Final Approved Nfamemo.Pdf

State of Oregon Department ofEnviromnental Quality Memorandum

Date: May 18, 2017 To: Kevin Parrett, Manager Northwest Region Cleanup and Tanks /' From: JenniferSutter, Project Manager PROVER�-./�-;.&./�s:S:::::==::'::_ Northwest Region Cleanup and Tanks Kevin Paqett, Manager J Subject: No Further Action Recommendation ATE f;/t2{1l 7 Shoreline Source Control I I Evraz Oregon Steel Mills ECSI #141

Purpose

This memo provides a summary of investigation and remedial action to prevent the transport of contaminated soil from the riverbank and upper beach along the Evraz Oregon Steel (EOS) site (Site) to the Willamette River. The EOS Site is located at 14400 N Rivergate Avenue, Portland, Oregon (see Figure 1). Oregon Steel Mills entered into a Voluntary Agreement with the Oregon Department of Environmental Quality (DEQ) in June 2000 to complete enviromnental work at the upland portion of the Site. EOS acquired OSM in 2007 and has been working under the Voluntary Agreement since that time. Several phases of site investigation and cleanup evaluation have been completed with Cleanup Program oversight. With EPA agreement, DEQ selected the riverbank source control measure for the Site in 2014 (EPA, 2014). The design was approved in 2015 afterreview and input fromEPA (EPA, 2015). A determination that the selected riverbank source control measure has been constructed consistent with the approved design and no further action (NF A), other than long-term monitoring and maintenance, is required for shoreline source control is proposed for the Site which requires the approval of the DEQ Cleanup Manager. A public notice for the proposed determination is attached.

Status of Other Source Control Pathways and Uplands

A source control decision addressing stormwater run-offfrom the facility was issued by DEQ in December 2010. A primaryelement of the stormwater source control action consists of end-of-pipe treatment, which has been implemented and is currently undergoing final design evaluations, including consideration of additional treatment using sand filters and the addition of a coagulant.

A No Further Action proposal for groundwater source control at the facility has been prepared and submitted to United States Enviromnental Protection Agency (EPA) for review as it relates to the Portland Harbor Superfund site. Additional sampling to address concerns raised by EPA is currentlyunder discussion. Memo to: Kevin Parrett 5/18/2017 Page 2

A risk assessment addressing potential upland exposures to contaminants has been approved by DEQ. EOS is preparing a feasibility study to address potential future worker exposures to upland contamination.

Background

The EOS facility is situated on the eastern bank of the Willamette River in the Rivergate industrial area of Portland, Oregon. The facility covers approximately 145 acres and has a physical address of 14400 N Rivergate Avenue. The facility layout is shown in Figure 2.

Gilmore Steel, a predecessor of EOS, purchased the EOS property from the Port of Portland in 1967. Prior to the purchase, the Port authorized Shaver Transportation and others to operate a former oil sump (the Ramsey Lakes Sump Area) on the Port property from approximately 1942 to 1960. The former sump was used for the disposal of ship bilge water and other waste oils and fluids.

During the time of Port ownership, the Port filled much of the portion of the property outside the sump area with dredge materials from the Willamette River, currently part of the Portland Harbor Superfund site. Fill material consisting of slag from steel making mixed with soil was also placed on the Site by Oregon Steel Mills periodically during plant expansion and construction activities. This mixed slag-soil fill is present as near surface fill across much of the facility; however, the thickness and character of the fill (e.g., amount of fine-grained soil mixed with the slag) vary somewhat across the facility. The mixed slag-soil fill forms a dense, semi- consolidated unit with a thickness of approximately two to ten feet across much of the facility, thickening at the riverbank to approximately fifteen feet. The berm at the top of the riverbank contains stormwater runoff from the Site (landward of the riverbank) and routes it through the stormwater treatment system, thereby preventing direct runoff of stormwater in contact with the slag-soil fill to the river.

No known industrial activities occurred at the Site between the closure of the former oil sump and construction of the steel mill, which was completed in 1969. Since 1969, the facility has been used for steel production and related ancillary operations. The EOS facility includes several large industrial process buildings (e.g., combination rolling mill, cut to length facility, former melt shop (currently used for storage), surface processing pipe mill, and pipe coating mill), a maintenance building, water treatment facilities, office buildings, parking lots, and materials processing and staging areas. The facility is primarily fenced with the exception of the western property boundary along the steep riverbank. The EOS facility property lies adjacent to the Portland Harbor Superfund site, which covers an approximate ten mile stretch of the lower Willamette River from River Mile 1.9 to 11.8. The property is surrounded by other industrial manufacturing and transfer facilities to the north, east, and south. The Willamette River forms the western property boundary. Memo to: Kevin Parrett 5/18/2017 Page 3

Geology/Hydrogeology

The area now occupied by the EOS facility is a historic floodplain between the Willamette and Columbia Rivers and is located approximately two miles upstream of the confluence of these rivers (i.e., River Mile 2). The native deposits at the Site consist of sands, silty sands and silts generally characteristic of river floodplains. The native deposits are overlain by various types of fill including dredge fill (which is similar to the native soil), slag-soil fill, and other localized fill units ranging in composition from silty sand to slag aggregate fill.

The dominant fill units at the EOS shoreline are as follows (starting from the most recent (uppermost) fill and working downward) (See Figure 3):

• Berm Fill – brown to yellow-brown, silty fine sand and fine grained sandy soils with some gravel. The fill soil was used to construct the berm along the western edge of the property for storm water control and aesthetic enhancement in 1995. Fill material used for the berm was generated onsite during excavation of the combination mill. Berm thickness ranges from five to ten feet. The berm is nearly continuous along the developed portion of the property with interruptions in two locations: at the northern end of the property providing access to the riverbank from the uplands, and in the central portion of the property where the dock extends from the uplands.

• Mixed Slag-Soil Fill – gray, gravel and silty to sandy gravel mixed with slag in many portions of the facility at a thickness of ten feet or less. The mixed slag-soil fill forms a dense, semi-consolidated unit. Along the riverbank area, the mixed slag-soil fill unit is wedge-shaped, thicker towards the river and has a maximum thickness of approximately fifteen feet, forming the near vertical portion of the bank. The slag-soil fill unit along the riverbank generally contains more fine- grained soil than the slag-soil unit across the rest of the property. The slag-soil fill was placed in the late 1960’s to early 1970’s.

• Dredge Fill – brown to gray, silty fine-grained sand used to fill the EOS property and the surrounding Rivergate Area from 1942 up to 1967. The dredge fill is exposed at the surface at the northern end of the riverbank. The dredge fill exposed at the north end of the property merges with slag-soil fill to the south. In many cases, the dredge fill unit is indistinguishable from the underlying alluvium unit based on similar texture and hydrology. The fill unit extends to depths of approximately 20 to 30 feet below ground surface (bgs) in the central and southern upland areas.

The upper groundwater bearing unit is a silty, fine sand encountered at a depth of 4 to 20 feet bgs (30 to 14 feet National Geodetic Vertical Datum 1929 (NGVD29)) and extending to the underlying aquitard at depths of 20 to 35 feet bgs (10 to -5 feet NGVD29). The sandy silt to silty clay aquitard is continuous beneath the Site and ranges in thickness from approximately 30 to 70 feet; vertical permeabilities are low (2.6 x 10-6 to 6.7 x 10-8 cm/sec). Memo to: Kevin Parrett 5/18/2017 Page 4

Shallow groundwater elevations measured in EOS upland groundwater monitoring wells range from approximately 26 feet NGVD29 in the eastern portion of the EOS facility to approximately 7 feet immediately upland of the berm. Groundwater elevation at the berm ranges from 7 to 10 feet NGVD29. In beach wells, the groundwater elevation is approximately 4 to 8 feet NGVD29. The groundwater levels fluctuate seasonally by 1.5 to 6 feet across the property, with the greatest fluctuations measured on the eastern side. Groundwater flows generally toward the west- southwest across the property (i.e., toward the Willamette River). Groundwater gradients range from approximately 0.002 to 0.003 feet/feet in the upland areas of the facility to approximately 0.03 to 0.06 feet/feet adjacent to the shoreline. Groundwater monitoring conducted from 2002 to 2005 indicates groundwater gradients and flow directions are seasonally consistent.

Willamette River levels along the shoreline range from a mean low water level of 4.1 to a mean high water level of 9.6 feet NGVD29. The ordinary high water (OHW) level is 16.6 feet and the 100-year flood level is 27.5 feet NGVD29. The mixed slag soil fill layer described above lies primarily between elevations 15 and 27 feet NGVD29.

Contaminants of Potential Concern

The nature and extent of contaminants of potential concern (COPCs) associated with the riverbank area have been assessed during several phases of investigation. These investigations identified polychlorinated biphenyls (PCBs) and metals (arsenic, cadmium, chromium, copper, lead, manganese, and zinc) as COPCs for the riverbank. Investigative samples of shoreline contaminated media were collected as part of the Pre-Remedial Investigation (Exponent, 2002), Phase I and IIA Remedial Investigations (Exponent 2004a and b, respectively), the Riverbank Source Control Evaluation (RETEC 2006), additional riverbank and upper beach soil sampling (AECOM, 2010), and pre-riverbank source control measure berm and upper beach sampling (Integral Consulting Inc., 2015).

PCBs and metals were detected in all riverbank samples collected, with the highest concentrations occurring in the mixed slag-soil fill layer. Based on the nature of the slag (i.e., generated from high temperature steel manufacturing processes that destroy any PCBs present on the metal surfaces), the PCBs were determined to be associated with the soil matrix in this layer as opposed to being a component of the slag itself. Potential sources of the PCBs include oils associated with the former oil sump, dredge material and other fill historically placed on the facility, hydraulic and electrical equipment at the EOS facility, and processed scrap metal.

COPC metals are present in slag and were detected throughout the EOS riverbank area, with the highest concentrations occurring in the mixed slag-soil layer. The magnitude of contamination along the riverbank has been defined by investigations conducted between 2002 and 2014. Sample locations and associated total PCB and metals concentrations are shown in Figures 4 through 8.

Record of Decision

A feasibility study (RETEC 2006a; RETEC 2006b; ENSR/AECOM 2008) was conducted to evaluate remedial options that met the following source control objectives: Memo to: Kevin Parrett 5/18/2017 Page 5

• Prevent further erosion of PCB- and metal-contaminated soil to the river at concentrations that exceed risk-based levels based on toxicity to aquatic life and food chain impacts to fish, birds, and humans via bioaccumulation.

• Employ measures that will be compatible with future remedial measures designed to address contaminated sediment adjacent to the beach.

• To the extent feasible, actively address hot spot contamination based on potential mobility and lack of containment of exposed soil proximal to the river and, while a risk assessment has not been completed for the Site, concentrations expected to reflect hot spot concentrations associated with risks to river-related receptors.

• While not covered under DEQ Cleanup authority, EOS has endeavored to maintain or improve existing aquatic and riparian habitat along the riverbank.

Three alternatives were evaluated considering the remedial factors set forth in OAR 340-122- 0090(3): No Action, Partial Removal/Capping/Shoreline Stabilization, and Complete Removal of Accessible Contaminated Bank Soils. Based on this evaluation, DEQ proposed the second alternative – Partial Removal, Capping, and Stabilization as the remedial action for the Site. This option addressed the primary exposure pathways to the river through a combination of removal and capping while maintaining the infrastructure (major utility lines, active roadway, and facility buildings). The costs of completely removing contaminated slag and soil along the EOS bank, in terms of absolute dollars as well as implementation risk and engineering challenges associated with the close proximity of mill infrastructure, were not commensurate with the potential benefits obtained. Partial removal and capping/stabilizing of remaining contamination with long-term monitoring and maintenance of engineering elements is expected to be effective in achieving remedial action objectives. Additional detail on the proposed approach was provided in the Revised Basis of Design/Conceptual Design memorandum (AECOM/Integral, 2013).

A public comment period was held on the proposed action in September 2014. Responses to comments are documented in the Record of Decision (ROD) for this Site issued in November 2014. While the general description of the selected remedial action was not changed, a portion of the shoreline stabilization design was modified as a result of discussions with the permitting agencies (National Oceanic and Atmospheric Administration (NOAA) Fisheries and United States Corps of Engineers (USACE)). In response to suggestions from NOAA to consider modifying a portion of the riprap bank to reduce the height of the riprap slope, EOS incorporated an “alcove” area into the northern portion of the shoreline in which the upper beach was extended further inland and the rock armor footprint was reduced.

The shoreline source control measures selected in the 2014 ROD included: 1. Clearing the bank action area of debris, constructing an access road, establishing stockpile areas for temporary storage of removed material, and identifying clean sources of backfill material. 2. Excavating soil, slag-soil fill, and upper beach material. Memo to: Kevin Parrett 5/18/2017 Page 6

3. Transporting and disposing of removed slag-soil fill at a permitted solid waste disposal facility. 4. Transporting removed beach and berm material to established upland containment areas. 5. Restoring the upper beach through placement of rounded well-graded river rock followed by planting with native trees and shrubs. 6. Capping an isolated removal area in the southern portion of the riverbank with clean soil followed by revegetation. 7. Constructing a cap/armoring layer along the bank consisting of a geotextile layer, a 1-foot thick layer of gravel, and a 3-foot thick layer of armor stone. The stabilized shoreline was designed to ensure that it would not erode under the stresses anticipated for the river; i.e., ship wakes, currents, including a 100-year flood and will be sufficiently stable to prevent recontamination during a moderate to large earthquake. 8. Stabilizing the berm slope using soil wraps incorporating living native riparian trees and shrubs. 9. Establishing long-term monitoring and maintenance protocols.

Implementation of Shoreline Source Control Action

DEQ approved the remedial design for the action with comments that were addressed in a June 2015 submittal which also addressed comments from EPA (Integral Consulting Inc./Crete Consulting, Inc., 2015a). USACE, Oregon Department of State Lands (DSL), DEQ and City of Portland permits and approvals were obtained. Site preparatory work including establishing haul routes, constructing the temporary disposal material management area (DMMA), locating and protecting utilities, and preparing onsite soil management areas began in June 2015. All work below the ordinary high water elevation (16.6 ft NGVD29) was completed between July 8 and October 20, 2015 during the in-water work window. Implementation included completion of the following primary tasks:

1. Constructing beach access ramps with sediment fencing riverward of the ramps to prevent erosion into the river. 2. Abandoning beach monitoring wells consistent with Oregon Water Resources Department (OWRD) regulations. 3. Clearing trees and large woody debris from the bank area. Large woody debris (trunk diameter exceeding 1-foot) was temporarily relocated and repositioned along the upper beach as habitat enhancement after the shoreline project was completed. 4. Excavating the riverward face of the majority of the berm and temporarily stockpiling the material for use as cover for material placed on the north side of the east landfill upland containment area. Berm slopes were temporarily covered with plastic sheeting to prevent erosion and maintain stability. 5. Excavating the slag-soil fill layer that comprised the bank face using an excavator positioned at the toe of the slope on the upper beach to achieve a stable horizontal to vertical design slope of 1.5:1. Material was loaded into off-road haul trucks staged on the upper beach. A mini-excavator, vactor truck, and hand tools were used to excavate material under the dock and around dock pilings. A total of 14,000 tons of slag/soil material was Memo to: Kevin Parrett 5/18/2017 Page 7

temporarily staged in the DMMA and subsequently trucked to a permitted Subtitle D landfill (Riverbend Landfill in McMinnville, Oregon). 6. Excavating the isolated pocket of PCB-impacted bank soil located south of the main stabilization area from the top of bank to a depth of 2.5 feet. 7. Excavating upper beach and north alcove soils as dictated by pre-construction beach sampling and as necessary to construct the trench toe required for stabilizing the reconstructed slope. Final depth of the upper beach and north alcove excavation ranged between 1.5 and 5 feet below surface grade. Material was hauled to designated upland disposal areas: either the north side of the east landfill or to the mold basement. (See Figure 2 for upland disposal area locations.) Approximately 4,700 cubic yards of beach soil were placed and compacted along the east landfill, covered with a geotextile indicator fabric, and covered with a 1-foot thick layer of berm soil (1,600 cubic yards) along with some imported soil. Jute matting was placed over the soil cap and hydroseeded. Approximately 3,700 cubic yards of beach soil were placed and compacted in the mold basement, covered with a geotextile indicator fabric and 6 inches of imported crushed rock. 8. Collecting samples of the new bank face prior to reconstruction of the slope to document conditions under the cap. PCB concentrations in this material ranged from 1,672 to 6,770 micrograms per kilogram (ug/kg). Elevated concentrations of arsenic, cadmium, chromium, manganese, and lead were also detected (see Figure 8). 9. Collecting soil samples at the base of the beach excavation prior to backfilling to determine where monitoring stakes would be required to identify areas where PCB concentrations exceeded 100 ug/kg at 3 feet bgs. Monitoring stakes were placed in three locations: the north alcove areas (NAPE-2, NAPE-3) and north of the dock (UBPE-2) (See Figures 9 and 10). 10. Analyzing all imported material used for backfilling excavations and reconstructing the upper beach, bank and berm, aside from the rock armor, for dioxins/furans, PCB Aroclors, metals, semi-volatile organic compounds, and pesticides to ensure it was not contaminated. 11. Reconstructing the bank face by placing a geotextile filtration fabric on the surface of the final bank excavation slope, placing 1.5-inch minus crushed rock on the surface of the geotextile, and placing Class 2000 rock armor on top of the crushed rock. In areas excavated by hand and vactor truck underneath the dock, Class 200 rock armor was placed by hand. The total post construction footprint of the rock armor is 0.96 acre. 12. Backfilling the small excavated area south of the main bank stabilization with 1-foot of Class 50 rock armor followed by placement of 1.5 feet of imported topsoil. 13. Backfilling the upper beach and north alcove the same day as the areas were excavated with imported 12-inch minus rounded river rock and sand blend. 14. Reconstructing the berm by placing and compacting imported berm material followed by placement of 2 feet of imported topsoil secured by jute matting. 15. Planting 331 cottonwood poles and 2,974 willow and dogwood livestakes in the upper beach. Planting a mix of 6,058 native trees and shrubs in the berm. The project results in 2.47 acres of native tree/shrub habitat. An additional 0.11 acres of native trees and shrubs were planted on the upper beach north of the project area. 16. Preparing a long-term monitoring and maintenance plan. Memo to: Kevin Parrett 5/18/2017 Page 8

17. Preparing an Easement and Equitable Servitude (EES) to file with the property deed identifying areas where contamination will be managed and referencing the long-term monitoring and maintenance plan.

EOS documented implementation of these measures in the Riverbank Source Control Measure Completion Report (Integral/Crete 2017). Comments on the report from DEQ and EPA have been addressed.

DEQ Conclusions

The Riverbank Source Control measures selected in DEQ’s ROD (DEQ 2014) have been successfully implemented at this Site. Actions were implemented consistent with the approved Final Design (Integral/Crete 2015a, b) with one minor exception. The design of the berm was modified during construction to provide a thicker layer of planting soil to enhance the overall moisture retention of the berm backfill. The change consisted of increasing the thickness of the planting soil to 2 feet, decreasing the quantity of aggregate berm backfill to accommodate the thicker planting soil layer, and incorporating the thicker planting soil layer into the geotextile reinforcement layer to maintain the overall stability of the berm. The modified berm backfill design stability was evaluated to ensure that no stability loss resulted from the change.

Long-term monitoring and maintenance will include assessment of vegetation, upper beach substrate, and the berm/bank control elements as well as the designated upland disposal areas (east landfill and mold basement) where some of the excavated beach and berm material was placed. Inspections will initially be conducted at least annually, with a potential reduction in reporting frequency following evaluation of containment measure performance. Monitoring will also be conducted following extreme events: river elevation exceeding flood stage or seismic event of magnitude 6.0 or larger that may impact stabilization elements. Inspections will include walking the length of the shoreline, assessing any areas of scour on the beach (particularly in those areas identified with marker stakes), photographing the shoreline from designated locations, and recommending and implementing maintenance where scour or slope failure is noted. Long-term monitoring also will include evaluation of the planting areas to limit invasive species and ensure establishment and continued development of the native vegetation planted.

Other than long-term monitoring and maintenance, EOS obligations under the Voluntary Agreement with respect to shoreline source control have been satisfied.

DEQ Recommendations

No further action is required to control shoreline sources of contamination beyond long-term monitoring and maintenance. Issuance of a conditional NFA determination for this aspect of Site source control work once the EES is approved and filed is therefore recommended. Memo to: Kevin Parrett 5/18/2017 Page 9

References

AECOM, 2010. Additional Riverbank and Upper Beach Soil Sampling Report. October 14, 2010

AECOM/Integral Consulting Inc., 2013. Revised Basis of Design/Conceptual Design for Upper Beach and Riverbank Interim Action, EVRAZ Oregon Steel, Portland, Oregon. May 24, 2013.

DEQ, 2014. Record of Decision – Selected Source Control Measure for the Evraz Oregon Steel Mills Riverbank. November, 2014.

ENSR/AECOM, 2008. Letter from Linda Baker, ENSR/AECOM to Jennifer Sutter, DEQ – EOSM Resolutions to ODEQ Comments on the Bank Stabilization Proposal. February 28, 2008.

EPA, 2014. Letter from Rich Muza, USEPA to Matt McClincy, DEQ – EPA Review of Final Source Control Measure for the Evraz Oregon Steel Mill Riverbank. December 17, 2014.

EPA, 2015. Letter from Rich Muza, USEPA to Jennifer Sutter, DEQ – EPA review of Final Design, Riverbank Source Control Measure for the Evraz Oregon Steel facility. February 25, 2015.

Integral Consulting Inc., 2015. Data Report for Berm, Upper Beach, and North Alcove Soil Sampling, EVRAZ Oregon Steel. January 21, 2015.

Integral Consulting Inc./Crete Consulting, Inc., 2017. Completion Report-Response to Oregon Department of Environmental Quality Comments on the EVRAZ Oregon Steel Riverbank Source Control Measure Completion Report. February 27, 2017.

Integral Consulting Inc./Crete Consulting, Inc., 2016. Riverbank Source Control Measure Completion Report – EVRAZ Oregon Steel. May 27, 2016.

Integral Consulting Inc./Crete Consulting, Inc., 2015a. Final Design – Response to Oregon Department of Environmental Quality Comments on the EVRAZ Oregon Steel Riverbank Source Control Measure Final Design. June 18, 2015.

Integral Consulting Inc./Crete Consulting, Inc., 2015b. Final Design – Riverbank Source Control Measure EVRAZ Oregon Steel. February 17, 2015.

RETEC, 2006a. Riverbank Source Control Evaluation, Oregon Steel Mills Inc., Portland, Oregon. May 17, 2006.

RETEC, 2006b. OSM Riverbank: Proposed Source Control Measure – Revision 1, Oregon Steel Mills, Portland, Oregon. December 2006. Approximate Property Boundary Project Area Source: USGS 7.5' Topographic Quadrangles Linnton, OR and Sauvie Island, OR-WA, ESRI Map Services Property Boundary: Metro RLIS, 2010.

0 2,000 4,000 Feet ¯ P:\Projects\C1144_StRives_Evraz\Production_MXDs\Construction_Completion_Report\Figure_1_location_map.mxd4/8/2016 1:25:38 PM

Figure 1. Topographic/Location Map EVRAZ Oregon Steel Portland, OR Project Area

WATER Property Boundary 31.2

Laydown/Stockpile Area , East Landfill Management Area ,

, Haul Route , , ,

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, COIL Upland Soil Management Designation , ,

Sta. 6+25 STORAGE , ,

East Landfill - Subsurface , , WEST LANDFILL ,

, East Landfill - Surface , ,

, , EAST LANDFILL ,

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FACILITY , , ,

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ACCESS ROAD

Disposal Material Management Area , , , , , Sta. 9+50 , , , ,

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Sta. 10+50 , MILL SCALE GYM

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East Landfill , Sta. 11+40 , , , , , , Mold Basement , COIL STORAGE MATERIAL

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Disposal Material Management Area COMBINATION MILL

BUILDING U / G , EL E C TR I C , VA U L T

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DOWN SHIP

COILER OFFICES Basemap Source: EVRAZ Oregon Steel (2007); , , riverbank contours based on Weddle (2014) PLATE ROLLING MILL

SHIPPING BAY , SUBSTATION, , MCC, & FANS REHEAT COOLING 0 200 400 TOWERS

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P:\Projects\C1144_StRives_Evraz\Production_MXDs\Construction_Completion_Report\Figure_9_Site_Map.mxdPM 5/4/2016 1:10:11 BRASS CAP

Figure 2 Site Map EVRAZ Oregon Steel Portland, OR Native tree and shrub species plantings on berm face & on top

Jute material secured to slope with pins Imported berm backfill and 2 feet of topsoil

:01:46PM 40 Reinforcement geotextile (placed every 2 feet within berm backfill)

Excavate, stockpile, test and reuse or dispose 1 (maximum) Pre-construction ground surface 1.5 30 Berm

ELEV 28.5 (Upper limit of rock) Excavate and dispose Excavation limit ELEV 27.5 (100-year flood elevation)

Geotextile Cottonwood cuttings Finished ground 1 Rock armor toe 1.5 Remove 1' to 3' (locally to 5') depth of beach Slag soil Bank 20 material and replace with beach restoration 1' thick crushed stone Dogwood and willow cuttings ELEV 16.6 (ORDINARY HIGH WATER) 3' thick rock armor

ELEV 15.0 12" minus river rock with gradation similar to existing (thickness varies)

10 ELEV 9.6 (MEAN HIGH WATER) s varie 3' gth ox. 2 len appr Native Alluvium/Dredge gth n len mea

Upper Beach

0 0+00 0+50 1+00 s_Evraz\CAD\Production Drawings\Construction_Completion_Report\Figure_2_Riverbank_Design.dwg 5/2/2016 5 NOTES:

1. VERTICAL DATUM IS NGVD29 (FEET) 0 612 2. DEQ ESTABLISHED A REFERENCE ELEVATION FOR MHW OF 9.6ft NGVD 29 (8ft COLUMBIA RIVER DATUM). FeetFeet No Vertical Exaggeration P:\Projects\C1144_StRive

Figure Adapted from Revised Basis of Design/Conceptual Design 3 for Upper Beach and Riverbank Interim Action, Evraz Riverbank Design Oregon Steel, Portland, OR. AECOM and Integral, 2013 EVRAZ Oregon Steel Portland, OR Location Depth (ft) Total PCBs Location Depth (ft) Total PCBs 0 Decision Unit 0 S-66d 0.5 <0.099 + ! NADU-1* 1.5 <0.021 ! 3 Upper Beach Sampling Location ! Beach Excavation to 1.5 Feet Location Depth (ft) Total PCBs Beach and Alcove Excavation to 2 Feet NASDU-1* 1.5 0.491 Beach and Alcove Excavation to 3 Feet !! NASDU-1* 1.5 0.464 (dup) Location Depth (ft) Total PCBs 0 0 Beach Excavation to 5 Feet S-53d 0.5 1.430 + 4 Location Depth (ft) Total PCBs Project Area S-53d 1.5 0.06 ! NADU-2* 1.5 0.043

Location Depth (ft) Total PCBs Basemap Source: EVRAZ Oregon Steel (2007); !! NASDU-2* 1.5 0.774 riverbank contours based on Weddle (2014) ! ! 0 ! 0 + 050100 5 Location Depth (ft) Total PCBs ! Location Depth (ft) Total PCBs Feet ¯ NADU-3* 1.5 0.034 S-44c 2.5 1.41 Location Depth (ft) Total PCBs NADU-4* 1.5 0.124 0 0 + ! Location Depth (ft) Total PCBs 6 Location Depth (ft) Total PCBs S-54d 0.5 0.210 ! S-67d 0.5 0.47 !! S-67d 3 0.13 Location Depth (ft) Total PCBs ! RB3 0.33 0.81 Location Depth (ft) Total PCBs 0 !! 0 UBDU-1* 3 0.87 Location Depth (ft) Total PCBs + 7 RB4a 0.33 1.77 !! RB4b 1 9.30 Location Depth (ft) Total PCBs ! UBDU-2* 3 0.97 Location Depth (ft) Total PCBs UBDU-2* 3 0.561 (dup) !! RB5 0.33 2.79 0 0 + 8 Location Depth (ft) Total PCBs S-68d 0.5 4.6 Location Depth (ft) Total PCBs S-68d 3 4.3 S-55d 0.5 0.17 !

0 0 + 9 Location Depth (ft) Total PCBs S-46d 0.5 0.57

0 0 + ! 0 1

0 Location Depth (ft) Total PCBs 0 + RB7 0.33 <0.2 1 1

Location Depth (ft) Total PCBs RB8 0.33 0.19 !

0 0 + 2 Location Depth (ft) Total PCBs 1 !! S-47d 3 0.880 11:22:39 AM 11:22:39 Location Depth (ft) Total PCBs ! RB9 0.33 0.55 0 0 + 3 1

0 0 + 4 1 Location Depth (ft) Total PCBs S-56d 0.5 3.3 !

0 0 + 5 1 Location Depth (ft) Total PCBs !! S-48d 0.5 9.3 S-48d 1.5 0.03

0 0 + 6 1 pletion_Report\Figure_4_Upper_Beach_Removed_PCBs.mxd 4/26/2016 4/26/2016 pletion_Report\Figure_4_Upper_Beach_Removed_PCBs.mxd

0 Location Depth (ft) Total PCBs

0 + S-57d 0.5 0.26 7 !! 1 S-57d 0.5 0.78 (dup)

Location Depth (ft) Total PCBs

0 0 S-64d 0.5 <0.099 + !! 8 S-64d 0.5 0.029 (dup) 1

Location Depth (ft) Total PCBs ! S-58d 0.5 0.43

1 P:\Projects\C1144_StRives_Evraz\Production_MXDs\Construction_Com

Notes: Figure 4. 1. Results shown in mg/kg 2. * Denotes composite sample Upper Beach Sample Locations Removed by Excavation NADU-1 through -4 and UBDU-1 through -2 are each composites of 3 sampling locations; (Total PCBs) NASDU-1 and NASDU-2 are each composites of 4 sampling locations EVRAZ Oregon Steel 3. Gray shading indicates removed sample Portland, OR Location Depth (ft) As Cd Cr Cu Pb Mn Zn

S-66d 0.5 3 0.1 30.7 27.8 4.71 578 66.3 0 0 + ! Location Depth (ft) As Cd Cr Cu Pb Mn Zn 3 NADU-1* 1.5 4.22 0.126 30 29.3 7.25 515 58.2 ! Location Depth (ft) As Cd Cr Cu Pb Mn Zn NASDU-1* 1.5 5.27 0.412 59.6 31.9 17.9 989 108 !! NASDU-1* 1.5 5.37 0.43 55 31.6 18.8 917 104 0 0 + 4 Location Depth (ft) As Cd Cr Cu Pb Mn Zn ! NADU-2* 1.5 3.13 0.167 17.5 16.5 5.94 732 53.5 Location Depth (ft) As Cd Cr Cu Pb Mn Zn S-53d 0.5 2.3 0.81 69.6 29 60.5 1650 268 !! ! S-53d 1.5 NA NA NA NA NA 3540 NA 0 ! 0 + Location Depth (ft) As Cd Cr Cu Pb Mn Zn 5 ! NADU-3* 1.5 1.95 0.16 11.6 9.92 5.21 221 50.9 Location Depth (ft) As Cd Cr Cu Pb Mn Zn NASDU-2* 1.5 4.67 0.49 159 35.9 26.8 1750 153

0 Location Depth (ft) As Cd Cr Cu Pb Mn Zn 0 + ! NADU-4* 1.5 2.37 0.515 78.5 17 47.8 912 177 6

Location Depth (ft) As Cd Cr Cu Pb Mn Zn !! S-54d 0.5 1.4 0.14 10.4 8 4.73 201 46.4 ! Location Depth (ft) As Cd Cr Cu Pb Mn Zn 0 0 S-67d 0.5 3 0.54 99.5 36.8 41.1 2540 189 + S-67d 3 1.6 0.24 18.8 16.4 13.9 230 99.57 !! Location Depth (ft) As Cd Cr Cu Pb Mn Zn UBDU-2* 3 4.73 0.39 49.7 27.8 24.4 1130 127 UBDU-2* 3 (dup) 5.14 0.425 74.8 31.1 25.5 1260 149 !! 0 0 Location Depth (ft) As Cd Cr Cu Pb Mn Zn + 8 UBDU-1* 3 10.6 1 148 56 48 1830 184

Location Depth (ft) As Cd Cr Cu Pb Mn Zn ! S-68d 0.5 4.4 2.43 194 51.7 237 6460 509 S-68d 3 4.4 2.28 1530 34.6 197 14000 805 0 0 + 9 Location Depth (ft) As Cd Cr Cu Pb Mn Zn S-55d 0.5 20.1 0.47 16.4 31.3 28.5 5140 122

0 0 + ! 0 1 Location Depth (ft) As Cd Cr Cu Pb Mn Zn S-46d 0.5 NA NA NA NA NA 843 30.3

0 0 + 1 1

0 0 + Location Depth (ft) As Cd Cr Cu Pb Mn Zn 2 1 ! S-47d 3 2.6 0.52 75.7 144 25 1220 744

0 0 + 3 1

0 0 + 4 1 Location Depth (ft) As Cd Cr Cu Pb Mn Zn S-56d 0.5 1.9 2.24 47.7 26.9 185 1040 773 !

0 0 + 5 1 Location Depth (ft) As Cd Cr Cu Pb Mn Zn !! S-48d 0.5 2.8 1.04 36.8 26.7 70.2 690 357 S-48d 1.5 NA NA NA NA NA NA NA

0 0 + 6 1

6 11:26:04 AM 6 11:26:04 4/26/201 pletion_Report\Figure_5_Upper_Beach_Removed_Metals.mxd Location Depth (ft) As Cd Cr Cu Pb Mn Zn S-57d 0.5 2 0.33 28.2 27.4 20.3 629 125 S-57d 0.5 2.2 0.36 86.4 22.1 22.2 1760 128

7 !! 1 Decision Unit ! Upper Beach Sampling Location Location Depth (ft) As Cd Cr Cu Pb Mn Zn S-64d 0.5 7.7 0.43 58.4 26.9 9.55 21700 67.3 Beach Excavation to 1.5 Feet S-64d 0.5 9.1 0.53 46.5 20.9 12.5 19600 76.3 Beach and Alcove Excavation to 2 Feet

0 0 Beach and Alcove Excavation to 3 Feet + !!

1 Beach Excavation to 5 Feet Project Area Location Depth (ft) As Cd Cr Cu Pb Mn Zn

! S-58d 0.5 7.3 0.76 321 67.8 33.2 34000 198 Basemap Source: EVRAZ Oregon Steel (2007);

0 riverbank contours based on Weddle (2014)

9 1 050100 Feet ¯ P:\Projects\C1144_StRives_Evraz\Production_MXDs\Construction_Com

Notes: 1. Results shown in mg/kg Figure 5. 2. * Denotes composite sample NADU-1 through -4 and UBDU-1 through -2 are each composites of 3 sampling locations; Upper Beach Sample Locations Removed by Excavation NASDU-1 and NASDU-2 are each composites of 4 sampling locations (Metals) 3. Gray shading indicates removed sample EVRAZ Oregon Steel Portland, OR 0 0 + 0 Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn S-52c 3 <0.02 6.76 <0.135 35.4 27.4 5.34 1150 56.2

0 0 + Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn 1 S-66d 3 <0.099 2.6 0.81 69.6 29 60.5 1650 268 ! Location Depth (ft) Total PCBs RB1 0.33 0.14 Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn 0 0 NADU-1* 3 <0.032 4.98 0.085 31.7 35.2 5.7 678 59.5 + 2 ! Location Depth (ft) Total PCBs Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn ! RB2 0.33 0.18 NADU-2* 3 <0.028 4.43 0.1 29.2 23.5 7.35 569 57 0 0 + ! 3 Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn ! S-53d 3 <0.10 1.1 0.12 4.6 6 3.25 137 38 !

0 0 Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn + 4 NADU-3* 3 0.61 4.17 1.64 62.9 31.1 136 1340 400 ! Location Depth (ft) Total PCBs NAPE-1 3 <0.013 Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn ! ! ! 0 ! NADU-4* 3 0.0498 2.83 0.263 22.8 14 12 381 79.7 0 + 5 ! Location Depth (ft) Total PCBs Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn NAPE-2 3 0.146 S-54d 3 0.099 2.2 0.22 12 12.8 9.61 805 84

0 0 + ! Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn 6 Location Depth (ft) Total PCBs UBDU-1* 5 <0.028 2.68 0.093 31.2 28 6.63 289 57.2 NAPE-3 3 0.884 !

0 Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn 0 + 7 UBDU-2* 5 <0.021 5.43 0.238 31.3 34.9 20 460 86.3 !

0 Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn 0 + 8 UBDU-3* 5 0.175 5.21 0.21 33.5 33.6 14 451 84.7 Location Depth (ft) Total PCBs ! UBPE-1 3 <0.012 ! Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn ! 0 UBDU-4* 3 <0.028 10.8 0.48 24.3 37 31.6 650 139 0 + 9 Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn S-55d 3 0.12 2.1 0.32 37.2 12 12.3 3680 95.9

0 0 + !! 0 1 Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn S-46d 1.5 0.049 NA NA NA NA NA 843 30.3

0 0 S-46d 3 <0.098 1.0 0.1 5.2 5.2 2.4 147 32 + 1 1

0 ! 0 + 2 1 Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn !! UBDU-5* 3 <0.027 2.57 0.21 209 31.3 18.7 2890 88.3

0 0 + 3 1 Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn UBDU-6* 5 0.006 3.73 0.172 18.7 18 7.69 369 67.8 08:12 PM 08:12 0 UBDU-6* 5 (dup) 0.0118 3.81 0.204 23.3 19.2 8.64 519 69.7 0 + 4 1 !! Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn 0 0 S-56d 1.5 0.011 NA NA NA NA 4.86 NA 61.2 Location Depth (ft) Total PCBs + 5 UBPE-2 3 1.71 1 S-56d 3 0.058 1.4 0.24 7.5 10 15.7 241 75.7 ! !

0 0 + Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn 6 1 S-48d 3 0.22 1.1 0.18 7.7 5.1 4.43 196 53.4

Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn S-57d 1.5 0.017 NA NA NA NA NA 268 NA 0

0 + S-57d 3 <0.087 1.8 0.14 7.8 16.6 4.52 370 45.7 7 !! 1

Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn

0 S-64d 1.5 <0.098 2.5 0.14 7.7 9.84 5.59 718 47.8

0 + ! 8

1 Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn pletion_Report\Figure_6_Upper_Beach_Remaining.mxd 10/24/2016 4: 10/24/2016 pletion_Report\Figure_6_Upper_Beach_Remaining.mxd S-58d 3 0.193 2.2 0.14 24.1 14.6 9.09 999 65.4 !!

9 1 Location Depth (ft) Total PCBs UBPE-3 3 0.0471 !! ! 0 Upper Beach Sampling Location

+ Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn 0 Decision Unit 2 S-49d 0.5 0.051 2.1 0.07 36.9 10.4 4.3 940 71.5 S-49d 3 <0.096 2.3 0.04 14.9 9 2.27 266 49.1 Beach Excavation to 1.5 Feet Location Depth (ft) Total PCBs Beach and Alcove Excavation to 2 Feet

0 ! 0 RB11 0.33 <0.2 Beach and Alcove Excavation to 3 Feet +

2 Location Depth (ft) Total PCBs Beach Excavation to 5 Feet RB12 0.33 <0.2 Decision Unit with Monitoring Stake Project Area

0 Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn

0 !

2 S-63d 0.5 <0.095 1.9 0.07 16.8 8.6 3.73 288 55 2 !!! Basemap Source: EVRAZ Oregon Steel (2007); S-63d (dup) 0.5 <0.10 1.8 0.07 9.8 10.5 3.81 211 41.3 riverbank contours based on Weddle (2014) S-63d 3 <0.096 2.2 0.04 11.4 9.9 2.35 488 50.2 075150

3 Feet 2 ¯ P:\Projects\C1144_StRives_Evraz\Production_MXDs\Construction_Com

Notes: Figure 6. 1. Results shown in mg/kg 2. * Denotes composite sample; ADU-1 through -4 and UBDU-1 through -6 are each Upper Beach Sample Locations Remaining Post-Excavation composites of 3 sampling locations. Gray shading indicates post-excavation results. EVRAZ Oregon Steel NAPE-1 through -3 and UBPE 1 through -3 are each composites of 4 sampling locations. Portland, OR ! Bank Face Sampling Location

0 Bank Face Sampling Area 0 + 3 Berm Area Bank Face Exposed Rock Armor Southern Excavation Area 0 0 Project Area + 4 Basemap Source: EVRAZ Oregon Steel (2007); Habitat Connectivity Path riverbank contours based on Weddle (2014) (Exposed 1.5" Crushed Rock) 050100 0 0 Feet + ¯ 5 Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn S-54b 0.5 34 5.51 0.971 242 46.2 64.9 2330 235

0 S-54bs 0.5 0.33 24.8 1.66 2510 769 14.6 20400 900 + ! S-54c 0.5 0.16 2.71 <0.112 <9.5 8.48 5.14 2026 51

Location Depth (ft) Total PCBs

0 ! S-45b 1 3.87 0 + 7 Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn S-55b 0.5 5.2 19.1 2.34 679 93.1 172 12700 1200 S-55c 2.5 0.072 1.87 <0.216 <13.9 7.91 12.8 293 79

0 0 + 8

0 0 + 9 Location Depth (ft) Total PCBs S-46b 0.5 6.25

0 0 + ! Location Depth (ft) Total PCBs 0 ! 1 S-46a 0.5 <0.021

0 0 + 1 1

Location Depth (ft) Total PCBs 0 0 + S-47b 1.25 6.9 2 1 ! Location Depth (ft) Total PCBs ! S-47a 1.25 1.26

0 0 + 3 Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn 1 S-1 0.5 1.9 5.1 2.9 89 59 190 1600 830

0 0 ! + 4 Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn 1 S-56b 1 6.2 11.2 20.8 201 106 1610 2350 7280 ! S-56c 2.5 <0.02 2.28 <0.149 <9.1 7.39 3.9 148 46.8 2:27 PM

0 0 + 5 1 Location Depth (ft) Total PCBs ! S-48b 0.75 13.5 ! 0 0 + Location Depth (ft) Total PCBs 6 1 S-48a 1.25 <0.021

Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn S-57b 0.75 6.4 7.65 0.86 436 46.2 58.8 11400 204 0

0 + S-57c 2 0.042 5.54 <0.135 <9.5 18.6 5.6 334 52.1 7 ! 1

Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn

0 S-64b 0.5 12 3 1.04 125 29.5 77.2 1580 323 0 ! +

1 Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn S-58b 0.5 0.53 4.35 0.885 150 30.5 49.9 3360 284 ! S-58c 4 0.35 5.51 1.26 515 39.2 62 14500 306 pletion_Report\Figure_7_Riverbank_Berm_Removed.mxd 5/2/2016 4:1 5/2/2016 pletion_Report\Figure_7_Riverbank_Berm_Removed.mxd 0

0 Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn

2 S-60bU 0.5 11.2 2.21 0.359 64 20.2 25 1350 140 S-60bM 0.5 8.1 3.4 1.58 142 62 161 2270 455 S-60bL 0.5 0.15 2.44 0.287 49 29.9 14.9 656 89.8

+ Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn

1 2 S-69b 0.5 0.18 2.2 0.13 17 10.3 7.26 291 68.9

Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn S-59b 0.5 3.4 5.99 0.418 83.7 23.9 22.5 2540 140

0 0 S-59c 1 <0.020 5.49 <0.0465 14.3 16.7 3.05 267 50.9 +

2 2 ! !!! ! Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn S-63bU 0.5 0.14 2.2 0.281 19.1 14.2 14.3 673 75.3

2 P:\Projects\C1144_StRives_Evraz\Production_MXDs\Construction_Com

Notes: Figure 7. 1. Results shown in mg/kg 2. Depths reference depth beneath pre-excavation bank face surface Bank and Berm Sample Locations Removed by Excavation 3. b = Slag-soil fill bank face EVRAZ Oregon Steel 4. c = Dredge fill, native alluvium or other fill below toe of riverbank Portland, OR 5. Gray shading indicates removed sample 0 + 0 Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn ! Bank Face Sampling Location S-51a 0.5 <0.02 7.04 <0.193 30.3 24 6.56 540 60.2 Bank Face Sampling Area S-51a (dup) 0.5 <0.02 7.08 <0.166 31.7 27.3 8.26 457 74.4 0 !! 0 S-51c 3.5 <0.02 8.07 <0.253 40.3 30.7 6.2 2370 59.3 + Berm Area 1 Bank Face Exposed Rock Armor Project Area

0 Property Boundary 0 + 2 !!

Basemap Source: EVRAZ Oregon Steel (2007); riverbank contours based on Weddle (2014) Location Depth (ft) Total PCBs S-43c 2.5 <0.019 075150 0 0 + 3 Feet ¯

0 0 + 4

0 0 + 5

Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn WEST LAND BF-1 0.5 2.4 5.26 0.58 139 37.1 22.7 3950 155 0 0 + 6

0 0 Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn + 7 BF-2 0.5 2.33 7.39 7.04 149 82.5 607 4750 2640 BF-2 (split) 0.5 5.1 6.54 6.73 223 77.7 582 3440 2070 !! AC 0 CES 0 S + 8

0 0 + 9

MIL L SC TR AL ANS E AR FER 0 EA 0 + 0 Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn 1 BF-3 0.5 6.77 9.33 0.614 270 54 42.1 9970 181 BF-3 (dup) 0.5 5.88 4.76 0.799 530 49.9 507 5340 209 ! 0 0 + 1 1

COM BIN BUI ATIO LDIN N M 0 G IL 0 L + 2 1 D OWN CO ILER

0 0 + 3 1

0 REH 0 EAT

3 PM + CO 4 TOW OLIN 1 Location Depth (ft) Total PCBs As Cd Cr CuER PbS G Mn Zn ! BF-4 0.5 5.4 8.75 2.88 317 97.9 305 5260 690

0 0 S + 5 1 S

COO 0 LING 0 P + ON 6 D 1

WA STE # TR 2 B ANS AG Location Depth (ft) Total PCBs As Cd Cr Cu Pb MnFER Hg Zn HOU

0 BF-5 0.5 1.62 4.24 0.804 276 44.6 68 4660 0.069 587 0 ! #1 + BA 8 H G- 1 O USE pletion_Report\Figure_8_Riverbank_Remaining.mxd 5/2/2016 3:47:0 5/2/2016 pletion_Report\Figure_8_Riverbank_Remaining.mxd WA TER 0 TRE 0 ATM Location Depth (ft) Total PCBs + FA ENT 9 CILI S-49c 1.5 <0.02 1 TY ST OR.

E 2

! AC 0 ! 0

C +

E 0

S 2

A LocationD Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn CO Location Depth (ft) Total PCBs S-62bM 0.5 0.079 2.98 0.597 31.2 32.5 42.9 1630 186

S-49b 0.5 0.032 + !

Location Depth (ft) Total PCBs As Cd Cr Cu Pb Mn Zn ! S-61bU 0.5 0.013 1.98 0.307 12.7 14.6 27.3 1000 56.7

PIPE 0 M 0 ILL +

2 P:\Projects\C1144_StRives_Evraz\Production_MXDs\Construction_Com

Notes: Figure 8. 1. Results shown in mg/kg 2. BF-1 through -5 are each composites of 10 sampling locations; Bank Face Sample Locations Remaining Remaining concentrations at these locations are capped with EVRAZ Oregon Steel geotextile fabric, 1 ft of crushed rock, and 3 ft of rock armor. Portland, OR P:\Projects\C1144_StRives_Evraz\CAD\Production Drawings\Construction_Completion_Report\Long_Term_Monitoring_Plan\Figure_1_2_Monitoring_Plot_Stakes.dwg 10/26/2016 11:11:09 AM 0 T1-T7 FeetFeet 0120 60 Plant Species PercentageSurvival Plots Upper Beach Substrate MonitoringIdentification Stakes Upper Beach Substrate MonitoringStake Upper Beach Substrate MonitoringLocation Bank Photo Documentation Location Documentation Photo Bank (10' x 10' Monitoring Plot) Vegetation Monitoring Transect Start Locations Start Transect Monitoring Vegetation Transect Monitoring Vegetation

N 10' Non-Native Plant Clearance Area Plant Non-Native 10' Restored Vegetation Vegetation - No Protection Armor Rock mg/kg 0.1 of Concentration PCB Exceed DecisionUnits where Subsurface Concentrationft (3 bgs) Riparian Planting Areas - Steep Slopes Areas Planting Riparian Gradual to Flat Slopes - Areas Planting Riparian - Upper Beach Areas Planting Riparian

Riparian Planting Areas Portland, OR EVRAZ Oregon Steel Berm, Bank, Upper Beach Substrate, and Figure 9 . Mo Vegetation Locations nitoring P:\Projects\C1144_StRives_Evraz\CAD\Production Drawings\Construction_Completion_Report\Long_Term_Monitoring_Plan\Figure_1_2_Monitoring_Plot_Stakes.dwg 10/26/2016 11:11:09 AM 0 T1-T7 FeetFeet 0120 60 Plant Species PercentageSurvival Plots Upper Beach Substrate MonitoringIdentification Stakes Upper Beach Substrate MonitoringStake Upper Beach Substrate MonitoringLocation Bank Photo Documentation Location Documentation Photo Bank (10' x 10' Monitoring Plot) Vegetation Monitoring Transect Start Location Start Transect Monitoring Vegetation Transect Monitoring Vegetation

Riparian Planting Areas Portland, OR EVRAZ Oregon Steel Berm, Bank, Upper Beach Substrate, and Figure 10 . Mo Vegetation Locations nitoring