to profile the soil.

Assessing Suspect Contaminated Soil. If field indications on soil or any other material suggest chemical contamination significantly different than SMA-1 or SMA-2 soils, a sample of the suspect soil will be obtained for chemical analysis. Suspect soil should not be excavated until adequately assessed through field screening and/or analytical testing. If suspect soil has already been excavated, it should be stockpiled on and covered with plastic sheeting until the proper method of disposal is determined. A representative sample will be collected and analyzed for hydrocarbon identification (HCID) by Northwest Method NWTPH-HCID with quantification of detected fuel types by Northwest methodology (Gx/Dx) and RCRA 8 metals (arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver) by EPA Method 6020/7471A. For any metals exceeding 20 times its hazardous waste toxicity characteristic (40 CFR 261.24), analysis by the Toxicity Characteristic Leaching Procedure (TCLP) per EPA Method 1311/6010 or 6020 will need to be performed as part of a hazardous waste determination. If volatile organic compounds (VOCs) are indicated by field screening, samples will be analyzed for VOCs by EPA Method 8260B.

Reclassification. Soil classifications have been established for on-site re-use (SMA-1) and off-site disposal (SMA-1 and SMA-2). The owner and/or contractor may elect to classify the soil based on soil samples collected during excavation, rather than relying on information collected as part of the RI, so as to determine if it meets clean fill screening levels or the requirements of a BUD. Re-classifying of the soil, however, will require involvement and discussions with the DEQ or other appropriate agency. Samples should be analyzed for TPH as diesel and oil by Northwest Method NWTPH-Dx, PAHs by EPA Method 8270-SIM, and metals by EPA Method 6020/7471A. Chemical data would then be compared against appropriate screening levels or risk-based criteria (e.g., RBCs). 4.1.3 Handling of Contaminated Soil The following are general requirements for handling of contaminated soil, including excavation, stockpiling, and loading. The requirements are generally the same for SMA-1 and SMA-2. SMA-1 soils may be reused on the site as fill material during grading activities. Excavated SMA-2 soils, however, must be disposed at an appropriate facility off the site. The following general requirements should be met at all times.

Excavation at the site should be completed in a manner that prevents co-mingling of SMA-1 and SMA-2 material. An on-site engineer or geologist should make a determination (based on soil saturation) if contaminated soil

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can be directly transported off the site, or if soil needs to be stockpiled to reduce water content. The engineer/geologist should determine when stockpiled soil might be transported off the site.

Minimize movement of excavation equipment over or through contaminated soil to prevent movement of contaminated soil into areas where no contaminated soil exists.

During construction and following development of the site, stormwater should be managed in accordance with applicable best management practices (BMPs). BMPs may include, but not be limited to, the use of silt fencing during construction, storm drain filters, and clean fill near stormwater drains.

Site soils (specifically SMA-2) should be stockpiled on an impervious surface to prevent the spread of contamination. Any water runoff from the contaminated soil stockpile area(s) should be contained and handled as contaminated water.

Stockpiles will be created in an approved location and should be surrounded by a fence to limit access. The stockpiles must be covered and bermed during periods of rainfall to prevent run-on and run-off. The stockpiles should be covered with a minimum 8 mil high density polyethylene (HDPE) plastic during periods of strong winds, nightfall, over the weekends, or during extended work stoppages. If dust is observed coming from the stockpiles, the stockpiles shall be either covered or the dust controlled with water.

Contaminated soil placed in stockpiles should be loaded into trucks in a manner that prevents the spilling or tracking of contaminated soil into areas of the site with uncontaminated soil. Loose material falling onto the exterior of the truck during loading should be removed before the truck leaves the loading area. Any material collected in the loading area should either be placed back into the truck or back into the stockpile. If the loading areas are unpaved, the surface soil should be inspected at the conclusion of loading activities to confirm that contaminated soil is not present. If the loading areas are paved, loose soil should be cleaned from the pavement at the conclusion of the loading activities. To avoid tracking soil off the site, a wheel wash and/or graveled apron should be placed at the site exit.

All applicable BMPs regarding engineering and/or health and safety precautions should be implemented to limit worker direct contact exposure to contaminated material. If excessive dust is generated during construction, dust control or respiratory protection may be required.

Suspect contaminated soil (i.e., soil significantly different than SMA-1 or SMA-2 soil) or foreign materials should not be disturbed by excavation because of issues involving worker safety and waste characterization, which must first be

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evaluated. An exclusion zone should be set up using appropriate barriers such as temporary fencing, orange netting, and/or warning tape. If the soil is determined to be non-hazardous, the soil will be managed in accordance with the above management procedures. If the soil is determined to be hazardous, all applicable RCRA hazardous waste requirements for managing and disposing of these soils shall be followed.

4.1.3 Off-Site Disposal or Re-use If not used on the site, SMA-1 soils can be disposed off the site at a facility that accepts contaminated soil (e.g., landfill or SWLA facility) or used as fill at an off-site location, such as a commercial/ industrial property, pursuant to a DEQ-approved BUD. Excavated SMA-2 soils must be disposed of at a landfill or other facility permitted to accept petroleum-contaminated soil. Other suspect contaminated soil or foreign materials should be disposed of in accordance with its waste determination. The following general guidelines for off-site transport and disposal/re-use of soil should be met:

Prior to transportation off the site for disposal or re-use, final approval for contaminated soil acceptance must be obtained from the receiving facility (i.e., landfill) or approved by the DEQ (through a BUD or SWLA), respectively. The use of landfills and other off-site locations is subject to the terms and conditions of their solid waste permits, the BUD, and/or SWLA. Requirements for off-site soil disposal/re-use may be more restrictive than those used to classify soil on the site.

Specific truck haul routes should be established before beginning off-site transport of contaminated soil. On-site truck routes should be established to minimize or prevent movement of trucks over contaminated soils. Off-site truck routes should be established to reduce the risk of releases of contaminated soils and impact on local traffic. It must be ensured that the loaded truck weights are within acceptable limits. All trucks should be covered (tarped) before they leave the loading area.

Maintain excavation equipment in good working order. Prevent spillage of oil, fuel, or hazardous substances from equipment. In particular, promptly repair oil leaks from equipment and cleanup any contaminated soil.

Owner should comply with all applicable Federal, State, or local laws, codes, and ordinances that govern or regulate transport of contaminated soil. If any soils are determined to be a hazardous waste, these soils must be managed and disposed in accordance with all applicable RCRA hazardous waste requirements including, but not limited to: having hazardous waste identification numbers for the site and transporters;

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manifesting; use of placards; land disposal restrictions; and treatment, if needed, prior to disposal.

Ensure that all drivers of vehicles transporting contaminated substances have in their possession all applicable Oregon State and local vehicle insurance documents, valid driver’s license, and vehicle registration and license. The owner will be responsible for informing all drivers of transport vehicles about:

• The nature of the material transported;

• Required road routes to and from the off-site disposal facility;

• Applicable city street regulations and requirements, and State of Oregon Department of Transportation codes, regulations and requirements; and

• The City’s requirement for proper handing and transportation of the substances.

Contaminated substances will not be allowed to be spilled or tracked off-site at any time during the project. Trucks used for the transportation of contaminated substances off-site should be substance compatible, license, insured, and permitted pursuant to federal, state, and local statutes, rules, regulations, and ordinances.

4.1.5 Recordkeeping Daily reports should be generated to document management of contaminated soil. These reports should be prepared on the same day in which activity has occurred and should be submitted to the owner the next day. All contaminated soil transport must use a bill of lading or manifest for each off-site shipment of contaminated soil. These documents should include the date and time of shipment, the name of the transportation company, the name of the truck driver, the disposal site, and a brief description of the contaminated material (e.g., soil). These documents and the associated weight slip showing the weight/volume of the contaminated soil should be provided to the owner upon disposal or re-use at the off-site facility.

4.2 Groundwater Management

Previous studies at the site have indicated the presence of PAHs and TPH at low levels in groundwater as a result of historical activities. The average depth to the water table, 20 feet, is much deeper than the maximum depth of foundation and sewer line excavations anticipated to be built at the site. Therefore, groundwater should not typically be encountered during future construction activities. However, the water table may be encountered due to the presence of shallow seasonally perched groundwater, or if deep excavation (for elevator shafts or

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auger cast piles) occurs during periods of seasonally high water table conditions. If encountered, groundwater must be collected and contained in temporary storage containers for off-site disposal at an approved facility in accordance with applicable Federal and State regulations. These protocols apply to groundwater beneath the entire site and the following procedures should be implemented:

Furnish, install, and operate all necessary machinery, pumps, pipes and miscellaneous equipment to keep excavations free from contaminated water during construction, pre-treat groundwater if necessary, and discharge to the City sewer system. The owner must acquire authorization to discharge groundwater to the City of Portland sewer system.

Pretreatment will likely be necessary prior to discharging groundwater generated in the SMA-2 area. The site should utilize temporary storage tanks for use in treatment of contaminated groundwater. The owner should acquire all permits and permissions necessary for the placement and operation of dewatering equipment, including temporary storage tanks. Collect samples of potentially contaminated groundwater prior to discharge in accordance with the Permit conditions.

Implement BMPs to meet total dissolved solids and total suspended sediment goals (to be determined) for acceptable amounts that may be placed in the sanitary sewer system.

Implement BMPs to prevent direct worker contact exposure to groundwater in or from an excavation.

5.0 HEALTH AND SAFETY REQUIREMENTS

Because contamination is present at the site, site personnel should be made aware of the potential for encountering contaminated media. It is the responsibility of each involved entity (owner, contractors, consultants) to conduct their own hazard assessment to determine appropriate health and safety measures.

5.1 Worker Safety

Each involved entity is responsible for the safety of their respective workers. This includes implementation of any training requirements, safety plans, monitoring, certifications, and any other action or requirement that may be required or prudent prior to beginning site activities. This CMMP or other notification must be provided to employees who will be working on the site. Prior to any ground-disturbing activities, a utility locate should be performed to identify potential utilities in proposed work areas.

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Each involved party will make preliminary assessments of potentially contaminated media as it relates to worker safety. Because COC concentrations in SMA-1 soils do not exceed risk-based levels for protection of worker health, no personal protective equipment (PPE) or special handling procedures will be required during handling of these soils. However, if excavation is planned at the site within SMA-2 (10 feet bgs or deeper), excavation workers may be required to have additional health and safety precautions. Occupational health guidelines for chemical hazards (i.e., OSHA and NIOSH) can be used to evaluate site conditions. The evaluation should consider exposure limits (i.e., TWA, STEL, PEL), exposure symptoms, and PPE. Specific recommendations should be provided to protect worker safety.

All entities are responsible for notifying and updating others and their employees of potential site hazards that may be encountered during the project. Testing, management, handling, excavation, transportation, etc., of contaminated media may require persons with 40-hour Hazardous Waste Operation & Emergency Response (29 CFR 1910.120) training. Each party involved should assess the need for this training on the basis of current information for the site. Changes may need to be made should additional contaminated areas be discovered.

5.2 Health and Safety Plan

Parties involved should prepare a site-specific Health and Safety Plan (HSP) for their employees to cover safety issues related to specific environmental hazards that may be encountered. The HSP should address specific site activities (i.e., excavation, trenching, heavy equipment, etc.) as well as potential contaminants that may be encountered. Based on the known contaminants and their concentrations, the Lot #3 site is likely to be classified as requiring Level C or D PPE during construction activities. It is anticipated that chemical exposure will be low; however, if excessive soil vapors are encountered or if there are high levels of dust, the Site Safety Officer may require Level C - respiratory protection. All parties will be responsible for compliance with their HSP, including use of appropriate PPE.

6.0 CLOSURE DOCUMENTATION

At the conclusion of the soil and groundwater management activities associated with development, a site closure report should be prepared that includes, but is not limited to:

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Description of excavation and soil management activities, including sampling activities and results, and the amount and types of contaminated soil excavated, and its disposal and/or re-use;

A discussion of handling of water removed during dewatering activities, including temporary storage, sampling activities and results, the volume and/or rate of wastewater disposed, and its disposal location;

Site maps indicating areas where contaminated soil was removed and where contaminated soil, if any, remains;

The nature of deviations, if any, from this CMMP;

Photographs of site activities; and

Copies of analytical laboratory reports, permits and approvals, and disposal manifests and receipts.

7.0 REFERENCES

Century West Engineering Corporation, 2002. Remedial Investigation, Lot #3 South Waterfront Redevelopment Area, Portland, Oregon. October 16, 2002. DEQ, 2002. Default background concentrations for metals. October 28, 2002.

DEQ, 2003. Feasibility Study Memorandum, South Waterfront Redevelopment Lot #3. September 8, 2003. DEQ, 2004. Remedial Action Record of Decision for South Waterfront Development Area, Lot #3, Multnomah County, Oregon. January 2004. DEQ, 2009. Excel® Spreadsheet for Risk Based Concentrations for Individual Chemicals. September 15, 2009. EPA, 2009. ProUCL Version 4.00.04 - Users Guide and Technical Guide. EPA/600/R-07/038 and 041. February 2009. EPA, 2010. Regional Screening Levels. November 2010.

ERM, 2004. Contaminated Media Management Plan, South Waterfront Lot #3, Portland, Oregon. February 2004.

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APPENDIX A SOIL DATA SUMMARY TABLES

Hart Crowser 15683-01 December 29, 2010

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Page 1 of 2

Table A1 - Soil Chemical Analyses Results: TPHSouth Waterfront Lot 3SW Moody Avenue and SW River Parkway, Portland, Oregon

Sample Date Depth TPH-D TPH-OConcentration in mg/kg (ppm)

HA-1 8/12/98 0.5 70 270HA-2 8/12/98 0.5 26 91HA-3 8/12/98 0.5 <25* <60*HA-4 8/12/98 0.5 <25* <60*HA-5 8/12/98 0.5 31 <60*HA-6 8/12/98 0.5 25 <60*HA-7 8/12/98 0.5 <25* <60*HA-8 8/12/98 0.5 46 310

CW-PB10-2.0' 11/17/99 2 <25* <60*MW1-3.0' 1/19/00 3 <17.6 89.7MW2-3.0' 1/19/00 3 <17.6 <58.8MW3-3.0' 1/18/00 3 <35.3 1,020MW4-3.0' 1/18/00 3 <19.7 189MW5-3.0' 1/17/00 3 <190 2,060MW6-3.0' 1/17/00 3 <18.3 <61

P-1-1 - 5 <33.5 <66.9P-2-1 - 5 <29.2 78.7P-3-1 - 5 <29.7 <59.5P-4-1 - 5 51.5 328P-5-1 - 5 <34.8 <69.5

CW-PB12C-7.5' 11/18/99 7.5 <34.9 514CW-PB8-7.5' 11/19/99 7.5 59.9 74.2CW-PB2-8.0' 11/19/99 8 236 <60.2CW-B1-10.0' 11/19/99 10 <188 1,440

CW-PB11A-10.0' 11/17/99 10 297 732CW-PB14A-10.0' 11/18/99 10 <163 1,130

CW-PB4-10.0' 11/19/99 10 <17.4 <58.1MW1-10.0' 1/19/00 10 <19.7 <65.8MW2-10.0' 1/19/00 10 <19 <63.3MW3-10.0 1/18/00 10 <17.6 294MW4-10.0' 1/18/00 10 <19.2 197

P-1-2 - 10 <28.2 138P-2-2 - 10 <35.2 <70.4P-3-2 - 10 <30.1 <60.3P-4-2 - 10 27.9 167

CW-B6-11.0' 11/23/99 11 ND NDCW-PB11B-11.0' 11/17/99 11 294 736CW-PB15-11.0' 11/18/99 11 24.1 107CW-PB9-11.0' 11/19/99 11 <188 1,530

MW5-11.0' 1/17/00 11 <100* 783CW-PB5-11.5' 11/19/99 11.5 <18.3 <61

CW-PB13-12.0' 11/22/99 12 86.3 170CW-PB3-12.0' 11/18/99 12 <18.1 <60.2

MW6-12.0 1/17/00 12 28 77.9P-5-2 12 <74.8 <69.5

MW1-14.0' 1/19/00 14 <781 10,500MW1-14.0' 1/19/00 14 ND 10,500

CW-PB5-14.5' 11/19/99 14.5 <16.9 67.5CW-B1-15.0' 11/19/99 15 <20 137

CW-PB10-15.0' 11/17/99 15 <17 170CW-PB13-15.0' 11/22/99 15 272 363

CW-B6-15.5' 11/23/99 15.5 <20.8 <69.4CW-PB2-16.0' 11/19/99 16 ND 51,800

Please refer to notes on the last page of this table.

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Page 2 of 2

Table A1 - Soil Chemical Analyses Results: TPHSouth Waterfront Lot 3SW Moody Avenue and SW River Parkway, Portland, Oregon

Sample Date Depth TPH-D TPH-OConcentration in mg/kg (ppm)

MW2-16.5' 1/19/00 16.5 ND NDMW6-16.5' 1/18/00 16.5 ND 443

CW-PB15-17.0' 11/18/99 17 ND NDCW-PB4-17.0' 11/19/99 17 69.4 324

MW1-17.0' 1/19/00 17 ND 407MW4-17.0' 1/18/00 17 ND 198

CW-PB14A-18.0' 11/18/99 18 ND 520CW-PB11B-18.5' 11/17/99 18.5 913 1,440

CW-PB8-18.5' 11/19/99 18.5 ND 182CW-PB12C-19.0' 11/18/99 19 ND 207

CW-PB3-20.0' 11/18/99 20 123 688CW-PB9-20.0' 11/19/99 20 ND 80

MW6-20.5' 1/18/00 20.5 ND 368CW-PB13-21.0' 11/22/99 21 33.9 143

MW1-21.0' 1/19/00 21 ND 494MW5-21.0' 1/17/00 21 ND ND

CW-PB10-22.0' 11/17/99 22 ND NDCW-PB14B-22.0' 11/18/99 22 ND 245

MW6-22.5' 1/18/00 22.5 ND 131CW-PB15-24.0' 11/18/99 24 ND NDCW-PB7-25.0' 11/18/99 25 ND ND

MW4-25.5' 1/18/00 25.5 68.7 259CW-PB10-27.0' 11/17/99 27 23.6 ND

CW-PB11B-27.0' 11/17/99 27 ND 3,180CW-PB8-27.0' 11/19/99 27 ND NDCW-PB4-27.5' 11/19/99 27.5 ND ND

CW-PB12C-30.0' 11/18/99 30 ND NDCW-PB2-30.0' 11/19/99 30 ND 1,840CW-B6-31.0' 11/23/99 31 ND ND

CW-PB14B-31.0' 11/18/99 31 23.3 82.4CW-PB5-31.5' 11/19/99 31.5 ND ND

CW-PB11B-33.0' 11/17/99 33 ND NDCW-PB9-33.0' 11/19/99 33 ND NDCW-PB7-35.0' 11/18/99 35 ND ND

PB-16-41 5/16/01 41 ND NDPB-17-43.5 5/17/01 43.5 ND ND

Notes:1. TPH-D = Total petroleum hydrocarbons as diesel2. TPH-O = Total petroleum hydrocarbons as oil.3. - = Not provided.4. < = Not detected above the indicated laboratory method reporting limit (MRL).5. ND = Not detected (MRL not provided by previous data tables).6. *Estimated MRL (not provided by previous data tables) based on other data obtained on or near the sample date.

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Table A2 - Soil Chemical Analyses Results: PAHsSouth Waterfront Lot 3SW Moody Avenue and SW River Parkway, Portland, Oregon

Sample Date Depth (ft.) Ace

naph

then

e

Ace

naph

thyl

ene

Ant

hrac

ene

Ben

zo(g

,h,i)

pery

lene

Fluo

rant

hene

Fluo

rene

Phe

nant

hren

e

Pyr

ene

Concentration in mg/kg (ppm)HA-1 8/12/98 0.5 <0.010* <0.010* <0.010* 0.033 0.038 <0.010* 0.02 0.041HA-2 8/12/98 0.5 <0.010* <0.010* <0.010* 0.030 0.042 <0.010* 0.024 0.042HA-3 8/12/98 0.5 <0.010* <0.010* <0.010* 0.011 <0.010* <0.010* <0.010* 0.011HA-4 8/12/98 0.5 <0.010* <0.010* <0.010* 0.014 0.017 <0.010* 0.010 0.023HA-5 8/12/98 0.5 <0.010* <0.010* <0.010* 0.020 0.018 <0.010* <0.010* <0.010*HA-6 8/12/98 0.5 <0.010* <0.010* <0.010* <0.010* <0.010* <0.010* <0.010* <0.010*HA-7 8/12/98 0.5 <0.010* <0.010* <0.010* <0.010* <0.010* <0.010* <0.010* <0.010*HA-8 8/12/98 0.5 <0.010* <0.010* <0.010* 0.013 0.013 <0.010* <0.010* 0.016

MW5-3.0' 1/17/00 3 0.183 0.04 0.317 0.114 0.251 0.277 0.795 1.21MW6-3.0' 1/17/00 3 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010MW4-3.0' 1/18/00 3 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010MW3-3.0' 1/18/00 3 <0.010 0.0151 0.0189 0.102 0.15 <0.010 0.0808 0.182MW1-3.0' 1/19/00 3 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010MW2-3.0' 1/19/00 3 <0.010 <0.010 <0.010 0.0105 0.0168 <0.010 <0.010 0.0246

CW-PB8-7.5' 11/19/99 7.5 <0.010 <0.010 <0.010 <0.010 0.0105 <0.010 0.016 0.0166CW-PB12C-7.5' 11/18/99 7.5 <0.010 0.0102 0.0194 0.151 0.232 <0.010 0.111 0.255

CW-PB2-8.0' 11/19/99 8 0.166 0.0246 0.0985 0.0207 0.038 0.278 1.00 0.0673CW-B1-10.0' 11/19/99 10 <0.010 0.0391 0.0517 0.274 0.394 0.0125 0.202 0.463

CW-PB4-10.0' 11/19/99 10 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010CW-PB11A-10.0' 11/17/99 10 <0.010 <0.010 <0.010 0.0353 0.0382 <0.010 0.0208 0.0735CW-PB14A-10.0 11/18/99 10 <0.025 0.0268 <0.025 0.193 0.0942 <0.025 0.029 0.199

MW4-10.0' 1/18/00 10 <0.010 <0.010 <0.010 0.0115 0.0142 <0.010 <0.010 0.0177MW3-10.0 1/18/00 10 <0.010 0.0174 0.0163 0.155 0.144 <0.010 0.0646 0.191MW1-10.0' 1/19/00 10 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010MW2-10.0' 1/19/00 10 <0.010 <0.010 <0.010 0.0551 0.075 <0.010 0.0295 0.113

CW-B6-11.0 11/23/99 11 <0.010 <0.010 <0.010 0.0535 0.0472 <0.010 0.0257 0.0605CW-PB9-11.0' 11/19/99 11 <0.010 <0.010 <0.010 0.0572 0.108 <0.010 0.0577 0.127

CW-PB11B-11.0' 11/17/99 11 <0.010 <0.010 0.0122 0.0957 0.0969 <0.010 0.0486 0.165CW-PB15-11.0' 11/18/99 11 <0.010 <0.010 0.0117 0.196 0.247 <0.010 0.058 0.296

MW5-11.0' 1/17/00 11 0.02 0.0155 0.0424 0.749 0.478 0.0165 0.156 0.596CW-PB3-12.0' 11/18/99 12 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010

MW6-12.0 1/17/00 12 <0.010 <0.010 0.0118 0.706 0.171 <0.010 0.0663 0.211MW6-12.0 DUP 1/17/00 12 0.0344 <0.010 0.0573 3.83 1.01 0.0349 0.274 1.15

MW1-14.0' 1/19/00 14 <0.050 <0.050 <0.050 0.143 <0.050 <0.050 <0.050 0.128CW-PB5-14.5' 11/19/99 14.5 <0.010 0.0108 0.0144 0.217 0.253 <0.010 0.103 0.33

CW-PB13-15.0' 11/22/99 15 0.153 0.0148 0.303 11.5 4.46 0.123 1.28 5.51CW-PB10-15.0' 11/17/99 15 0.0102 <0.010 <0.010 0.12 0.0788 <0.010 0.0479 0.117CW-PB2-16.0' 11/19/99 16 0.157 <0.100 0.318 0.538 1.73 0.46 2.11 1.8

MW6-16.5' 1/18/00 16.5 0.028 <0.010 0.0383 3.35 0.805 0.0272 0.24 0.881MW2-16.5' 1/19/00 16.5 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010

CW-PB4-17.0' 11/19/99 17 0.038 <0.010 0.0637 5.93 1.27 0.0264 0.328 1.61CW-PB7-17.0' 11/18/99 17 0.0216 <0.010 0.0197 1.39 0.469 0.0116 0.0902 0.574

MW4-17.0' 1/18/00 17 0.0158 <0.010 0.0218 3.79 0.416 <0.010 0.0854 0.611MW1-17.0' 1/19/00 17 0.0736 0.0437 0.553 5.12 8.08 0.0977 1.3 14

CW-PB8-18.5' 11/19/99 18.5 0.0247 0.02 0.0671 0.612 0.731 0.038 0.507 0.895CW-PB12C-19.0' 11/18/99 19 <0.010 <0.010 <0.010 0.0126 0.019 <0.010 0.0178 0.0212

CW-PB9-20.0' 11/19/99 20 <0.010 0.0324 0.0291 0.42 0.668 <0.010 0.224 0.925CW-B1-20.0' 11/19/99 20 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010

CW-PB3-20.0' 11/18/99 20 0.0755 0.013 0.1327 10.9 2.99 0.0474 0.486 4.27

Please refer to notes on the last page of this table.

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Table A2 - Soil Chemical Analyses Results: PAHsSouth Waterfront Lot 3SW Moody Avenue and SW River Parkway, Portland, Oregon

Sample Date Depth (ft.) Ace

naph

then

e

Ace

naph

thyl

ene

Ant

hrac

ene

Ben

zo(g

,h,i)

pery

lene

Fluo

rant

hene

Fluo

rene

Phe

nant

hren

e

Pyr

ene

Concentration in mg/kg (ppm)MW6-20.5' 1/18/00 20.5 0.0108 <0.010 0.0267 1.51 0.338 0.0112 0.0957 0.438

CW-B6-21.0' 11/23/99 21 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010CWPB13-21' 11/22/99 21 0.0366 <0.010 0.0723 3.85 1.11 0.0312 0.241 1.37MW5-21.0' 1/17/00 21 <0.010 <0.010 0.0141 0.0304 0.118 <0.010 0.0339 0.127

MW5-21.0 DUP 1/17/00 21 <0.010 <0.010 <0.010 <0.010 0.0173 <0.010 <0.010 0.0242MW1-21.0' 1/19/00 21 <0.010 0.0203 0.0211 0.184 0.273 0.0109 0.115 0.305

CW-PB14B-22.0' 11/18/99 22 <0.010 <0.010 <0.010 0.0138 0.0149 <0.010 <0.010 0.0209CW-PB10-22' 11/17/99 22 <0.010 <0.010 <0.010 0.0112 <0.010 <0.010 <0.010 <0.010

MW6-22.5 1/18/00 22.5 <0.010 <0.010 0.0183 0.341 0.321 <0.010 0.0483 0.452CW-PB15-24.0' 11/18/99 24 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010

MW4-25.5' 1/18/00 25.5 <0.010 <0.010 0.0241 0.0351 0.0918 0.0328 0.0958 0.089CW-PB8-27.0' 11/19/99 27 <0.010 <0.010 <0.010 <0.010 0.0177 <0.010 0.0237 0.0244

CW-PB11B-27.0' 11/17/99 27 0.0127 <0.010 0.026 0.0518 0.201 0.0348 0.181 0.208CW-PB4-27.5' 11/19/99 27.5 <0.010 <0.010 <0.010 0.0145 0.0213 <0.010 <0.010 0.0265CW-PB2-30.0' 11/19/99 30 0.0189 <0.010 0.0253 0.051 0.163 0.0247 0.0572 0.174

CW-PB12C-30.0' 11/18/99 30 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010CW-B6-31.0' 11/23/99 31 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010

CW-PB14B-31.0' 11/18/99 31 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010CW-PB5-31.5' 11/19/99 31.5 <0.010 <0.010 <0.010 <0.010 0.0149 <0.010 <0.010 0.0165CW-PB9-33.0' 11/19/99 33 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010

CW-PB11B-33.0' 11/17/99 33 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010CW-B1-35.0' 11/19/99 35 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010

PB16-41' 5/16/01 41 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010PB17-43.5' 5/17/01 43.5 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010

Please refer to notes on the last page of this table.

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Page 3 of 4

Table A2 - Soil Chemical Analyses Results: PAHsSouth Waterfront Lot 3SW Moody Avenue and SW River Parkway, Portland, Oregon

Sample Date Depth (ft.) Ben

zo(a

)ant

hrac

ene

Ben

zo(a

)pyr

ene

Ben

zo(b

)fluo

rant

hene

Ben

zo(k

)fluo

rant

hene

Chr

ysen

e

Dib

enzo

(a,h

)ant

hrac

ene

Inde

no(1

,2,3

-cd)

pyre

ne

Nap

htha

lene

Concentration in mg/kg (ppm)HA-1 8/12/98 0.5 0.016 0.027 0.030 0.018 0.020 <0.010* <0.010* <0.010*HA-2 8/12/98 0.5 0.023 0.029 0.039 0.012 0.024 <0.010* 0.022 <0.010*HA-3 8/12/98 0.5 <0.010* 0.011 0.014 <0.010* <0.010* <0.010* <0.010* <0.010*HA-4 8/12/98 0.5 <0.010* 0.013 0.016 <0.010* 0.011 <0.010* <0.010* <0.010*HA-5 8/12/98 0.5 0.012 0.017 0.025 <0.010* 0.013 <0.010* 0.014 <0.010*HA-6 8/12/98 0.5 <0.010* <0.010* <0.010* <0.010* <0.010* <0.010* <0.010* <0.010*HA-7 8/12/98 0.5 <0.010* <0.010* <0.010* <0.010* <0.010* <0.010* <0.010* <0.010*HA-8 8/12/98 0.5 <0.010* 0.011 0.015 <0.010* <0.010* <0.010* <0.010* <0.010*

MW5-3.0' 1/17/00 3 0.432 0.224 0.128 0.0184 0.521 0.0422 0.0333 0.0617MW6-3.0' 1/17/00 3 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010MW4-3.0' 1/18/00 3 <0.010 0.0118 0.0139 <0.010 <0.010 <0.010 <0.010 <0.010MW3-3.0' 1/18/00 3 0.0803 0.142 0.132 0.0346 0.0739 0.0288 0.0748 0.0297MW1-3.0' 1/19/00 3 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010MW2-3.0' 1/19/00 3 <0.010 0.0123 0.0132 <0.010 <0.010 <0.010 <0.010 <0.010

CW-PB8-7.5' 11/19/99 7.5 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010CW-PB12C-7.5' 11/18/99 7.5 0.111 0.169 0.222 0.0524 0.134 0.0406 0.113 0.0258

CW-PB2-8.0' 11/19/99 8 0.0155 0.0229 0.0293 <0.010 0.0193 <0.010 0.0168 0.0188CW-B1-10.0' 11/19/99 10 0.251 0.486 0.517 0.133 0.221 0.105 0.242 0.0265

CW-PB4-10.0' 11/19/99 10 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010CW-PB11A-10.0' 11/17/99 10 0.0341 0.0464 0.0532 0.0151 0.0419 0.0119 0.0269 <0.010CW-PB14A-10.0 11/18/99 10 0.0424 0.17 0.18 0.033 0.0598 0.0616 0.108 <0.025

MW4-10.0' 1/18/00 10 <0.010 0.0132 0.0142 <0.010 <0.010 <0.010 <0.010 <0.010MW3-10.0 1/18/00 10 0.0944 0.165 0.2 0.0563 0.0969 0.0452 0.117 <0.010MW1-10.0' 1/19/00 10 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010MW2-10.0' 1/19/00 10 0.0315 0.0574 0.0558 0.014 0.0352 <0.010 0.0384 <0.010

CW-B6-11.0 11/23/99 11 0.0312 0.0526 0.0676 0.0199 0.0351 0.0148 0.0407 <0.010CW-PB9-11.0' 11/19/99 11 0.0528 0.073 0.0894 0.026 0.0535 0.0212 0.0385 <0.010

CW-PB11B-11.0' 11/17/99 11 0.0817 0.122 0.143 0.0368 0.0892 0.0324 0.0738 <0.010CW-PB15-11.0' 11/18/99 11 0.163 0.246 0.333 0.0836 0.205 0.0663 0.165 <0.010

MW5-11.0' 1/17/00 11 0.551 1.13 1 0.308 0.535 0.255 0.656 0.0264CW-PB3-12.0' 11/18/99 12 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010

MW6-12.0 1/17/00 12 0.246 0.723 0.791 0.176 0.286 0.214 0.592 0.0209MW6-12.0 DUP 1/17/00 12 1.56 5.21 5.79 1.54 1.93 1.21 3.36 0.134

MW1-14.0' 1/19/00 14 0.0824 0.319 0.348 <0.050 0.112 0.0662 <0.050 <0.050CW-PB5-14.5' 11/19/99 14.5 0.153 0.246 0.322 0.0946 0.207 0.0686 0.176 0.0161

CW-PB13-15.0' 11/22/99 15 5.49 14.7 15.7 4.19 6.61 4.11 10.1 0.479CW-PB10-15.0' 11/17/99 15 0.0542 0.126 0.137 0.0356 6.27 0.0356 0.0921 <0.010CW-PB2-16.0' 11/19/99 16 0.706 0.698 0.836 0.136 1.3 0.262 0.245 0.446

MW6-16.5' 1/18/00 16.5 1.07 3.57 5.5 0.886 1.2 0.914 2.79 0.102MW2-16.5' 1/19/00 16.5 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010

CW-PB4-17.0' 11/19/99 17 2.07 6.41 7.3 2.17 2.64 2.06 5.14 0.143CW-PB7-17.0' 11/18/99 17 0.752 1.62 2.07 0.601 0.724 0.554 1.24 0.0272

MW4-17.0' 1/18/00 17 0.857 4.22 4.09 0.71 0.921 0.985 3.26 0.0321MW1-17.0' 1/19/00 17 5.79 9.27 7.5 2.13 5.01 1.71 4.4 0.144

CW-PB8-18.5' 11/19/99 18.5 0.408 0.799 0.808 0.288 0.403 0.204 0.525 0.0221CW-PB12C-19.0' 11/18/99 19 <0.010 0.0131 0.0158 <0.010 <0.010 <0.010 0.0103 <0.010

CW-PB9-20.0' 11/19/99 20 0.251 0.404 0.0129 0.114 0.298 0.0592 0.294 <0.010CW-B1-20.0' 11/19/99 20 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010

CW-PB3-20.0' 11/18/99 20 3.97 12.9 12.8 3.44 4.76 3.72 9.53 0.149

Please refer to notes on the last page of this table.

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Page 4 of 4

Table A2 - Soil Chemical Analyses Results: PAHsSouth Waterfront Lot 3SW Moody Avenue and SW River Parkway, Portland, Oregon

Sample Date Depth (ft.) Ben

zo(a

)ant

hrac

ene

Ben

zo(a

)pyr

ene

Ben

zo(b

)fluo

rant

hene

Ben

zo(k

)fluo

rant

hene

Chr

ysen

e

Dib

enzo

(a,h

)ant

hrac

ene

Inde

no(1

,2,3

-cd)

pyre

ne

Nap

htha

lene

Concentration in mg/kg (ppm)MW6-20.5' 1/18/00 20.5 0.521 1.98 2.14 0.393 0.562 0.484 1.25 0.0243

CW-B6-21.0' 11/23/99 21 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010CWPB13-21' 11/22/99 21 1.92 6.05 6.09 1.4 2.09 1.36 3.62 0.0787MW5-21.0' 1/17/00 21 0.0785 0.0708 0.074 0.0253 0.0569 0.0104 0.029 <0.010

MW5-21.0 DUP 1/17/00 21 0.0129 0.0124 0.0152 <0.010 0.0115 <0.010 <0.010 <0.010MW1-21.0' 1/19/00 21 0.15 0.251 0.271 0.0922 0.155 0.047 0.151 <0.010

CW-PB14B-22.0' 11/18/99 22 <0.010 0.0108 0.0133 <0.010 <0.010 <0.010 <0.010 <0.010CW-PB10-22' 11/17/99 22 <0.010 <0.010 0.01 <0.010 <0.010 <0.010 <0.010 <0.010

MW6-22.5' 1/18/00 22.5 0.256 0.459 0.41 0.0995 0.226 0.0844 0.284 0.0148CW-PB15-24.0' 11/18/99 24 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010

MW4-25.5' 1/18/00 25.5 0.0443 0.049 0.0553 0.0155 0.039 0.0103 0.0326 0.0318CW-PB8-27.0' 11/19/99 27 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010

CW-PB11B-27.0' 11/17/99 27 0.0711 0.0722 0.113 0.026 0.0784 0.0196 0.0424 0.0101CW-PB4-27.5 11/19/99 27.5 0.0125 0.0193 0.0218 <0.010 0.0132 <0.010 0.0125 <0.010CW-PB2-30.0' 11/19/99 30 0.0756 0.0811 0.0899 0.0272 0.0933 0.0204 0.0396 <0.010

CW-PB12C-30.0' 11/18/99 30 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010CW-B6-31.0' 11/23/99 31 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010

CW-PB14B-31.0' 11/18/99 31 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010CW-PB5-31.5' 11/19/99 31.5 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010CW-PB9-33.0' 11/19/99 33 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010

CW-PB11B-33.0' 11/17/99 33 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010CW-B1-35.0' 11/19/99 35 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010

PB16-41' 5/16/01 41 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010PB17-43.5' 5/17/01 43.5 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010

Notes:1. PAHs = Polynuclear aromatic hydrocarbons.2. < = Not detected above the indicated laboratory method reporting limit (MRL).3. *Estimated MRL (not provided by previous data tables) based on other data and mimimum detections.

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Page 1 of 2

Table A3 - Soil Chemical Analyses Results: MetalsSouth Waterfront Lot 3SW Moody Avenue and SW River Parkway, Portland, Oregon

Sample Date Depth (ft.) Antimony Arsenic Barium Beryllium Cadmium Chromium Copper LeadConcentration in mg/kg (ppm)

HA-1 8/12/98 0.5 - 6.91 141 - ND 16.9 - 25HA-2 8/12/98 0.5 - 6.0 150 - ND 20.0 - 27HA-3 8/12/98 0.5 - 5.0 140 - ND 17.0 - 18HA-4 8/12/98 0.5 - 5.0 150 - ND 18.0 - 19HA-5 8/12/98 0.5 - 6.0 150 - ND 19.0 - 23HA-6 8/12/98 0.5 - 7.0 160 - ND 20.0 - 19HA-7 8/12/98 0.5 - 6.0 140 - ND 19.0 - 15HA-8 8/12/98 0.5 - 6.0 150 - ND 20.0 - 24

MW5-3.0' 1/17/00 3 <0.0101 3.37 - <0.00101 3.31 16.2 40.4 55.9MW6-3.0' 1/17/00 3 <0.505 1.97 - <0.0505 2.53 8.77 10.7 3.81MW4-3.0' 1/18/00 3 <0.477 8.83 - <0.0477 2.38 14.1 15.7 8.58MW3-3.0' 1/18/00 3 1 3.41 - <0.0500 3.5 22.8 38 259MW1-3.0' 1/19/00 3 <0.505 3.25 - <0.0505 2.53 12.2 14.1 16.2MW2-3.0' 1/19/00 3 <0.505 3.38 - <0.0505 2.53 11.7 15.7 14.6CW-B1-10 11/19/99 10 <0.500 7.52 - <0.05 2.26 21.3 74.9 1,260MW4-10.0' 1/18/00 10 <0.510 2.96 - <0.0510 2.55 13.1 12.2 51.5MW3-10.0' 1/18/00 10 <0.490 2.20 - <0.0490 3.43 13.9 58.3 93.6MW1-10.0' 1/19/00 10 <0.516 2.31 - <0.0516 2.58 9.59 10.8 5.67MW2-10.0' 1/19/00 10 <0.505 3.14 - <0.0505 2.53 13.2 14.6 101

CW-PB15-11.0' 11/18/99 11 <0.500 2.15 - 0.091 1.72 12 30.1 57.8MW5-11.0 1/17/00 11 <0.505 3.59 - <0.0505 6.07 76.3 174 222MW6-12.0 1/17/00 12 <0.505 1.08 - <0.0505 2.14 28.6 29 12MW1-14.0' 1/19/00 14 <0.500 1.04 - <0.0500 2 5.7 12 7.5

CW-PB2-16.0' 11/19/99 16 <0.500 1.65 - <0.05 0.0883 19 24.4 81.4MW6-16.5' 1/18/00 16.5 1.52 7.46 - <0.0505 3.03 25.6 38.9 63.1MW2-16.5' 1/19/00 16.5 <0.510 2.8 - <0.0510 2.55 13.1 22.4 130

CW-PB4-17.0' 11/19/99 17 <0.500 2.5 - 0.301 0.982 20.4 152 37.1CW-PB7-17.0' 11/18/99 17 <0.500 2.07 - <0.0500 0.897 61.5 35.9 25.2

MW4-17.0' 1/18/00 17 <0.500 3.18 - <0.0500 3 17.6 200 262MW1-17.0' 1/19/00 17 <0.481 0.663 - <0.0481 0.962 7.36 54.8 84.1MW6-20.5' 1/18/00 20.5 <0.485 3.21 - <0.0485 4.37 24.1 47.1 27.7MW5-21.0' 1/17/00 21 <0.505 1.94 - <0.0505 2.26 12.3 8.02 11.3MW1-21.0' 1/19/00 21 <0.521 1.92 - <0.0521 2.6 15.2 11.5 156

CW-PB3-22.0' 11/18/99 22 <0.500 5.76 - 0.0958 1.79 39.9 76.9 33.1MW6-22.5 1/18/00 22.5 <0.472 2.88 - <0.0472 1.89 14.5 24.5 67.5

CW-PB13-25.0' 11/22/99 25 <0.500 3.94 - <0.0500 1.21 17.1 32.9 27MW4-25.5' 1/18/00 25.5 <0.495 3.42 - <0.0495 2.48 12.7 18.8 173

CW-PB11B-27.0' 11/17/99 27 <0.500 0.48 - <0.05 1.78 2.72 26.7 332

Please refer to notes on the last page of this table.

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Page 2 of 2

Table A3 - Soil Chemical Analyses Results: MetalsSouth Waterfront Lot 3SW Moody Avenue and SW River Parkway, Portland, Oregon

Sample Date Depth (ft.) Mercury Nickel Selenium Silver Thallium ZincConcentration in mg/kg (ppm)

HA-1 8/12/98 0.5 0.18 - ND ND - -HA-2 8/12/98 0.5 0.12 - ND ND - -HA-3 8/12/98 0.5 ND - ND ND - -HA-4 8/12/98 0.5 ND - ND ND - -HA-5 8/12/98 0.5 ND - ND ND - -HA-6 8/12/98 0.5 ND - ND ND - -HA-7 8/12/98 0.5 ND - ND ND - -HA-8 8/12/98 0.5 ND - ND ND - -

MW5-3.0' 1/17/00 3 0.127 18.5 <0.0202 <0.0101 <0.0253 136MW6-3.0' 1/17/00 3 0.017 11 <1.01 <0.505 <1.26 41.7MW4-3.0' 1/18/00 3 0.037 11 <0.953 <0.953 <1.19 56.2MW3-3.0' 1/18/00 3 0.174 18 <1.00 1 <1.25 220MW1-3.0' 1/19/00 3 0.092 12.6 <1.01 <1.01 <1.26 59.1MW2-3.0' 1/19/00 3 0.126 12.1 <1.01 <1.01 <1.26 60.6CW-B1-10 11/19/99 10 0.144 19.5 <1.00 <0.500 <1.25 597MW4-10.0' 1/18/00 10 0.2 9.69 <1.02 1.02 1.28 80.1MW3-10.0' 1/18/00 10 0.144 17.6 <0.980 <0.980 <1.23 184MW1-10.0' 1/19/00 10 0.04 11.3 <1.03 <1.03 <1.29 43.8MW2-10.0' 1/19/00 10 1.88 9.6 <1.01 <1.01 <1.26 92.4

CWPB15-11.0' 11/18/99 11 0.134 12.6 <1.00 <0.500 <1.25 121MW5-11.0 1/17/00 11 0.4 103 <1.01 <0.505 <1.26 474MW6-12.0 1/17/00 12 0.046 5.66 <1.01 <0.505 <1.26 24.6MW1-14.0' 1/19/00 14 0.057 12.5 <1.00 <1.00 <1.25 41

CWPB2-16.0' 11/19/99 16 0.47 32.7 <1.00 <0.500 <1.25 304MW6-16.5' 1/18/00 16.5 0.127 15.7 <1.01 <0.505 <1.26 76.8MW2-16.5' 1/19/00 16.5 0.068 10.2 <1.02 <1.02 <1.28 139

CW-PB4-17.0' 11/19/99 17 <.0700 7.28 <1.00 <0.500 <1.25 200CW-PB7-17.0' 11/18/99 17 <0.0700 32.8 8.36 <0.500 <1.25 107

MW4-17.0' 1/18/00 17 1.46 13.5 <1.00 1 <1.25 193MW1-17.0' 1/19/00 17 0.036 6.25 <0.962 <0.962 <1.20 47.1MW6-20.5' 1/18/00 20.5 0.068 31.1 <0.971 <0.971 <1.21 63.6MW5-21.0' 1/17/00 21 0.035 7.92 <1.01 <0.505 <1.26 70.4MW1-21.0' 1/19/00 21 0.313 9.37 <1.04 <1.04 <1.30 98.4

CW-PB3-22.0' 11/18/99 22 <.0700 29.1 <1.00 <0.500 <1.25 75.3MW6-22.5 1/18/00 22.5 0.154 9.43 <.943 <.943 <1.18 103

CW-PB13-25.0' 11/22/99 25 <0.0700 12.5 <1.00 <0.500 <1.25 84.5MW4-25.5' 1/18/00 25.5 0.088 10.4 <0.990 <0.990 <1.24 136

CWPB11B-27.0' 11/17/99 27 <.0700 12.8 <1.00 <0.500 <1.25 513

Note:1. < = Not detected above the indicated laboratory method reporting limit (MRL).2. - = Not analyzed.3. ND = Not detected (MRL not provided by previous data tables).

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APPENDIX B BUD ASSESSMENT

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APPENDIX B BUD ASSESSMENT

The upper 10 feet of soil (classified as SMA-1) have contaminant concentrations above clean fill criteria, thus not meeting the definition of “clean fill” as defined by Oregon Administrative Rules (OAR) 340-93. This soil can be re-used on the site, but would require off-site disposal at a facility that accepts contaminated soil (e.g., solid waste landfill). Alternatively, the Oregon Department of Environmental Quality (DEQ) can approve re-use at other off-site locations through a Solid Waste Letter of Authorization pursuant to OAR 340-93-0060 or a Beneficial Use Determination (BUD) pursuant to OAR 340-093-0260 to -0290. This appendix presents an assessment of SMA-1 soils in support of a BUD for re-use as fill at an off-site commercial/industrial property.

Initial Screening

Environmental investigation activities at the site have identified TPH as diesel and oil, PAHs, and metals as the primary contaminants in soil from SMA-1 (Table B1). To identify specific contaminants of potential concern (COPCs), we compared the maximum concentrations of diesel, oil, individual PAHs, and 14 metals for SMA-1 soils to DEQ’s risk-based concentrations (RBCs) for direct contact with soil by occupational workers (DEQ, 2009). Where DEQ RBCs were not available, EPA Regional Screening Levels (RSLs) were used (EPA, 2010). For arsenic, the natural background concentration was used (DEQ, 2002). Upon screening, only arsenic and benzo(a)pyrene exceeded their respective direct contact RBCs for occupational workers and were identified as COPCs for further statistical analysis. Table B1 presents this initial screening.

Statistical Evaluation

For each COPC, we used ProUCL 4.00.04 to calculate summary statistics (e.g., mean, median), determine the data distribution, and calculate the 90% upper confidence limit (UCL) on the arithmetic mean (EPA, 2009). Due to uncertainties in sample data (where a portion of all soil at a site is sampled), the 90% UCL is used to estimate a reasonable maximum concentration that equals or exceeds the true mean 90% of the time. The objective of this statistical analysis was to estimate the likely average (mean) and reasonable maximum COPC concentrations of the soil after mixing through excavation, placement, and grading and then compare these values to risk-based criteria applicable at off-site locations where soil would be re-used as fill. The following protocols were used.

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Only observed detections were used to calculate the arithmetic mean and median. In the case of benzo(a)pyrene where non-detect values were present, the mean and median would likely be biased high.

For UCL calculations, ProUCL recommends an appropriate UCL to use for the 95% UCL. We used this recommended UCL when determining the 90% UCL.

For COPCs with non-detect values, the non-parametric Kaplan-Meier (KM) estimation method was used to estimate the UCL as it can handle non-detect observations with multiple MRLs.

Table B2 lists the statistical results for SMA-1 soils. ProUCL output files are also included in this appendix.

Data Evaluation

If SMA-1 soils were re-used as fill at an off-site commercial/industrial property, they would undergo mixing as a result of site excavation and off-site placement and grading. For most contaminants, concentrations are below risk-based criteria for direct contact by occupational workers (Table B1). For benzo(a)pyrene and arsenic, statistical analysis was use to estimate the resultant concentration of the mixed, excess soil. Comparison of the 90% UCLs for these COPCs indicates that benzo(a)pyrene is below its occupational RBC and arsenic is consistent with its natural background concentration. As such, SMA-1 soils would not pose an unacceptable risk to occupational workers if re-used as fill at an off-site commercial/industrial property. Potential risks to construction or excavation workers are also considered acceptable, as RBCs for these people are higher than for occupational workers.

Off-Site Re-use of SMA-1 Soils

Evaluation of SMA-1 soil data indicates that it would not pose an unacceptable risk to occupational workers if used as fill at an off-site commercial/industrial property. For soil used in this manner, however, it is anticipated that it cannot be placed where it could encounter groundwater, where it could erode to a surface water body, or where significant ecological habitat is present. Before SMA-1 soils could be transported and re-used off the site, a BUD would need to be prepared and approved by the DEQ pursuant to OAR 340-093-0260 to -0290. This appendix was included in this Contaminated Media Management Plan (CMMP) to demonstrate that SMA-1 soils could be re-used off the site per a BUD. Because risk-based criteria are constantly updated, however, the maximum and statistically-derived COPC concentrations (i.e., 90% UCLs) should be compared

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against current and applicable screening levels (RBCs, RSLs, and/or background concentrations) for the off-site location prior to development at the site. Based on this comparison, excess soils need to be handled in a manner consistent with the evaluation methods presented in this CMMP.

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Table B1 - SMA-1 Soil Data Summary and Initial Risk ScreeningSouth Waterfront Lot 3SW Moody Avenue and SW River Parkway, Portland, Oregon

Max Detect OccupationalDetection Detection Range of Sample Direct Contact

Analyte Frequency Percent Range of MRL Detection (Depth) Soil RBCTPH Concentration in mg/kg (ppm)

Diesel 10/35 29% 17.4 - 190 25 - 297 PB-11A (10) 70,000Oil 18/35 51% 58.1 - 70.4 74.2 - 2,060 MW-5 (3) 70,000

PAHs Non-Carcinogenic PAHs

Acenaphthene 4/25 16% 0.010 - 0.025 0.0166 - 0.183 MW-5 (3) 61,000Acenaphthylene 7/25 28% 0.010 0.0102 - 0.0400 MW-5 (3) -

Anthracene 6/25 24% 0.010 - 0.025 0.0163 - 0.317 MW-5 (3) 310,000Benzo(g,h,i)perylene 17/25 68% 0.010 0.0105 - 2.27 B1 (10) -

Fluoranthene 17/25 68% 0.010 0.0105 - 0.591 B1 (10) 2.23Fluorene 3/25 12% 0.010 - 0.025 0.0125 - 0.278 PB-2 (8) 41,000

Phenanthrene 13/25 52% 0.010 0.016 - 1.00 PB-2 (8) -Pyrene 17/25 68% 0.010 0.0166 - 1.21 MW-5 (3) 21,000

Carcinogenic PAHsBenz(a)anthracene 12/25 48% 0.010 0.0155 - 0.432 MW-5 (3) 2.7

Benzo(a)pyrene 18/25 72% 0.010 0.011 - 0.486 B1 (10) 0.27Benzo(b)fluoranthene 18/25 72% 0.010 0.0132 - 0.517 B1 (10) 2.7Benzo(k)fluoranthene 10/25 40% 0.010 0.012 - 0.133 B1 (10) 27

Chrysene 13/25 52% 0.010 0.011 - 0.521 MW-5 (3) 270Dibenzo(a,h)anthracene 7/25 28% 0.010 0.0119 - 0.105 B1 (10) 0.27Indeno(1,2,3-cd)pyrene 11/25 44% 0.010 0.014 - 0.242 B1 (10) 2.7

Naphthalene 5/25 20% 0.010 - 0.025 0.0188 - 0.0617 MW-5 (3) 23

Metals Antimony 1/11 9% 0.0101 - 0.516 1.00 MW-3 (3) 410a

Arsenic 19/19 100% na 1.97 - 8.83 MW-4 (3) 7b

Barium 8/8 100% na 140 - 160 HA-6 (0.5) 190,000Beryllium 0/11 0% 0.00101 - 0.0516 nd na 2,000Cadmium 11/19 58% - 2.26 - 3.5 MW-3 (3) 9,000

Chromium 19/19 100% na 8.77 - 22.8 MW-3 (3) 190Copper 11/11 100% na 10.7 - 74.9 B1 (10) 41,000

Lead 19/19 100% na 3.81 - 1,260 B1 (10) 800Mercury 13/19 68% - 0.017 - 1.88 MW-2 (10) 310

Nickel 11/11 100% na 9.6 - 19.5 B1 (10) 62,000Selenium 0/19 0% 0.0202 - 1.03 nd na 5,100a

Silver 2/19 11% 0.0101 - 1.03 1.00 - 1.02 MW-4 (10) 5,100Thallium 1/11 9% 0.0253 - 1.29 1.28 MW-4 (10) -

Zinc 11/11 100% na 41.7 - 597 B1 (10) 310,000a

Notes:1. Available chemical data was used for preparation of this table as provided from Appendix A tables.2. TPH results by Northwest Methodology, PAHs by EPA Method 8270-SIM, and metals by EPA Method 6000/7000-series. All results reported on a dry weight basis.3. Direct contact with soil RBCs for occupational workers from DEQ (2009), except for: aAntimony, selenium, and zinc where no RBCs were available, so EPA RSLs are presented (EPA, 2010); and bArsenic for which its background concentration of 7 mg/kg was used (DEQ, 2002).4. - = Not available.5. Shading indicates the maximum chemical concentration at the site exceeds the occupational worker RBC. These chemical compounds were carried forward for statistical analysis.

Acronyms:MRL = Method reporting limitna = Not applicablend = Not detectedPAHs = Polynuclear aromatic hydrocarbonsRBC = Risk-based concentrationRSL = Regional Screening LevelTPH = Total petroleum hydrocarbons

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Table B2 - Statistical Summary: SMA-1 SoilsSouth Waterfront Lot 3SW Moody Avenue and SW River Parkway, Portland, Oregon

OccupationalArithmetic Direct Contact

Analyte Mean Median Distribution Soil RBCPAHs Concentration in mg/kg (ppm) Carcinogenic PAHs

Benzo(a)pyrene 0.0904 0.028 Non-Parametric KM (Chebyshev) 0.134 0.270

Metals Arsenic 4.75 5.0 Normal Student's-t 5.37 7

Notes:1. ProUCL 4.00.04 used for all statistical calculations.2. For arithmetic mean and medians, only detected observations were used. 3. For data sets with no ND values, ProUCL was used to obtain the data distribution and UCL statistic. Non-parametric statistics were used to calculate UCLs where ND values were present; specifically, KM statistics were used so multiple MRLs could be handled.4. Direct contact with soil RBCs for occupational workers from DEQ (2009), except for arsenic for which its background concentration of 7 mg/kg was used (DEQ, 2002).

Acronyms:KM = Kaplan-MeierMRL = Method reporting limitPAHs = Polynuclear aromatic hydrocarbonsUCL = Upper confidence limit

Test 90% UCL

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App B Backup

Num Ds NumNDs % NDs Minimum Maximum Mean Median SD MAD/0.675 Skewness CV

18 7 28.00% 0.011 0.486 0.0904 0.028 0.122 0.0252 2.25 1.348

NumObs Minimum Maximum Mean Median Variance SD MAD/0.675 Skewness Kurtosis CV

19 1.97 8.83 4.75 5 4.124 2.031 2.595 0.334 -1.004 0.428

Variable

As

Summary Statistics for Raw Dataset with NDs

Raw Statistics using Detected Observations

Variable

BAP

From File: C:\SMA.wst

Summary Statistics for Raw Full Data Sets

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Note: DL/2 is not a recommended method.

95% Adjusted Gamma UCL 0.187

95% Gamma Approximate UCL 0.174

Nu star 9.427 Potential UCLs to Use

AppChi2 3.587 97.5% KM (Chebyshev) UCL 0.205

Theta star 0.352

k star 0.189 99% KM (Chebyshev) UCL 0.287

SD 0.11 97.5% KM (Chebyshev) UCL 0.205

Median 0.017 95% KM (Chebyshev) UCL 0.164

Mean 0.0664 95% KM (Percentile Bootstrap) UCL 0.108

Maximum 0.486 95% KM (BCA) UCL 0.102

Minimum 1E-09 95% KM (bootstrap t) UCL 0.134

Assuming Gamma Distribution 95% KM (z) UCL 0.104

Gamma ROS Statistics using Extrapolated Data 95% KM (jackknife) UCL 0.105

Data not Gamma Distributed at 5% Significance Level SE of Mean 0.022

95% KM (t) UCL 0.106

5% K-S Critical Value 0.211 SD 0.107

K-S Test Statistic 0.777 Mean 0.0682

A-D Test Statistic 1.144 Nonparametric Statistics

5% A-D Critical Value 0.777 Kaplan-Meier (KM) Method

nu star 24.76

k star (bias corrected) 0.688 Data do not follow a Discernable Distribution (0.05)

Theta Star 0.132

Gamma Distribution Test with Detected Values Only Data Distribution Test with Detected Values Only

95% BCA Bootstrap UCL 0.12

95% Percentile Bootstrap UCL 0.104

95% MLE (Tiku) UCL 0.0881 SD in Original Scale 0.11

95% MLE (t) UCL 0.0868 Mean in Original Scale 0.0658

SD 0.134 SD in Log Scale 1.792

Mean 0.0409 Mean in Log Scale -4.016

Maximum Likelihood Estimate(MLE) Method Log ROS Method

95% DL/2 (t) UCL 0.104 95% H-Stat (DL/2) UCL 0.121

SD 0.11 SD 1.444

Mean 0.0665 Mean -3.763

Assuming Normal Distribution Assuming Lognormal Distribution

DL/2 Substitution Method DL/2 Substitution Method

Data not Normal at 5% Significance Level Data not Lognormal at 5% Significance Level

5% Shapiro Wilk Critical Value 0.897 5% Shapiro Wilk Critical Value 0.897

Shapiro Wilk Test Statistic 0.69 Shapiro Wilk Test Statistic 0.875

UCL Statistics

Normal Distribution Test with Detected Values Only Lognormal Distribution Test with Detected Values Only

Maximum Non-Detect 0.01 Maximum Non-Detect -4.605

Minimum Non-Detect 0.01 Minimum Non-Detect -4.605

SD of Detected 0.122 SD of Detected 1.263

Mean of Detected 0.0904 Mean of Detected -3.166

Maximum Detected 0.486 Maximum Detected -0.722

Raw Statistics Log-transformed Statistics

Minimum Detected 0.011 Minimum Detected -4.51

Percent Non-Detects 28.00%

Number of Distinct Detected Data 17 Number of Non-Detect Data 7

General Statistics

Number of Valid Data 25 Number of Detected Data 18

BAP

Confidence Coefficient 95%

Number of Bootstrap Operations 2000

From File C:\SMA.wst

Full Precision OFF

General UCL Statistics for Data Sets with Non-Detects

User Selected Options

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Note: DL/2 is not a recommended method.

90% Gamma Approximate UCL 0.14 Recommendation Provided only

90% Adjusted Gamma UCL 0.146 for 95% Confidence Coeficient

Nu star 9.427

AppChi2 4.464 Potential UCL to Use

Theta star 0.352 99% KM (Chebyshev) UCL 0.287

k star 0.189 97.5% KM (Chebyshev) UCL 0.205

SD 0.11 95% KM (Chebyshev) UCL 0.164

Median 0.017 90% KM (Chebyshev) UCL 0.134

Mean 0.0664 90% KM (Percentile Bootstrap) UCL 0.0974

Maximum 0.486 90% KM (BCA) UCL 0.0921

Minimum 1E-09 90% KM (bootstrap t) UCL 0.113

Assuming Gamma Distribution 90% KM (z) UCL 0.0963

Gamma ROS Statistics using Extrapolated Data 90% KM (jackknife) UCL 0.0969

Data not Gamma Distributed at 5% Significance Level SE of Mean 0.022

90% KM (t) UCL 0.0971

5% K-S Critical Value 0.211 SD 0.107

K-S Test Statistic 0.777 Mean 0.0682

A-D Test Statistic 1.144 Nonparametric Statistics

5% A-D Critical Value 0.777 Kaplan-Meier (KM) Method

nu star 24.76

k star (bias corrected) 0.688 Data do not follow a Discernable Distribution (0.05)

Theta Star 0.132

Gamma Distribution Test with Detected Values Only Data Distribution Test with Detected Values Only

90% BCA Bootstrap UCL 0.104

90% Percentile Bootstrap UCL 0.0953

90% MLE (Tiku) UCL 0.0773 SD in Original Scale 0.11

90% MLE (t) UCL 0.0762 Mean in Original Scale 0.0658

SD 0.134 SD in Log Scale 1.792

Mean 0.0409 Mean in Log Scale -4.016

Maximum Likelihood Estimate(MLE) Method Log ROS Method

90% DL/2 (t) UCL 0.0955 90% H-Stat (DL/2) UCL 0.0984

SD 0.11 SD 1.444

Mean 0.0665 Mean -3.763

Assuming Normal Distribution Assuming Lognormal Distribution

DL/2 Substitution Method DL/2 Substitution Method

Data not Normal at 5% Significance Level Data not Lognormal at 5% Significance Level

5% Shapiro Wilk Critical Value 0.897 5% Shapiro Wilk Critical Value 0.897

Shapiro Wilk Test Statistic 0.69 Shapiro Wilk Test Statistic 0.875

UCL Statistics

Normal Distribution Test with Detected Values Only Lognormal Distribution Test with Detected Values Only

Maximum Non-Detect 0.01 Maximum Non-Detect -4.605

Minimum Non-Detect 0.01 Minimum Non-Detect -4.605

SD of Detected 0.122 SD of Detected 1.263

Mean of Detected 0.0904 Mean of Detected -3.166

Maximum Detected 0.486 Maximum Detected -0.722

Raw Statistics Log-transformed Statistics

Minimum Detected 0.011 Minimum Detected -4.51

Percent Non-Detects 28.00%

Number of Distinct Detected Data 17 Number of Non-Detect Data 7

General Statistics

Number of Valid Data 25 Number of Detected Data 18

BAP

Confidence Coefficient 90%

Number of Bootstrap Operations 2000

From File C:\SMA.wst

Full Precision OFF

General UCL Statistics for Data Sets with Non-Detects

User Selected Options

Page 45: Contaminated Media Management Plan South Waterfront Lot #3 ...

Potential UCL to Use Use 95% Student's-t UCL 5.558

95% Adjusted Gamma UCL 5.801

Assuming Gamma Distribution 99% Chebyshev(Mean, Sd) UCL 9.385

95% Approximate Gamma UCL 5.707

Data appear Gamma Distributed at 5% Significance Level 95% Chebyshev(Mean, Sd) UCL 6.781

97.5% Chebyshev(Mean, Sd) UCL 7.659

Kolmogorov-Smirnov 5% Critical Value 0.199 95% BCA Bootstrap UCL 5.521

Kolmogorov-Smirnov Test Statistic 0.197 95% Percentile Bootstrap UCL 5.478

Anderson-Darling 5% Critical Value 0.742 95% Hall's Bootstrap UCL 5.558

Anderson-Darling Test Statistic 0.59 95% Bootstrap-t UCL 5.629

95% Standard Bootstrap UCL 5.482

Adjusted Chi Square Value 145.7 95% Jackknife UCL 5.558

Adjusted Level of Significance 0.0369 95% CLT UCL 5.516

nu star 178

Approximate Chi Square Value (.05) 148.1 Nonparametric Statistics

MLE of Mean 4.75

MLE of Standard Deviation 2.195

k star (bias corrected) 4.683 Data appear Normal at 5% Significance Level

Theta Star 1.014

Gamma Distribution Test Data Distribution

95% Modified-t UCL 5.564 99% Chebyshev (MVUE) UCL 9.86

95% UCLs (Adjusted for Skewness) 95% Chebyshev (MVUE) UCL 6.999

95% Adjusted-CLT UCL 5.554 97.5% Chebyshev (MVUE) UCL 7.964

Assuming Normal Distribution Assuming Lognormal Distribution

95% Student's-t UCL 5.558 95% H-UCL 5.922

Data appear Normal at 5% Significance Level Data appear Lognormal at 5% Significance Level

Shapiro Wilk Critical Value 0.901 Shapiro Wilk Critical Value 0.901

Shapiro Wilk Test Statistic 0.929 Shapiro Wilk Test Statistic 0.933

Relevant UCL Statistics

Normal Distribution Test Lognormal Distribution Test

Skewness 0.334

Coefficient of Variation 0.428

SD 2.031

Median 5 SD of log Data 0.454

Mean 4.75 Mean of log Data 1.465

Maximum 8.83 Maximum of Log Data 2.178

Raw Statistics Log-transformed Statistics

Minimum 1.97 Minimum of Log Data 0.678

General Statistics

Number of Valid Observations 19 Number of Distinct Observations 15

As

Confidence Coefficient 95%

Number of Bootstrap Operations 2000

From File C:\SMA.wst

Full Precision OFF

General UCL Statistics for Full Data Sets

User Selected Options

Page 46: Contaminated Media Management Plan South Waterfront Lot #3 ...

Potential UCL to Use Recommendation Provided only for 95% Confidence Coefficient

90% Adjusted Gamma UCL 5.535

Assuming Gamma Distribution 99% Chebyshev(Mean, Sd) UCL 9.385

90% Approximate Gamma UCL 5.48

97.5% Chebyshev(Mean, Sd) UCL 7.659

Data appear Gamma Distributed at 5% Significance Level 90% Chebyshev(Mean, Sd) UCL 6.148

95% Chebyshev(Mean, Sd) UCL 6.781

Kolmogorov-Smirnov 5% Critical Value 0.199 90% BCA Bootstrap UCL 5.391

Kolmogorov-Smirnov Test Statistic 0.197 90% Percentile Bootstrap UCL 5.311

Anderson-Darling 5% Critical Value 0.742 90% Hall's Bootstrap UCL 5.368

Anderson-Darling Test Statistic 0.59 90% Bootstrap-t UCL 5.418

90% Standard Bootstrap UCL 5.324

Adjusted Chi Square Value 152.7 90% Jackknife UCL 5.37

Adjusted Level of Significance 0.0852 90% CLT UCL 5.347

nu star 178

Approximate Chi Square Value (.05) 154.3 Nonparametric Statistics

MLE of Mean 4.75

MLE of Standard Deviation 2.195

k star (bias corrected) 4.683 Data appear Normal at 5% Significance Level

Theta Star 1.014

Gamma Distribution Test Data Distribution

90% Modified-t UCL 5.376 99% Chebyshev (MVUE) UCL 9.86

90% Adjusted-CLT UCL 5.373 97.5% Chebyshev (MVUE) UCL 7.964

90% Chebyshev (MVUE) UCL 6.304

90% UCLs (Adjusted for Skewness) 95% Chebyshev (MVUE) UCL 6.999

Assuming Normal Distribution Assuming Lognormal Distribution

90% Student's-t UCL 5.37 90% H-UCL 5.618

Data appear Normal at 5% Significance Level Data appear Lognormal at 5% Significance Level

Shapiro Wilk Critical Value 0.901 Shapiro Wilk Critical Value 0.901

Shapiro Wilk Test Statistic 0.929 Shapiro Wilk Test Statistic 0.933

Relevant UCL Statistics

Normal Distribution Test Lognormal Distribution Test

Skewness 0.334

Coefficient of Variation 0.428

SD 2.031

Median 5 SD of log Data 0.454

Mean 4.75 Mean of log Data 1.465

Maximum 8.83 Maximum of Log Data 2.178

Raw Statistics Log-transformed Statistics

Minimum 1.97 Minimum of Log Data 0.678

General Statistics

Number of Valid Observations 19 Number of Distinct Observations 15

As

Confidence Coefficient 90%

Number of Bootstrap Operations 2000

From File C:\SMA.wst

Full Precision OFF

General UCL Statistics for Full Data Sets

User Selected Options