AT&T Hall Ridge Work Plan 03-07-2016

8/19/2019 AT&T Hall Ridge Work Plan 03-07-2016

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CB&I500 Penn Center Blvd.

Suite 1000Pittsburgh, PA 15235

Tel: 412.372.7701Fax: 412.380.4091

www.CBI.com

March 7, 2016 Project No. 156319

Mr. Geoffrey Brown Emergency Response Program Oregon Department of Environmental Quality Western Region – Eugene 165 E 7 th Ave, Suite 100 Eugene, OR 97401 ‐3049

Re: Path to Closure Work Plan AT&T Hall Ridge Cell Tower National Response Center Report No. 1140291 Oregon Emergency Response System Report No. 2016 ‐0374 Detroit, Marion County, Oregon

Dear Mr. Brown:

CB&I on the behalf of AT&T, is pleased to present this Path to Closure Work Plan for the post excavation

and characterization activities at the AT&T’s Hall Ridge, Detroit, Oregon, cell tower (Site). The

emergency response team, which consisted of CB&I, NRC, NWFF, and SMAF, have completed the initial

phase of the emergency response including the removal of impacted soil in the release area,

containment of the downslope migration of fuel, characterization of the impacted soil, snow removal,

and initial road repairs.

On February 11, 2016, Barry Williams (AT&T) received notification of a release of diesel at the subject

site. The initial investigation estimated the amount of fuel released from the tank system at 550 gallons.

It appeared the fuel was pumped from the 800 ‐gallon main tank to the 220 ‐gallon day tank, which

discharged from the vent located on the roof. Mr. Williams notified the National Response Center to

report the spill at 1740 Eastern Standard Time (EST). The National Response Center assigned Report No. 1140291 to the spill. Mr. Williams also notified the Oregon Emergency Response System at 1750 EST to

report the spill and was assigned Report No. 2016 ‐0374.

This Work Plan was developed to provide guidance for the implementation of bio ‐stimulation treatment

activities and post excavation and characterization monitoring.


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Mr. Geoffrey Brown ‐ 2 ‐ March 7, 2016

Background

The site and surrounding area are located on the U.S. Geological Survey 7.5 ‐minute Detroit, Oregon,

topographic quadrangle map. The site is located at approximately 44°43’09.7” north latitude,

122°13’03.6” west longitude. A review of the quadrangle map shows the site at an elevation of approximately 4,400 feet above mean sea level (msl). The nearest surface water to the site is an

unnamed tributary, which is approximately 600 feet northeast of the site. A site vicinity map is

presented as Figure 1.

According to the United States Geological Survey’s National Geologic Map Database, the site is located

on the eastern flank of the Sardine Syncline and the Breitenbush Anticline is located to the east. Bedrock

dips at a shallow angle to the west. Bedrock listed is the Sardine Series, which consists of series of

Miocene age rhyolite, andesite, basalt, tuff, and breccia exposed on Sardine Mountain northwest of

Detroit.

Emergency Response Tasks Completed

The following tasks have been completed under this emergency response:

On February 12, 2016, crews were mobilized to inspect the site. The impacted area was assessed and absorbent booms and pads placed in strategic areas to capture the free phase diesel.

From February 13 through February 19, 2016 – Road clearing continued with additional snow fall. Several impacted areas were hand excavated. Absorbent pads inspected and replaced. Waste was containerized and staged for disposal.

On February 22, 2016, the ORDEQ and USFS provisionally approved the Sampling and Analysis Plan.

On February 23, 2016, the USFS located and authorized NRC to collect water from a source near the site for the percolation test.

On February 24 ‐25, 2016, the percolation test commenced over a two ‐day period using fluorescent dye (Bright Dyes® FLT Yellow ‐Green Powder) to recreate the flow paths of diesel fuel through bedrock.

On February 26, 2016, soil samples were collected on a 20 ‐foot grid to delineate the extent of the diesel in the shallow soil downslope from the release.

On Friday February 19, 2016, Sunday February 21, 2016, and Sunday February 28, 2016, four surface water samples were collected from the unnamed tributaries (SW‐01, SW‐02, SW‐03, and SW‐04) and SW‐05 on Thursday February 25, 2016. Daily inspections occur at the five surface water locations.


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Discussion of Soil Sample Results

On February 26, 2016, soil samples were taken from 21 locations at the release area excavation and downslope areas. Sample locations were identified using an established downslope grid and biased

where diesel fuel was visually observed (Figure 3). Soil samples were analyzed for diesel range organics

by NWTPH‐Dx, RBDM VOCs by EPA 8260B, and PAHs by EPA 8270D SIM. The laboratory analytical results

have been tabulated and presented in Table 1.

The soil sample results were compared against ORDEQ risk‐based concentrations (RBCs) for two

exposure pathways: soil ingestion, dermal contact, and inhalation (RBCSS), and soil leaching to

groundwater (RBCSW). Three sample locations showed NWTPH‐Dx concentrations that exceed RBCs via

either exposure pathway. These three “hot spot” locations (0C, 1C, and 2C) follow the centerline of the

downslope grid, adjacent to the release area excavation.

At sample location 0C, laboratory results show RBC exceedances for NWTPH‐Dx (9,430 milligrams per

kilogram [mg/kg]), Benzene (0.161 mg/kg), Ethylbenzene (3.70 mg/kg), Naphthalene (2.15 mg/kg), and

1,2,4 ‐Trimethylbenzene (19.9 mg/kg). At sample location 1C, results show RBC exceedance for NWTPH‐

Dx (66,400 mg/kg). At sample location 2C, results show RBC exceedance for NWTPH‐Dx (96,800 mg/kg).

NWTPH‐Dx concentrations were also observed at sample locations EW‐SIDEWALL‐E (184 mg/kg), 0B

(1,090 mg/kg), 1B (44.6 mg/kg), 2B (70.2 mg/kg), and 3A (29.1 mg/kg). These locations are directly

adjacent to the “hot spot” locations, with the exception of 3A. The NWTPH‐Dx concentrations at all

other sample locations were non ‐detect. The laboratory analytical results are presented in Appendix A.

Outcrop Source Removal

Diesel has accumulated on top of a bedrock outcrop located approximately 40 feet down slope from the

release area as indicated by soil analytical data, PID readings and site observation. Impacted soil on top

of the rock outcrop will be excavated to provide mass removal and eliminate known potential source

areas for future leaching of diesel. The limits of the excavation will extend approximately 4 feet upslope

from the rock outcrop, approximately 10 feet across the width of the rock outcrop, and extend

approximately 1 foot deep to bedrock. The limits of the excavation will be determined in the field using

a PID and field observations. Due to the extreme site conditions, the impacted soil will be excavated by hand.

Confirmation soil samples will be collected on the side walls of the excavation, estimated at two samples

along the top wall and one sample on each side walls of the excavation. The floor and down slope wall

of the excavation are anticipated to be bedrock; therefore, soil samples are not anticipated at these

locations. Soil samples will be analyzed for diesel range organics by NWTPH‐Dx, RBDM VOCs by EPA

8260B, and PAHs by EPA 8270D SIM.


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Bio‐stimulation

AT&T proposes to use a combination of two bio ‐stimulation products to naturally degrade residual

diesel at the Site. These products include Oil Spill Eaters International Corporation’s proprietary OSE II

and Micro ‐Blaze® Non ‐Formulated. Micro ‐Blaze® Non ‐Formulated is a consortium of hydrocarbon degrading bacteria that will be applied to the individual release areas in a 10% solution following the

application of OSE II. Micro ‐Blaze® Non ‐Formulated contains no surfactants or nutrients, just a

consortium of known hydrocarbon degrading bacteria.

AT&T proposes to use Oil Spill Eaters International Corporation’s proprietary OSE II amendment to

breakdown residual diesel LNAPL in the subsurface. OSE II is a bio ‐catalyst that contains enzymes and

nutrients designed to enhance the emulsification of LNAPL and stimulate hydrocarbon consuming

bacteria to degrade hydrocarbons released in the environment. Nutrients within OSE II will increase the

rate of biodegradation of the diesel ‐consuming bacteria present beneath the Site to remove the

dissolved diesel. OSE II has been evaluated by the Environmental Protection Agency and is listed as an

accepted remedial response technology for hydrocarbon releases (Environmental Protection Agency,

2009). The California Department of Wildlife (formerly Department of Fish and Game) has licensed OSE

II for oil spill treatment in California. Documentation of the OSE II is provided in Appendix B.

The application of the OSE II and Micro ‐Blaze® Non ‐Formulated is proposed in three areas. The first

application will be applied to a small trench excavated on the upgradient side of the AT&T

communication building. This will be conducted to treat residual diesel in the base course beneath the

building foundation. The second application will be in the release area excavation to introduce these

solutions into the subsurface following a similar pathway as the original release. The third application will be a surface application of these solutions within the limits of the downslope excavation following

the removal of impacted soil on top of the rock outcrop and the surface application of the soil between

the release area and rock outcrop. Documentation of Micro ‐Blaze® Non ‐Formulated is provided in

Appendix B. Each of these applications is discussed below.

Building Foundation Application OSE II/Micro ‐Blaze® Non ‐Formulated will be applied hydraulically upgradient of the AT&T

Communication building in an attempt to treat residual diesel residing in the base course beneath the

building foundation. A small trench will be excavated along the north footing of the building for the

application of the OSE II. The trench will be approximately 1 foot wide and 6 inches deep. Excavated material will be placed along the outside extent of the trench to form a berm. A licensed archeologist

will be on ‐site during all ground disturbance activities. Approximately 300 gallons of the OSE II solution

will be gravity fed into the trench at such a rate as to not overflow the trench, while maintaining a

constant head in the trench. Absorbent pads will be placed adjacent to the exposed base course along

the south side of the building to capture diesel that may be displaced during this procedure.


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Release Area Application OSE II will be applied within the limits of the release area in an effort to follow the same pathway as the

diesel during the original release. Approximately 900 gallons of OSE II solution will be applied on top of

the exposed bedrock in the release area excavation. The application rate will be consistent with the dye

test conducted on February 23, 2016 to evaluate flow pathways and maintained at a rate as to not

overflow the excavation. Absorbent pads located downslope of the excavation will be monitored and

replaced as necessary during this task.

Outcrop Excavation OSE II Application OSE II will be applied to the surface of the downslope outcrop excavation adjacent to the rock outcrop

and surrounding soil. Approximately 100 gallons of OSE II solution will be applied on top of the soil in the

area extending from the release area to the rock outcrop using a hose. The soil in this area is potentially

impacted based on soil analytical data and site observations. The application rate should be monitored

to prevent surface runoff, but sufficient to promote infiltration and near saturation. If the soil in the

treatment area becomes saturated to the point surface runoff occurs, the application rate will be

reduced. If surface water runoff continues to occur, the remaining volume of OSE II solution will be

applied to the release area. Absorbent pads located downslope of the impacted soil area will be

monitored and replaced as necessary during this task.

Mixing Procedure Micro ‐Blaze® Non ‐Formulated will be mixed to a 10% solution using 5 gallons of Micro ‐Blaze to 50

gallons of water. The water will be collected from the sample source used in the dye test, pending USFS

approval.

The OSE II application system will consist of a bulk mixing tank, one 55 gallon drum of OSE II, a circulation pump, and associated hoses, valves, and fittings. The application system will be powered by

an existing onsite generator. Surface water from a nearby stream will be used to blend with the OSE II to

make the 25:1 solution of water to OSE II, pending USFS approval. Approximately 1,375 gallons of the

OSE II/surface water solution will be applied in and around the release area. It is anticipated that the

OSE II/surface water solution will be prepared in 300 ‐gallon batches for application; therefore, 12

gallons of OSE II will be mixed with 300 gallons of water to prepare the 25:1 solution.

Surface Water Sampling

Currently, CB&I performs a daily visual inspection of five unnamed tributaries (SW‐01, SW‐02, SW‐03, SW‐04, and SW‐05) and collects weekly surface water samples from these locations on a weekly basis.

These surface water samples are analyzed for RBDM VOCs by EPA Method 8260B and PAHs by EPA

Method 8270D SIM. No VOCs or PAHs have been detected in any of the surface water samples collected

from the identified streams. The laboratory analytical results have been tabulated and presented in

Table 2. Surface water sample locations are presented in Figure 4.


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Surface water samples will be collected 30 days, 90 days, and 180 days following the application of OSE

II to monitor potential impact to the adjacent surface water streams. Surface water sampling will be

discontinued following the 180 day sampling event if the analytical results remain below laboratory

detection limits. Approval will be requested from ORDEQ and USFS to discontinue the sampling program

if no VOCs or PAHs have been detected in the surface water following the 180 days of post bio ‐

stimulation sampling.

In the event that any RBDM VOCs and PAHs are detected in the surface water samples above the

applicable standards, then the surface water sampling plan will be amended to collect samples further

downstream and/or at the reservoir discharge locations. The new surface water locations and the

number of collected samples will be approved by ORDEQ and USFS.

Data from the sampling will be submitted to the ORDEQ and USFS in status reports. The status reports

will provide a brief summary of the analytical results and confirm the future sampling frequency.

Absorbent and Weir Maintenance

After excavation of the source area, crews established a downslope catchment system including a weir

and trenches containing absorbent booms, and absorbent pads interweaved across the exposed

bedrock seepage areas. Crews are monitoring the absorbents daily and replacing them as needed.

Saturated absorbents are containerized in Super Sacs and removed offsite to a landfill.

Following application of the OSE II treatment, crews will continue to change out absorbent pads and/or

booms along the downslope hillside on a weekly basis. In the event that no color change in the

absorbents is observed for 30 days, then crews will remove absorbents and booms from the site and backfill the weir, trenches, and potholes. Crews will restore the site as close as possible to pre ‐

disturbance drainage conditions.

Site Restoration

Release area The release area excavation and adjacent area will be restored to pre ‐excavation conditions following

the bio ‐stimulation application. Approximately 4‐inch layer of peat moss will be applied adjacent to the

exposed building footing and over the exposed bedrock with previously observed contact with diesel.

The diesel readily binds with peat moss until it naturally biodegrades, preventing any residual diesel from migrating offsite. Sufficient gravel will be placed over the peat moss to restore the site to near pre ‐

excavation grade. Clean gravel that was excavated during the initial response and temporarily

stockpiled adjacent to the excavation will be used as fill material. Additional gravel from an offsite

source consisting of 3/4 ‐inch minus will be applied to the excavation to restore the area to the original

grade. Fill material will be applied in 6‐inch lifts and compacted by driving over the fill material with the

equipment. The area will be graded to promote positive drainage away from the building.


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Outcrop Excavation The outcrop excavation and adjacent area will be restored to pre ‐excavation conditions following the

bio ‐stimulation application. Approximately 4‐inch layer of peat moss will be applied adjacent to the exposed bedrock with previously observed contact with diesel. Top soil will be applied on top of the

peat moss in 6‐inch lifts and hand compacted until the elevation of the fill material is consistent with the

surrounding topography. Grass matting will be applied over the top soil to minimize erosion.

Recommendation

Please provide your written approval if this Work Plan is acceptable or let us know if you have any

questions, comments, or revisions. If necessary, the Work Plan will be revised and resubmitted for your

approval. Thank you for your time during our on ‐site meetings and for your responsiveness in working

with us to develop this Plan.

Please contact either of the undersigned if you have any questions concerning this report.

Sincerely:

Ronald Malec, P.G. Kent Roberts

Incident Commander,

Unit

Chief

Senior

Operations

Manager

412 ‐380 ‐4484 321 ‐543 ‐1194 [email protected] [email protected]

MF:KR:RM:lmk Attachments

cc: Lauren Plunk (AT&T) Bryn Thoms (ORDEQ) Greg Aitken (ORDEQ) Grady McMahan (USFS) Darrin Neff (USFS) Jamie Sheahan Alonso (USFS) Penny Keen (USFS) Mark Finney (CB&I) Bryan Holmes (CB&I)


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Tables


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1A 1B 1C 2A 2B

Contaminant (mg/kg) (mg/kg) (mg/kg) (mg/kg) (mg/kg) (mg/kg) (mg/kg)

PID Reading (ppm) ‐‐‐ ‐‐‐ 5.4 6.4 397 2.7 1.9NWTPH‐Dx: Diesel 9,500 4,600 ND 44.6 66,400 ND 70.NWTPH‐Dx: Oil > Max 11,000 123 159 ND ND 312Benzene 0.10 300 ND ND ND ND N

Toluene 310 28,000 ND ND ND ND N

Ethylbenzene 0.94 1,700 ND ND ND ND N

Xylenes 49 20,000 ND ND ND ND N

Naphthalene 0.37 580 ND ND ND ND N

MTBE 0.50 12,000 ND ND ND ND N

Isopropylbenzene 280 27,000 ND ND ND ND N

n‐Propylbenzene No Std. No Std. ND ND ND ND N1,2,4 ‐Trimethylbenzene 5.6 2,000 ND ND ND ND N1,3,5 ‐Trimethylbenzene 110 3,500 ND ND ND ND N1,2 ‐Dibromoethane (EDB) 0.00056 9 ND ND ND ND N1,2 ‐Dichloroethane (EDC) 0.013 200 ND ND ND ND N

Table 1Soil Sample Analytical Results

AT&T Hall Ridge

Willamette National ForestDetroit, Oregon

Oregon Emergency Response System Report No. 2016 ‐0374

Soil Sample Analytical Results

RBCss 2RBCsw

1

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1A 1B 1C 2A 2B


Acenaphthene ‐‐‐ 21,000 ND ND NA ND NAcenaphthylene No Std. No Std. ND ND NA ND NAnthracene ‐‐‐ 110,000 ND ND NA ND NBenz(a)anthracene 2.3 24 ND ND NA ND N

Benzo(a)pyrene 1.9 2.4 ND ND NA ND N

Benzo(b)fluoranthene ‐‐‐ 24 ND ND NA ND NBenzo(k)fluoranthene ‐‐‐ 240 ND ND NA ND NBenzo(g,h,i)perylene No Std. No Std. ND ND NA ND NChrysene ‐‐‐ 2,400 ND ND NA ND NDibenz(a,h)anthracene ‐‐‐ 2.4 ND ND NA ND NDibenzofuran No Std. No Std. ND ND NA ND NFluoranthene ‐‐‐ 10,000 ND ND NA ND NFluorene ‐‐‐ 14,000 ND ND NA ND NIndeno(1,2,3 ‐cd)pyrene ‐‐‐ 24 ND ND NA ND N1‐Methylnaphthalene No Std. No Std. ND ND NA ND N2‐Methylnaphthalene No Std. No Std. ND ND NA ND NNaphthalene 0.37 580 ND ND NA ND N

Phenanthrene No Std. No Std. ND ND NA ND NPyrene ‐‐‐ 7,500 ND ND NA ND N


RBCss 2RBCsw

1

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3A 3B 3C 3D 4A


PID Reading (ppm) ‐‐‐ ‐‐‐ 3.3 2.0 3.3 1.7 3.4NWTPH‐Dx: Diesel 9,500 4,600 29.1 ND ND ND NDNWTPH‐Dx: Oil > Max 11,000 116 ND 98.7 ND 117Benzene 0.10 300 ND ND ND ND N

Toluene 310 28,000 ND ND ND ND N

Ethylbenzene 0.94 1,700 ND ND ND ND N

Xylenes 49 20,000 ND ND ND ND N

Naphthalene 0.37 580 ND ND ND ND N


Isopropylbenzene 280 27,000 ND ND ND ND N

n‐Propylbenzene No Std. No Std. ND ND ND ND N1,2,4 ‐Trimethylbenzene 5.6 2,000 ND ND ND ND N1,3,5 ‐Trimethylbenzene 110 3,500 ND ND ND ND N1,2 ‐Dibromoethane (EDB) 0.00056 9 ND ND ND ND N1,2 ‐Dichloroethane (EDC) 0.013 200 ND ND ND ND N


RBCss 2RBCsw

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3A 3B 3C 3D 4A


Acenaphthene ‐‐‐ 21,000 ND ND ND ND NAcenaphthylene No Std. No Std. ND ND ND ND NAnthracene ‐‐‐ 110,000 ND ND ND ND NBenz(a)anthracene 2.3 24 ND ND ND ND N

Benzo(a)pyrene 1.9 2.4 ND ND ND ND N

Benzo(b)fluoranthene ‐‐‐ 24 ND ND ND ND NBenzo(k)fluoranthene ‐‐‐ 240 ND ND ND ND NBenzo(g,h,i)perylene No Std. No Std. ND ND ND ND NChrysene ‐‐‐ 2,400 ND ND ND ND NDibenz(a,h)anthracene ‐‐‐ 2.4 ND ND ND ND NDibenzofuran No Std. No Std. ND ND ND ND NFluoranthene ‐‐‐ 10,000 ND ND ND ND NFluorene ‐‐‐ 14,000 ND ND ND ND NIndeno(1,2,3 ‐cd)pyrene ‐‐‐ 24 ND ND ND ND N1‐Methylnaphthalene No Std. No Std. ND ND ND ND N2‐Methylnaphthalene No Std. No Std. ND ND ND ND NNaphthalene 0.37 580 ND ND ND ND N

Phenanthrene No Std. No Std. ND ND ND ND NPyrene ‐‐‐ 7,500 ND ND ND ND N


RBCss 2RBCsw

1

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Ex Side4D 0A 0B 0C S


PID Reading (ppm) ‐‐‐ ‐‐‐ 1.2 0.9 10.5 36.8 5.0NWTPH‐Dx: Diesel 9,500 4,600 ND ND 1,090 9,430 NDNWTPH‐Dx: Oil > Max 11,000 ND ND ND ND NBenzene 0.10 300 ND ND ND 0.161 ND

Toluene 310 28,000 ND ND 0.224 2.93 ND

Ethylbenzene 0.94 1,700 ND ND 0.200 3.70 ND

Xylenes 49 20,000 ND ND 1.04 20.6 ND

Naphthalene 0.37 580 ND ND ND 2.15 ND


Isopropylbenzene 280 27,000 ND ND ND 1.03 ND

n‐Propylbenzene No Std. No Std. ND ND 0.162 3.82 ND1,2,4 ‐Trimethylbenzene 5.6 2,000 ND ND 0.755 19.9 ND1,3,5 ‐Trimethylbenzene 110 3,500 ND ND 0.264 6.59 ND1,2 ‐Dibromoethane (EDB) 0.00056 9 ND ND ND ND N1,2 ‐Dichloroethane (EDC) 0.013 200 ND ND ND ND N


RBCss 2RBCsw

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Ex Side4D 0A 0B 0C S


Acenaphthene ‐‐‐ 21,000 ND ND ND ND NAcenaphthylene No Std. No Std. ND ND ND ND NAnthracene ‐‐‐ 110,000 ND ND ND ND NBenz(a)anthracene 2.3 24 ND ND ND ND N

Benzo(a)pyrene 1.9 2.4 ND ND ND ND N

Benzo(b)fluoranthene ‐‐‐ 24 ND ND ND ND NBenzo(k)fluoranthene ‐‐‐ 240 ND ND ND ND NBenzo(g,h,i)perylene No Std. No Std. ND ND ND ND NChrysene ‐‐‐ 2,400 ND ND ND ND NDibenz(a,h)anthracene ‐‐‐ 2.4 ND ND ND ND NDibenzofuran No Std. No Std. ND ND 0.0620 0.376 NDFluoranthene ‐‐‐ 10,000 ND ND ND ND NFluorene ‐‐‐ 14,000 ND ND ND 0.454 NDIndeno(1,2,3 ‐cd)pyrene ‐‐‐ 24 ND ND ND ND N1‐Methylnaphthalene No Std. No Std. ND ND 0.114 3.29 ND2‐Methylnaphthalene No Std. No Std. ND ND 0.155 5.58 NDNaphthalene 0.37 580 ND ND ND 2.08 ND

Phenanthrene No Std. No Std. ND ND 0.0489 0.740 NDPyrene ‐‐‐ 7,500 ND ND 0.0411 0.389 ND

RBCsw 1


RBCss 2

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Notes:

Bold = Soil Sample analytical results exceeded applicable standard.

mg/kg = milligrams per kilogram.

MTBE = Methyl tert ‐butyl ether

No Std. = No standard listed in Risk Based Concentrations for Individual Chemicals State of Oregon Department of Environmental Q

PID = Photoionization detector readings are reported in parts per million (ppm).

Soil samples were collected on February 26, 2016.

ND = Concentration not detected at the laboratory method detection limit.NA = Not Analyzed

Analytical Results were compared to the Oregon standards for the Soils Leaching to Groundwater (RCBsw) Urban Residential and tDermal Contact and Inhulation (RCBss) Construction Worker. The lowere of the two values was selected for comparison to the ana

‐‐‐ = All RBC values for indirect pathways that exceed a limit (Csat, S, or Pv) are removed from the Risk‐Based Concentrations For In

> Max = The constituent RBC for this pathway is calculated as greater than 1,000,000 mg/kg or 1,000,000 mg/L. Therefore, this subthis scenario.

2 Risk‐Based Concentrations For Individual Chemicals (State of Oregon Department of Environmental Quality), Soils Leaching to SoiInhalation (RBCss), Construction Worker dated November 1, 2015.

1 Risk‐Based Concentrations For Individual Chemicals (State of Oregon Department of Environmental Quality), Soils Leaching to Grdated November 1, 2015.

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SW‐01 Unnamed Tributary SW ‐01 SW ‐01 SW ‐01 SW ‐01 SW ‐01

02/19/16 02/21/16 02/28/16

Contaminant (μ g/L) (μ g/L) (μ g/L) (μ g/L) (μ g/L) (μ g/L)

NWTPH‐Dx: Diesel 100 ND NA NA ‐‐ ‐‐

NWTPH‐Dx: Oil 300 ND NA NA ‐‐ ‐‐

Benzene 2.0 ND ND ND ‐‐ ‐‐

Toluene 4,400 ND ND ND ‐‐ ‐‐

Ethylbenzene 6.7 ND ND ND ‐‐ ‐‐ Xylenes 710 ND ND ND ‐‐ ‐‐ Naphthalene 0.78 ND ND ND ‐‐ ‐‐

MTBE 64 ND ND ND ‐‐ ‐‐

Isopropylbenzene 1,800 ND ND ND ‐‐ ‐‐

n ‐Propylbenzene No Std. ND ND ND ‐‐ ‐‐

1,2,4 ‐Trimethylbenzene 54 ND ND ND ‐‐ ‐‐

1,3,5 ‐Trimethylbenzene 500 ND ND ND ‐‐ ‐‐ 1,2 ‐Dibromoethane (EDB) 0.034 ND ND ND ‐‐ ‐‐

1,2 ‐Dichloroethane (EDC) 0.78 ND ND ND ‐‐ ‐‐

Table 2Water Sample Analytical Results

AT&T Hall Ridge


Oregon Emergency Response System Report No. 2016 ‐ 0374

Water Sample Analytical Results

RBCtw 1

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SW‐01 Unnamed Tributary SW ‐01 SW ‐01 SW ‐01 SW ‐01 SW ‐01

02/19/16 02/21/16 02/28/16


Acenaphthene 2,400 ND ND ND ‐‐ ‐‐

Acenaphthylene No Std. ND ND ND ‐‐ ‐‐

Anthracene ‐‐‐ ND ND ND ‐‐ ‐‐

Benz(a)anthracene 0.043 ND ND ND ‐‐ ‐‐

Benzo(a)pyrene 0.011 ND ND ND ‐‐ ‐‐ Benzo(b)fluoranthene 0.11 ND ND ND ‐‐ ‐‐ Benzo(k)fluoranthene ‐‐‐ ND ND ND ‐‐ ‐‐

Benzo(g,h,i)perylene No Std. ND ND ND ‐‐ ‐‐

Chrysene ‐‐‐ ND ND ND ‐‐ ‐‐

Dibenz(a,h)anthracene 0.011 ND ND ND ‐‐ ‐‐

Dibenzofuran No Std. ND ND ND ‐‐ ‐‐

Fluoranthene ‐‐‐ ND ND ND ‐‐ ‐‐ Fluorene 1,400 ND ND ND ‐‐ ‐‐ Indeno(1,2,3 ‐cd)pyrene 0.11 ND ND ND ‐‐ ‐‐

1‐Methylnaphthalene No Std. ND ND ND ‐‐ ‐‐


Naphthalene 0.78 ND ND ND ‐‐ ‐‐

Phenanthrene No Std. ND ND ND ‐‐ ‐‐ Pyrene ‐‐‐ ND ND ND ‐‐ ‐‐


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Benzene 2.0 ND ND ‐‐ ‐‐ ‐‐

Toluene 4,400 ND ND ‐‐ ‐‐ ‐‐

Ethylbenzene 6.7 ND ND ‐‐ ‐‐ ‐‐

Xylenes 710 ND ND ‐‐ ‐‐ ‐‐

Naphthalene 0.78 ND ND ‐‐ ‐‐ ‐‐ MTBE 64 ND ND ‐‐ ‐‐ ‐‐ Isopropylbenzene 1,800 ND ND ‐‐ ‐‐ ‐‐

n ‐Propylbenzene No Std. ND ND ‐‐ ‐‐ ‐‐

1,2,4 ‐Trimethylbenzene 54 ND ND ‐‐ ‐‐ ‐‐

1,3,5 ‐Trimethylbenzene 500 ND ND ‐‐ ‐‐ ‐‐

1,2 ‐Dibromoethane (EDB) 0.034 ND ND ‐‐ ‐‐ ‐‐

1,2 ‐Dichloroethane (EDC) 0.78 ND ND ‐‐ ‐‐ ‐‐


RBCtw

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Acenaphthene 2,400 ND ND ‐‐ ‐‐ ‐‐

Acenaphthylene No Std. ND ND ‐‐ ‐‐ ‐‐

Anthracene ‐‐‐ ND ND ‐‐ ‐‐ ‐‐

Benz(a)anthracene 0.043 ND ND ‐‐ ‐‐ ‐‐

Benzo(a)pyrene 0.011 ND ND ‐‐ ‐‐ ‐‐ Benzo(b)fluoranthene 0.11 ND ND ‐‐ ‐‐ ‐‐ Benzo(k)fluoranthene ‐‐‐ ND ND ‐‐ ‐‐ ‐‐

Benzo(g,h,i)perylene No Std. ND ND ‐‐ ‐‐ ‐‐

Chrysene ‐‐‐ ND ND ‐‐ ‐‐ ‐‐

Dibenz(a,h)anthracene 0.011 ND ND ‐‐ ‐‐ ‐‐

Dibenzofuran No Std. ND ND ‐‐ ‐‐ ‐‐

Fluoranthene ‐‐‐ ND ND ‐‐ ‐‐ ‐‐ Fluorene 1,400 ND ND ‐‐ ‐‐ ‐‐ Indeno(1,2,3 ‐cd)pyrene 0.11 ND ND ‐‐ ‐‐ ‐‐

1‐Methylnaphthalene No Std. ND ND ‐‐ ‐‐ ‐‐

2‐Methylnaphthalene No Std. ND ND ‐‐ ‐‐ ‐‐

Naphthalene 0.78 ND ND ‐‐ ‐‐ ‐‐

Phenanthrene No Std. ND ND ‐‐ ‐‐ ‐‐ Pyrene ‐‐‐ ND ND ‐‐ ‐‐ ‐‐


RBCtw

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Notes:

(μ g/L) = micrograms per liter.

MTBE = Methyl tert ‐butyl ether

No Std. = No Standard Listed

ND = Concentration not detected at the laboratory reporting limit.

NA = Not Analyzed ‐‐‐ = All RBC values for indirect pathways that exceed a limit (Csat, S, or Pv) are removed from the Risk‐Based Concentrations Fo

1 Risk‐Based Concentrations For Individual Chemicals (State of Oregon Department of Environmental Quality), Groundwater Ing

(RBCtw), Urban Residential dated November 1, 2015.

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Figures


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Appendix A

Draft Laboratory Analytical Results


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12232 S.W. Garden PlaceTigard, OR 97223 503-718-2323 Phone 503-718-0333 Fax

Apex Labs

NRC-CB&I

RE: AT&T Hall Ridge / 156319

Portland, OR 972176211 N Ensign St

Ron Malec

Enclosed are the results of analyses for work order A6B0900, which was received by the laboratory on2/27/2016 at 9:15:00AM.

Thank you for using Apex Labs. We appreciate your business and strive to provide the highest qualityservices to the environmental industry.

If you have any questions concerning this report or the services we offer , please feel free to contact me byemail at: [email protected], or by phone at 503-718-2323.

Sunday, February 28, 2016

DRAFT REPORT, DATA SUBJECT TO CHANGE

DRAFT REPORT The results provided in this report are PRELIMINARY and are subject to change basedon subsequent analysis, QC validation or final data review. Please use these resultswith the understanding that they may have not been finalized by the laboratory

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Apex Labs12232 S.W. Garden PlaceTigard, OR 97223 503-718-2323 Phone 503-718-0333 Fax

Portland, OR 97217 02/28/16 12:19Ron Malec

6211 N Ensign St

NRC-CB&I

Reported:

Project Manager:

Project Number:

AT&T Hall RidgeProject:

156319

ANALYTICAL SAMPLE RESULTS

Diesel and/or Oil Hydrocarbons by NWTPH-Dx

ResultAnalyte LimitReporting

Method NotesDilutionUnitsMDL Date Analyzed

Matrix: Soil1A (A6B0900-01) Batch: 6020836

NWTPH-Dxmg/kg dry 1Diesel 02/27/16 13:53 ND --- 28.6F-17Oil "" ""123 --- 57.2

"Surrogate: o-Terphenyl (Surr) Limits: 50-150 % "" Recovery: 88 %

Matrix: Soil1B (A6B0900-02) Batch: 6020836

F-17Diesel NWTPH-Dxmg/kg dry 02/27/16 14:33144.6 --- 32.2F-17Oil "" ""159 --- 64.3


Matrix: Soil1C (A6B0900-03) Batch: 6020835

Diesel NWTPH-Dxmg/kg dry 02/27/16 13:535066400 --- 2040

"" "Oil " ND --- 4080

S-01"Surrogate: o-Terphenyl (Surr) Limits: 50-150 % "" Recovery: %


NWTPH-Dxmg/kg dry 1Diesel 02/27/16 15:12 ND --- 26.1

"" "Oil " ND --- 52.2






Diesel NWTPH-Dxmg/kg dry 02/27/16 14:335096800 --- 2490

"" "Oil " ND --- 4970

S-01"Surrogate: o-Terphenyl (Surr) Limits: 50-150 % "" Recovery: %

Matrix: Soil2D (A6B0900-07) Batch: 6020836

NWTPH-Dxmg/kg dry 5Diesel 02/27/16 16:12 ND --- 180F-17Oil "" ""606 --- 360







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6211 N Ensign St

NRC-CB&I

Reported:

Project Manager:

Project Number:


156319







"" "Oil " ND --- 51.5



NWTPH-Dxmg/kg dry 1Diesel 02/27/16 17:31 ND --- 27.0F-17Oil "" ""98.7 --- 54.0




"" "Oil " ND --- 55.3



NWTPH-Dxmg/kg dry 1Diesel 02/27/16 17:31 ND --- 29.8F-17Oil "" ""117 --- 59.6




"" "Oil " ND --- 50.0


Matrix: Soil4C (A6B0900-14RE1) Batch: 6020836

NWTPH-Dxmg/kg dry 1Diesel 02/27/16 15:12 ND --- 28.9F-17Oil "" ""87.2 --- 57.7




"" "Oil " ND --- 50.0




"" "Oil " ND --- 69.1




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6211 N Ensign St

NRC-CB&I

Reported:

Project Manager:

Project Number:


156319






Diesel NWTPH-Dxmg/kg dry 02/27/16 15:5211090 --- 33.4

"" "Oil " ND --- 66.8



Diesel NWTPH-Dxmg/kg dry 02/27/16 16:3259430 --- 186"" "Oil " ND --- 372

S-05"Surrogate: o-Terphenyl (Surr) Limits: 50-150 % "" Recovery: 137 %

Matrix: SoilEx Sidewall S (A6B0900-19) Batch: 6020836


"" "Oil " ND --- 50.0


Matrix: SoilEx Sidewall W (A6B0900-20) Batch: 6020836


"" "Oil " ND --- 53.5


Matrix: SoilEx Sidewall E (A6B0900-21) Batch: 6020836

Diesel NWTPH-Dxmg/kg dry 02/27/16 16:521184 --- 25.0

"" "Oil " ND --- 50.0




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6211 N Ensign St

NRC-CB&I

Reported:

Project Manager:

Project Number:


156319


RBDM Compounds (BTEX+) by EPA 8260B




5035/8260Bmg/kg dry 50Benzene 02/27/16 13:54 ND --- 0.0217

"" "Toluene " ND --- 0.108

"" "Ethylbenzene " ND --- 0.0542

"" "Xylenes, total " ND --- 0.163

"" " Naphthalene " ND --- 0.217

"" "Methyl tert-butyl ether (MTBE) " ND --- 0.108

"" "Isopropylbenzene " ND --- 0.108

"" "n-Propylbenzene " ND --- 0.0542

"" "1,2,4-Trimethylbenzene " ND --- 0.108


"" "1,2-Dibromoethane (EDB) " ND --- 0.0542

"" "1,2-Dichloroethane (EDC) " ND --- 0.0542

"Surrogate: Dibromofluoromethane (Surr) Limits: 70-130 % "1 Recovery: 106 %

" 1,4-Difluorobenzene (Surr) Limits: 70-130 % "" 103 %

" Toluene-d8 (Surr) Limits: 70-130 % "" 100 %

" 4-Bromofluorobenzene (Surr) Limits: 70-130 % "" 97 %



"" "Toluene " ND --- 0.136



















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NRC-CB&I

Reported:

Project Manager:

Project Number:


156319






5035/8260Bmg/kg dry 50Toluene " ND --- 0.0812

















"" "Toluene " ND --- 0.177
















Benzene 5035/8260Bmg/kg dry 02/27/16 16:16500.0449 --- 0.0391

Toluene "" ""0.887 --- 0.195



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NRC-CB&I

Reported:

Project Manager:

Project Number:


156319






Ethylbenzene 5035/8260Bmg/kg dry "500.832 --- 0.0976

Xylenes, total "" ""4.74 --- 0.293




n-Propylbenzene "" ""0.642 --- 0.09761,2,4-Trimethylbenzene "" ""3.53 --- 0.195

1,3,5-Trimethylbenzene "" ""1.04 --- 0.195









"" "Toluene " ND --- 0.108

















"" "Toluene " ND --- 0.0801




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NRC-CB&I

Reported:

Project Manager:

Project Number:


156319






5035/8260Bmg/kg dry 50Xylenes, total " ND --- 0.120















"" "Toluene " ND --- 0.0782

















"" "Toluene " ND --- 0.0994





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NRC-CB&I

Reported:

Project Manager:

Project Number:


156319






5035/8260Bmg/kg dry 50 Naphthalene " ND --- 0.199














"" "Toluene " ND --- 0.103

















"" "Toluene " ND --- 0.0809






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NRC-CB&I

Reported:

Project Manager:

Project Number:


156319






5035/8260Bmg/kg dry 50Methyl tert-butyl ether (MTBE) " ND --- 0.0809













"" "Toluene " ND --- 0.0702

















"" "Toluene " ND --- 0.0491







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6211 N Ensign St

NRC-CB&I

Reported:

Project Manager:

Project Number:


156319






n-Propylbenzene 5035/8260Bmg/kg dry "500.162 --- 0.0680










Benzene 5035/8260Bmg/kg dry 02/27/16 16:29500.161 --- 0.0336

Toluene "" ""2.93 --- 0.168

Ethylbenzene "" ""3.70 --- 0.0840

Xylenes, total "" ""20.6 --- 0.252M-04Naphthalene "" ""2.15 --- 0.336


Isopropylbenzene "" ""1.03 --- 0.168

n-Propylbenzene "" ""3.82 --- 0.08401,2,4-Trimethylbenzene "" ""19.9 --- 0.168










"" "Toluene " ND --- 0.0386









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6211 N Ensign St

NRC-CB&I

Reported:

Project Manager:

Project Number:


156319






5035/8260Bmg/kg dry 501,2,4-Trimethylbenzene " ND --- 0.0386








Matrix: SoilEx Sidewall W (A6B0900-20) Batch: 6020834


"" "Toluene " ND --- 0.0594

















"" "Toluene " ND --- 0.0358










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6211 N Ensign St

NRC-CB&I

Reported:

Project Manager:

Project Number:


156319






5035/8260Bmg/kg dry 501,3,5-Trimethylbenzene " ND --- 0.0358









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6211 N Ensign St

NRC-CB&I

Reported:

Project Manager:

Project Number:


156319


Polyaromatic Hydrocarbons (PAHs) by EPA 8270D SIM




EPA 8270D (SIM)mg/kg dry 1Acenaphthene 02/27/16 14:05 ND --- 0.0143

"" "Acenaphthylene " ND --- 0.0143

"" "Anthracene " ND --- 0.0143

"" "Benz(a)anthracene " ND --- 0.0143

"" "Benzo(a)pyrene " ND --- 0.0143

"" "Benzo(b)fluoranthene " ND --- 0.0143

"" "Benzo(k)fluoranthene " ND --- 0.0143

"" "Benzo(g,h,i)perylene " ND --- 0.0143

"" "Chrysene " ND --- 0.0143

"" "Dibenz(a,h)anthracene " ND --- 0.0143

"" "Dibenzofuran " ND --- 0.0143

"" "Fluoranthene " ND --- 0.0143

"" "Fluorene " ND --- 0.0143

"" "Indeno(1,2,3-cd)pyrene " ND --- 0.0143

"" "1-Methylnaphthalene " ND --- 0.0143



"" "Phenanthrene " ND --- 0.0143"" "Pyrene " ND --- 0.0143

"Surrogate: 2-Fluorobiphenyl (Surr) Limits: 44-115 % "" Recovery: 87 %

" p-Terphenyl-d14 (Surr) Limits: 54-127 % "" 105 %



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NRC-CB&I

Reported:

Project Manager:

Project Number:


156319














"" "Chrysene " ND --- 0.0161




"" "Fluorene " ND --- 0.0161










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NRC-CB&I

Reported:

Project Manager:

Project Number:


156319














"" "Chrysene " ND --- 0.0130




"" "Fluorene " ND --- 0.0130










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NRC-CB&I

Reported:

Project Manager:

Project Number:


156319














"" "Chrysene " ND --- 0.0180




"" "Fluorene " ND --- 0.0180










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NRC-CB&I

Reported:

Project Manager:

Project Number:


156319













"" "Benzo(g,

Documents

AT&T Hall Ridge Work Plan 03-07-2016