State of Oregon Department of Environmental Quality Memorandum

Date: February 28, 2017

To: FILE

Through: Dan Hafley, Lead Worker Northwest Region Cleanup Section

From: Paul Seidel, Project Manager Northwest Region Cleanup Section

Subject: 3009 NE Killingsworth Street, Portland, Oregon ECSI 6052; Staff Memorandum in support of a No Further Action determination

This document presents the basis for the Oregon Department of Environmental Quality’s (DEQ’s) recommended No Further Action (NFA) determination for the property at 3009 NE Killingsworth Street in Portland, Oregon, formerly known as Bighouse Automotive (see Attachment 1 for site location). As discussed in this memorandum, contaminant concentrations in soil are below acceptable risk levels, while other environmental media have not been impacted.

The proposed NFA determination meets the requirements of Oregon Administrative Rules Chapter 340 Division 122, Sections 010 to 0140; and ORS 465.200 through 465.455.

The proposal is based on information documented in the administrative record for this site. A copy of the administrative record index is presented at the end of this memorandum.

1. BACKGROUND

Site location. The site’s location can be described as follows: Address: 3009 Northeast Killingsworth Street, Portland (Multnomah County), Oregon. Latitude 45.562804 North, longitude 122.6348220 West, Willamette Baseline and Meridian Tax lot 1N1E13CD-15000.

Site setting. The property is an urban lot approximately 0.23 acres in size, and was previously used for an automotive fueling and service station, automotive repair and U-Haul storage facility. The site is reported to have been first developed in 1939 by the City of Portland. The property is currently planned for redevelopment and is located in a mixed use commercial and residential neighborhood that is undergoing re-development. The site is bounded on the south by NE Killingsworth Street, on the west by NE 30th Avenue and on the east and north by residential properties (Figure 1). 3009 NE Killingsworth Street, ECSI # 6052 Staff Memorandum February 28, 2017 Page 2 of 10

The land is zoned Storefront Commercial (CS) by the City of Portland.

Physical setting. The site is a flat lot located in the Concordia neighborhood of North Portland. Shallow groundwater was not encountered in borings completed during a Phase II investigation in 2015, which extended to a maximum depth of 25 feet below ground surface (bgs). According to the site consultant, groundwater in this area occurs at depths exceeding 60 feet bgs. The area is within the ancestral Columbia River flood plain. The geology of this area is defined by catastrophic flood events that drained ancient glacial Lake Missoula repeatedly from 15,300 to 12,700 years ago. These repeated floods deposited gravels and fine sediments in the Portland area and formed the topography of the Alameda Ridge, sloping gently north to the Columbia Slough. Shallow groundwater flow directions were not determined for the site, but groundwater likely flows northerly toward the Columbia Slough and River.

Site history. On a 1924 Sanborn map, the site depicted as a vacant lot and in a 1934 aerial photograph, the Site is a vacant lot. The earliest known development on the site occurred in 1939, as reported by the City of Portland. Commercial use as an automotive service facility started at that time and continued until recently, when the site was sold for redevelopment. Prior to demolition in 2016, an approximately 1,300-square-foot wood-frame building with a concrete slab on-grade was present in the central portion of the lot. A service island and canopy for vehicle fueling was present immediately south of the building. Two service bays were used, each containing a subsurface hydraulic hoist and a catch basin with a sump that discharged to the City of Portland sanitary sewer system. No staining or evidence of releases was observed around the lifts at the time of the phase I assessment.

The site is listed in DEQ’s UST database. No decommissioning records are available and no UST releases have been reported to DEQ. No transactions or site closure is indicated in DEQ’s UST records. Site closure for all site activities is therefore recommended under this memorandum. During site reconnaissance conducted in 2015, the Site owner reported that he removed the three USTs in 1989, including one gasoline and one diesel UST from the paved area east of the building and one waste-oil UST immediately north of the service bays. The USTs reportedly were emptied, removed with a backhoe, and recycled off-site. Groundwater reportedly was not encountered during the UST removal activities, and no confirmation soil samples were collected prior to backfilling the UST excavations with clean sand fill.

A Phase I site assessment was completed in May 2015 (Phase I Environmental Site Assessment, Report, Northeast Killingsworth Property, Portland, Oregon, prepared by Farrallon, LLC. May 27, 2015). The report identified two recognized environmental conditions (RECs). These were: a) potential releases associated with former uses in automotive service and repair, and; b) potential for releases from former dry cleaning in the site vicinity. A historic dry cleaner was reported to have operated at 5425 NE 30th Avenue, approximately 200 feet south of the site. No known releases are reported associated with this site, but it presence was identified as an REC.

3009 NE Killingsworth Street, ECSI # 6052 Staff Memorandum February 28, 2017 Page 3 of 10

In 2017, a mixed-use commercial/residential building will be constructed on-site, with residential space above the first floor. Site redeveloped occurred under a Soil Management Plan (SMP) and Health and Safety Plan (HASP) prepared independently of DEQ Contaminated soil (see discussion below) was segregated and disposed at the Hillsboro Landfill under the SMP (Soil Management Plan Implementation and Site Closure, Northeast Killingsworth Property, Portland, Oregon, prepared by Farrallon, LLC. February 16, 2017).

2. BENEFICIAL LAND AND WATER USE DETERMINATIONS

Land use. Currently, the site is zoned Storefront Commercial (CS). According to the City, this zoning designation is intended to preserve and enhance older commercial areas that have a storefront character. The zone intends that new development in these areas will be compatible with this desired character. The Concordia neighborhood and site area is fully-developed, and will be undergoing redevelopment is a manner consistent with this zoning into the future.

Groundwater use. There is no current use of groundwater at the site. Water is supplied to the site by the City. A review of Oregon Water Resources well logs did not identify any wells in the immediate site vicinity. However, groundwater may exceed depths of 50 feet based on experience of the site consultant. There is no indication that shallow groundwater has been impacted by site-related contaminants, based on the sampling results from the Phase II investigation. As discussed below, site impacts are negligible to minor and confined to near-surface soil. It is expected that there will be no use of groundwater at the site for the foreseeable future, based on the urban location. On this basis, the groundwater ingestion and inhalation pathway was not included in the risk evaluation.

Surface water use. The nearest surface water body to the site is the Buffalo Slough, located approximately 0.9 miles to the north. The site topography is generally flat, and stormwater from the site is either captured in City catch basins or infiltrates into the ground around the site. Given that the site is currently being redeveloped and will be covered by a combination of hardscape and minimal landscaping, runoff or erosion of contaminants in soil does not appear to be a significant concern. To the extent that residual soil contamination is present, it will be covered by buildings or landscaping and not expected to migrate to nearby City catch basins.

3. INVESTIGATION AND CLEANUP WORK

Based on the identified RECs in the Phase I assessment, Farrallon, LLC performed initial sampling and investigation of subsurface conditions to evaluate the potential presence of any hazardous substances associated with former site use as an automotive repair facility or migration of contaminants from off-site. A Phase II environmental site assessment was performed in May and June 2015 to assess potential contaminant impact to site media (Phase II Environmental Site Assessment Report, Northeast Killingsworth Property, Portland, Oregon, 3009 NE Killingsworth Street, ECSI # 6052 Staff Memorandum February 28, 2017 Page 4 of 10 prepared by Farrallon, LLC. June 9, 2015). Analytical Data from the Phase I investigation is presented in Tables 1-6. Sample locations are presented in Figure 2.

The Phase II report documents the following work:

1) Completion of 15 investigative borings, advanced in locations based on the proximity to former site features including service bays, near hydraulic hoist and pumping equipment, and borings near the service island, product lines, former USTs and the sanitary sewer lines.

2) Collection of 31 soil samples at varying depths within the borings. PID readings were low to zero. Therefore shallow samples were selected for analysis, along with deeper samples from borings B-7, B-8 and B-9 in the former UST area. Nineteen total samples were analyzed for petroleum hydrocarbons by method TPH-HCID.

3) The same 19 soil samples were analyzed for petroleum hydrocarbon ranges (gasoline, diesel and oil) by method NWTPH.

4) A subset of four samples from borings B-1 and B-2 were analyzed for metals by EPA Method 6000/7000, volatile organic compounds (VOCs) by EPA Method 8260B and polychlorinated biphenyls (PCBs) by EPA Method 8082.

5) Four soil vapor samples were collected from the subsurface soil zone (approximately 10 feet bgs) and analyzed by EPA Method T0-15.

Oil range hydrocarbons were detected in seven of the 19 samples. A single sample at 4,310 mg/kg exceeded DEQ risk-based concentration for diesel or heating Oil (RBC; Risk-Based Decision Making for the Remediation of Petroleum-Contaminated Sites, 2003) for urban residential exposure, taken at a depth of 5.5 feet bgs from boring B-7. However, estimating the average concentration using all samples at all depths results in an estimate of a 90th upper confidence limit on the average TPH- Residual Oil concentration of approximately 780 mg/kg, which is below the urban residential RBC of 2,200 mg/kg. Because site soils are more likely to be mixed during redevelopment, and because estimates of average are better predictors of risk potential, the low level of TPH as oil, which is less than the applicable risk-based concentration (RBC), does not appear to pose significant risk potential, as described further in Section 4.

However, regardless of risk potential, a soil management plan was prepared for site redevelopment. The area where sample B-07(5-5) was collected was excavated up the three feet (bgs) and removed to the Hillsboro Landfill (see previously referenced soil management report). Deeper soil is underneath current construction.

3009 NE Killingsworth Street, ECSI # 6052 Staff Memorandum February 28, 2017 Page 5 of 10

VOCs and PCBs were not detected in any of the three samples analyzed. These samples were collected adjacent to service bays and hoists and were intended to capture any leakage from the hoists (see Figure 2).

Metals were detected in each of the four samples analyzed at levels generally consistent with background. However, lead exceeded background in one sample, detected at a concentration of 236 mg/kg. Cadmium exceeded the estimate of background in two samples at 1.1 and 1.4 mg/kg, respectively. Sample results in excess of background for these two metals is not unexpected, since both cadmium and lead are known to be common contaminants in urban particulate from automotive sources. (Charlesworth, S., De Miguel., E. and A. Oronez. 2011. Environ. Geochem. Health (2011) 33:103–123 DOI 10.1007/s10653-010-9325-7). In both cases, cadmium and lead are well below screening risk-based concentrations (see Table 3).

Polycyclic aromatic hydrocarbon (PAHs) were not analyzed in this investigation. However, based on the low-to-negligible levels of TPH detected, significant PAH detections would not be expected. Moreover, future site development is expected to completely cap site soils, eliminating potential for direct contact with soil. During the implementation of the soil management plan, a soil samples was collected in the footprint of the former service bays and adjacent to the western underground hoist (Figure 2), an area of soil exhibiting a petroleum-like odor and black staining was encountered from the ground surface to a depth of approximately 5.5 feet bgs. The soil sample of this stained soil was collected from the ground surface. The excavation was advanced to a depth of approximately 6 feet bgs, where no olfactory or visual evidence of contamination was noted in surrounding soil. A confirmation soil sample was collected from this excavation at a depth of 6 feet bgs. These two soil samples were submitted for laboratory analysis for DRO and ORO by Northwest Method NWTPH-Dx, and for GRO by Northwest Method NWTPH-Gx. DRO was detected at a concentration of 85,300 mg/kg in the sample collected from the ground surface, and at a concentration of 300 mg/kg in the sample collected at a depth of 6 feet bgs. After receipt of data, the soil was disposed at the Hillsboro Landfill. Therefore, no significantly impacted soil near the hoists remains on site (Table 6).

Four soil vapor samples were collected from soil locations where contaminant impacts might have occurred, and no significant detections of hazardous substances in soil vapor were found. Had there been significant releases of petroleum hydrocarbons from the USTs or piping, it would likely been detected by soil vapor sampling. The absence of significant soil vapor detections further supports the absence of a release from the facility during historical operations.

Nature and extent of contamination. The detections of petroleum hydrocarbons and metals are low to insignificant, and VOCs and PCBs were not detected in any samples. Soil gas samples did not contain any significant VOCs including chlorinated VOCs that are associated with dry cleaning operations. Therefore, the absence of any reported release from the nearby historic dry cleaner and the on-site soil gas data support a conclusion of no significant or detectable release from that former facility identified as an REC in the phase I assessment. The TPH detection from boring B-7 at 4,310 mg/kg exceeded the generic diesel/heating oil risk-based concentration (RBC), but soil overlying this area was excavated and disposed at the Hillsboro landfill, and site wide average TPH is below levels of 3009 NE Killingsworth Street, ECSI # 6052 Staff Memorandum February 28, 2017 Page 6 of 10 concern. No releases have been reported to DEQ associated with the former Bighouse Automotive facility. Overall, site history and analytical data support and interpretation that there has not been a significant release and the site does not appear to be significantly contaminated. Finally, petroleum impacted soil has been excavated and disposed as part of site redevelopment, as described in the previously referenced soil management plan implementation and closure report.

4. RISK EVALUATION

Because the site current and reasonably likely future use is urban residential, potential receptors include future residents, and occupational, construction, or excavation workers. The impacted medium at the site is surface (0 to 3 feet bgs) or subsurface soil (greater than 3 feet bgs) with no evidence that groundwater has been impacted. Current and reasonably likely future use of the site includes complete cover by asphalt or buildings. Accordingly, direct contact with soil is not a reasonably likely complete exposure pathway. Urban residential, occupational, construction and excavation worker are considered in this risk evaluation.

To evaluate human exposure to residual chemical contamination requires an assessment of the type and extent of that exposure, based on current and reasonably likely future site use. DEQ has published RBCs (see reference above) for contaminants commonly encountered, for different types of exposure scenarios. These RBCs are generally conservative estimates of protective levels of contaminants in relevant environmental media. Table 1 shows potential exposure pathways and receptors for this site.

Table 1. Identification of applicable RBCs, for relevant pathways and receptors

Pathway Receptor Applicable Basis for exclusion RBC? SOIL Ingestion, dermal Residential No Urban residential is a contact, and Urban residential Yes future land use inhalation Occupational Yes Construction worker Yes Excavation worker Yes Volatilization to Residential No Urban residential outdoor air Urban residential Yes assumptions apply. Occupational Yes Vapor intrusion into Residential No Potentially complete. buildings Urban residential Yes However, residences are located on second floor and vapor intrusion from subsurface is therefore insignificant. Occupational Yes Leaching to Residential No Depth to groundwater, 3009 NE Killingsworth Street, ECSI # 6052 Staff Memorandum February 28, 2017 Page 7 of 10

Pathway Receptor Applicable Basis for exclusion RBC? groundwater Urban residential No Absence of significant Occupational No release.

Notes: 1. Groundwater RBCs are excluded from this table since City water is provided. Local groundwater is not currently used for drinking water and is not likely to be used for this purpose in the future. Further, groundwater is at least 25 feet or more below ground surface, based on site borings. Construction and excavation work are generally limited to a depth of approximately 15 feet. Finally, there is no reason to expect site contamination of groundwater. Based on these considerations, groundwater is excluded as a relevant medium.

Contaminant concentrations. Constituents of interest (COI) are TPH, metals, VOCs, and PCBs based on former site use as an automotive repair facility. PCBs were not detected in any sample. Low levels of a few common petroleum VOCs were detected below RBCs in soil gas samples and no chlorinated VOCs were detected. Heavy (or residual-range) oil was reported as present in borings B-6, B-7, and B-8, and B-9 and B-10, while gasoline and diesel range TPH were not detected. Residual oil was detected at concentrations ranging from 65 to 4,310 mg/kg in seven samples from B-7 through B-10 and not detected in other borings. Metals were consistent with background concentrations with the exception of cadmium and lead in two samples taken from boring B-2 in the service bays.

During the implementation of the soil management plan and site redevelopment several additional samples were collected and analyzed for TPH. One high sample at 85,300 mg/kg near the former west hoist was used to identify impacted soil that was disposed at the Hillsboro landfill. The host area was vertically delineated to below significant impacts (300 mg/kg- TPH, see Table 6).

A full report for all measured analytes is presented in Phase II Environmental Site Assessment Report, Northeast Killingsworth Property, Portland, Oregon, prepared by Farrallon, LLC. June 9, 2015. Data are summarized in Tables 1 through 5 included with this memorandum.

Human health risk. Contaminants including metals and low levels of TPH are present in soil, but generally below DEQ RBCs for soil ingestion, dermal contact, and inhalation. The metals cadmium and lead exceeded estimates of background in one or more samples. However, neither metal exceeded applicable DEQ RBCs. Detection of a few volatile compounds also occurred in soil gas samples, but was well below levels of concern for vapor intrusion into buildings.

Although one TPH soil sample, collected at a depth of five feet was modestly elevated as compared to other sample results, a comparison of an estimate of average concentration may be made to the urban residential RBC. DEQ estimated the 90th upper confidence limit on the mean for TPH oil as 782 mg/kg. This estimate of average site-wide TPH- oil is well below the urban 3009 NE Killingsworth Street, ECSI # 6052 Staff Memorandum February 28, 2017 Page 8 of 10 residential risk based concentration for diesel/heating Oil of 2,200 mg/kg. The site currently re- developed and exposure to soil is insignificant.

Ecological risk. The property is level, fully paved, and has been used as service station for decades. It is less than 0.25 acre in size and within the Portland urban area. Stormwater is managed through City catch basins. DEQ concludes, given the absence of ecological habitat, that potential exposure to ecological receptors is an incomplete exposure pathway and no ecological assessment is warranted.

5. RECOMMENDATION

Based on the findings documented in this memorandum, acceptable risk levels are not exceeded, and pursuant to OAR 340-122-0072 (5)(d), no further action is required for this site in accordance with the Oregon Environmental Cleanup Law, ORS 465.200 et seq.

Because minor contamination was detected in some soil, appropriate soil management and disposal were implemented during site redevelopment and completed in 2017. The site was re- developed under an SMP reviewed by DEQ. The SMP included management of soil to prevent release to ground surface and nearby catch basins, and sampling prior to off-site transport and disposal. The work is documented in the Soil Management Plan Implementation and Closure Report.

6. ADMINISTRATIVE RECORD

SITE-SPECIFIC DOCUMENTS.

Phase I Environmental Site Assessment, Report, Northeast Killingsworth Property, Portland, Oregon, prepared by Farrallon, LLC. May 27, 2015.

Phase II Environmental Site Assessment Report, Northeast Killingsworth Property, Portland, Oregon, prepared by Farrallon, LLC. June 9, 2015.

Soil Management Plan Implementation and Site Closure, Northeast Killingsworth Property, Portland, Oregon, prepared by Farrallon, LLC. February 16, 2017.

STATE OF OREGON Oregon’s Environmental Cleanup Laws, Oregon Revised Statutes 465.200-.900, as amended by the Oregon Legislature in 1995.

Oregon’s Hazardous Substance Remedial Action Rules, Oregon Administrative Rules, Chapter 340, Division 122, adopted by the Environmental Quality Commission in 1997.

3009 NE Killingsworth Street, ECSI # 6052 Staff Memorandum February 28, 2017 Page 9 of 10

Oregon’s Solid Waste Rules , Oregon Administrative Rules, Chapter 340, Division 093-096, OAR-340-093 through OAR-340-096.

GUIDANCE AND TECHNICAL INFORMATION DEQ 2013.Background Levels of Metals in Soils for Cleanups. March 2013.

DEQ. Guidance for Conduct of Deterministic Human Health Risk Assessment. May 1998 (subsequently updated). DEQ Risk-Based Decision Making for Remediation of Petroleum- Contaminated Sites (RBDM) guidance (September 2000, subsequently updated). 3009 NE Killingsworth Street, ECSI # 6052 Staff Memorandum February 28, 2017 Page 10 of 10

7. ATTACHMENTS

1) Figure 1: Site Vicinity Map. 2) Figure 2: Site Plan and Sampling Locations 3) Table 1:Soil Analytical Results: Petroleum Hydrocarbons 4) Table 2: Soil Analytical Results: Volatile Organic Compounds 5) Table 3: Soil Analytical Results: Metals 6) Table 4: Soil Analytical Results: PCBs 7) Table 5: Soil Gas Analytical Results: VOCs 8) Table 6: Soil Analytical Results: Petroleum Hydrocarbons (SMP Implementation)

SITE LOCATION

REFERENCE: 7.5 MINUTE USGS QUADRANGLE NORTH PORTLAND, OREGON, DATED 2011

Washington Issaquah | Bellingham | Seattle PORTLAND FIGURE 1 Oregon Portland | Bend | Baker City SITE VICINITY MAP NORTHEAST KILLINGSWORTH PROPERTY Farallon California CONSULTING Oakland | Sacramento | Irvine 3009 NORTHEAST KILLINGSWORTH STREET PORTLAND, OREGON Quality Service for Environmental Solutions | farallonconsulting.com 0 5,000 FARALLON PN: 1380-002 Drawn By: pgarvin Checked By: MH Date: 12/27/2016 Disc Reference: SCALE IN FEET Document Path: G:\Projects\1380 Ascend Holdings\1380002 Northeast Killingsworth Property\GIS\1380_002_Figure_1B.mxd RESIDENTIAL

SG2 CANOPY POSSIBLE FORMER LOCATION OF WHITE GAS UST

B12 REPORTED FORMER LOCATION B14 B13 OF WASTE OIL UST REPORTED FORMER LOCATION SG1 B11 OF GASOLINE AND DIESEL USTs

SG3 RESIDENTIAL B15 B02 SERVICE OFFICE B09 B08 BAYS (West Hoist Top-072916) B01 SG4 (West Hoist 6.0-072916)

NORTHEAST 30TH AVENUE WESTERN EASTERN HOIST HOIST B07 B10 OVERHANG

PUMP ISLAND B06

B04 B03 B05

NORTHEAST KILLINGSWORTH STREET

Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community LEGEND

APPROXIMATE SITE BOUNDARY SOIL SAMPLING LOCATION

ESTIMATED EXTENT OF PETROLEUM-IMPACTED SOIL EXCEEDING RBCs (AREA 1) SOIL GAS SAMPLING LOCATION

ESTIMATED EXTENT OF PETROLEUM-IMPACTED SOIL LESS THAN RBCs (AREA 2) CATCH BASIN APPROXIMATE EXTENT OF PETROLEUM-IMPACTED SOIL DISPOSED OFF-SITE INFERRED SANITARY SEWER LOCATION AUGUST 2016 SOIL SAMPLING LOCATION (SAMPLE ID)

Washington Issaquah | Bellingham | Seattle FIGURE 2 Oregon SITE PLAN Portland | Bend | Baker City NORTHEAST KILLINGSWORTH PROPERTY Farallon California 3009 NORTHEAST KILLINGSWORTH STREET CONSULTING Oakland | Sacramento | Irvine PORTLAND, OREGON 0 25 Quality Service for Environmental Solutions | farallonconsulting.com FARALLON PN: 1380-002 Scale in feet Drawn By: pgarvin Checked By: MH Date: 12/27/2016 Disc Reference: 1380002.MXD Document Path: G:\Projects\1380 Ascend Holdings\1380002 Northeast Killingsworth Property\GIS\1380_002_Figure_2_closure_rptB.mxd Table 1 Soil Analytical Results—Petroleum Hydrocarbons Northeast Killingsworth Street Property Portland, Oregon Farallon PN: 1380-002

Analytical Results (milligrams per kilogram)2 Sample Sample Sample Sample Identification Location Date Depth1 DRO ORO GRO B01_7-7.5 B01 04/13/15 7.5 <53.4 <107 <4.99 B02_7-7.5 B02 04/13/15 7.5 <49.8 <99.7 <4.85 B03_6-6.5 B03 04/13/15 6.5 <53.6 <107 <21.5 B04_6-6.5 B04 04/13/15 6.5 <52.7 <105 <21.1 B05_12-12.5 B05 04/13/15 12.5 <51.7 <103 <20.7 B06_6-6.5 B06 04/13/15 6.5 <25.0 108 <20.7 B06_17-17.5 B06 04/13/15 17.5 <25.0 <50 NA B07_5-5.5 B07 04/13/15 5.5 <925 4310 <985 B07_15-15.5 B07 04/13/15 15.5 <200 837 NA B08_5-5.5 B08 04/14/15 5.5 <25.0 65.1 <21.5 B08_23-23.5 B08 04/14/15 23.5 <25.0 <50 NA B09_5-5.5 B09 04/14/15 5.5 <93.7 446 <22.2 B09_16-16.5 B09 04/14/15 16.5 <216 665 NA B10_5-5.5 B10 04/14/15 5.5 <430 1610 <106 B10_23.5-24 B10 04/14/15 24 <25.0 <50 NA B11_6-6.5 B11 04/14/15 6.5 <52.8 <106 <4.94 B12_6-6.5 B12 04/14/15 6.5 <52.6 <105 <21.0 B14_6-6.5 B14 04/14/15 6.5 <54.1 <102 <21.6 B15_6-6.5 B15 04/14/15 6.5 <50.9 <102 <20.3 3,4 DEQ RBCss 1,100 2,800 1,200 3,4 DEQ RBCso >Max >Max 5,900 3 DEQ RBCsi Residential >Max >Max 94 3 DEQ RBCsw Residential 9,500 >Max 31 NOTES: > Max = The constituent risk-based concentration for this pathway DRO = total petroleum hydrocarbons as diesel-range organics is calculated as greater than 1,000,000 milligrams per kilogram GRO= total petroleum hydrocarbons as gasoline-range organics or 1,000,000 milligrams per liter; therefore, this substance NA = Not analyzed is deemed not to pose a risk in this scenario. ORO = total petroleum hydrocarbons as oil-range organics < denotes analyte not detected at or exceeding the reporting limit listed. RBC = risk-based concentration 1 Depth in feet below ground surface. RBCsi = RBC for the Vapor Intrusion into Buildings pathway 2 Analyzed by Northwest Methods NWTPH-HCID, NWTPH-Dx, RBCso = RBC for the Volatilization to Outdoor Air pathway

and NWTPH-Gx. RBCss = RBC for the Soil Ingestion, Dermal Contact, and Inhalation Pathway 3 RBCs are from http://www.deq.state.or.us/lq/pubs/docs/RBDMTable.pdf. RBCsw = RBC for the Leaching to Groundwater pathway 4RBC is the lowest RBC for this exposure pathway.

1 of 1 G:\Projects\1380 Ascend Holdings\1380002 Northeast Killingsworth Property\Reports\Phase II ESA\1380002_Tables Table 2 Soil Analytical Results—Volatile Organic Compounds Northeast Killingsworth Street Property Portland, Oregon Farallon PN: 1380-002

Analytical Results (micrograms per kilogram)2 Sample Sample Sample Sample Identification Location Date Depth1 PCE TCE 1,1-DCE cis-1,2-DCE trans-1,2-DCE Vinyl Chloride Vinyl Chloride B01_7-7.5 B01 4/14/2015 7.5 <24.9 <24.9 <24.9 <24.9 <24.9 <24.9

RBCsi = RBC for the Vapor Intrusion into Buildings pathway.

RBCso = RBC for the Volatilization to Outdoor Air pathway.

RBCss = RBC for the Soil Ingestion, Dermal Contact, and Inhalation pathway. TCE = trichloroethene

1 of 1 G:\Projects\1380 Ascend Holdings\1380002 Northeast Killingsworth Property\Reports\Phase II ESA\1380002_Tables Table 3 Soil Analytical Results—Metals Northeast Killingsworth Street Property Portland, Oregon Farallon PN: 1380-002

Analytical Results (milligrams per kilogram)2 Sample Sample Sample Sample Identification Location Date Depth1 Arsenic Barium Cadmium Chromium Lead Mercury Selenium Silver B01_7-7.5 B01 4/14/2015 7.5 <1.17 189 0.432 7.52 4.97 <0.0934 <2.34 <.0234 B01_24-24.5 B01 4/14/2015 24.5 <1.08 112 0.355 12.9 4.24 <0.0861 <2.15 <.0215 B02_7-7.5 B02 4/14/2015 7.5 1.25 214 1.09 13.8 236 <0.0868 <2.17 <.0217 B02_24.5-25 B02 4/14/2015 25 <1.06 154 1.454 21.3 30.1 <0.0844 <2.11 <.0211 Background Concentrations3 0.55-15.1 103-968 0.128-0.587 3-306 1-30 0.007-0.090 0.099-0.880 0.11-2.2 4 DEQ RBCss Residential 1.7 15,000 39 120,000 400 23 - 390 NOTES: < denotes analyte not detected at or exceeding the reporting limit listed. DEQ = Oregon Department of Environmental Quality > Max = The constituent risk-based concentration for this pathway is calculated as greater than 1,000,000 milligrams per kilogram RBC = Risk-Based Concentration

or 1,000,000 milligrams per liter; therefore, this substance is deemed not to pose a risk in this scenario. RBCss = RBC for the Soil Ingestion, Dermal Contact, and Inhalation pathway 1Depth in feet below ground surface. 2Analyzed by U.S. Environmental Protection Agency Method 8260B. 3Background concentrations for the Deschutes - Columbia Plateau physiographic province from the DEQ guidance document Development of Oregon Background Metals Concentrations in Soil. 4RBCs are from http://www.deq.state.or.us/lq/pubs/docs/RBDMTable.pdf.

1 of 1 G:\Projects\1380 Ascend Holdings\1380002 Northeast Killingsworth Property\Reports\Phase II ESA\1380002_Tables Table 4 Soil Analytical Results—PCBs Northeast Killingsworth Street Property Portland, Oregon Farallon PN: 1380-002

Analytical Results (micrograms per kilogram)2 Sample Sample Sample Aroclor Aroclor Aroclor Aroclor Aroclor Aroclor Aroclor Sample Identification Location Date Depth1 1016 1221 1232 1242 1248 1254 1260 B01_7-7.5 B01 4/14/2015 7.5 <10.4 <10.4 <10.4 <10.4 <10.4 <10.4 <10.4 B01_24-24.5 B01 4/14/2015 24.5 <10.2 <10.2 <10.2 <10.2 <10.2 <10.2 <10.2 B02_7-7.5 B02 4/14/2015 7.5 <9.90 <9.90 <9.90 <9.90 <9.90 <9.90 <9.90 B02_24.5-25 B02 4/14/2015 25 <10.4 <10.4 <10.4 <10.4 <10.4 <10.4 <10.4 3 DEQ RBCss Occupational 560 560 560 560 560 560 560 3 DEQ RBCsw Residential 110 110 110 110 110 110 110 NOTES: < denotes analyte not detected at or exceeding the reporting limit listed. DEQ = Oregon Department of Environmental Quality 1 Depth in feet below ground surface. PCBs = polychlorinated biphenyls 2 Analyzed by U.S. Environmental Protection Agency Method 8082A. RBC = Risk-Based Concentration 3 RBCs are from http://www.deq.state.or.us/lq/pubs/docs/RBDMTable.pdf. RBCss = RBC for the Soil Ingestion, Dermal Contact, and Inhalation pathway

RBCsw = RBC for the Leaching to Groundwater pathway

1 of 1 G:\Projects\1380 Ascend Holdings\1380002 Northeast Killingsworth Property\Reports\Phase II ESA\1380002_Tables Table 5 Soil Gas Analytical Results Northeast Killingsworth Street Property Portland, Oregon Farallon PN: 1380-002

Sample Sample Sample Sample 2-Butanone Identification Location Date Depth2 Benzene 1,3-Butadiene Toluene (Methyl Ethyl Ketone) Ethanol Acetone 2-Propanol o-Xylene m,p-Xylene Other VOCs SG1_041415 SG1 4/14/15 10.0 <3.9 <2.7 <4.6 <14 <9.2 <29 <12 <5.3 <5.3

3 DEQ RBCsi Residential 62 NA 1,000,000 NA NA NA NA 21,000 21,000 Varies NOTES: < denotes analyte not detected at or exceeding the reporting limit listed. DCE = dichloroethene 1 Analyzed by U.S. Environmental Protection Agency Method TO-15. DEQ = Oregon Department of Environmental Quality 2 Depth in feet below ground surface. Farallon = Farallon Consulting, L.L.C. 3 RBCs are from http://www.deq.state.or.us/lq/pubs/docs/RBDMTable.pdf. NA = Not applicable PCE = tetrachloroethene RBC = Risk-Based Concentration

RBCsi = RBC for the Vapor Intrusion into Buildings pathway TCE = trichloroethene

1 of 1 G:\Projects\1380 Ascend Holdings\1380002 Northeast Killingsworth Property\Reports\Phase II ESA\1380002_Tables Table 6 Soil Analytical Results—Petroleum Hydrocarbons Northeast Killingsworth Property Portland, Oregon Farallon PN: 1380-002

Analytical Results (milligrams per kilogram)2 Sample Sample Identification Date Sample Depth1 DRO ORO GRO AREA 2-1 8/16/2016 NA <25.0 141 — AREA 2-2 8/16/2016 NA <25.0 176 — AREA 2-3 8/16/2016 NA <25.0 56.4 — West Hoist Top-072916 7/29/2016 0 85,300 <1,600 <41.9 West Hoist 6.0-072916 7/29/2016 6 300 <50 <3.86 3,4 DEQ RBCss 1,100 2,800 1,200 3,4 DEQ RBCso >Max >Max 5,900 3 DEQ RBCsi Residential >Max >Max 94 3 DEQ RBCsw Residential 9,500 >Max 31 NOTES: — denotes sample not analyzed. DRO = total petroleum hydrocarbons as diesel-range organics < denotes analyte not detected at or exceeding the reporting limit listed. GRO= total petroleum hydrocarbons as gasoline-range organics > Max = The constituent risk-based concentration for this pathway NA = Not Applicable is calculated as greater than 1,000,000 milligrams per kilogram or ORO = total petroleum hydrocarbons as oil-range organics 1,000,000 milligrams per liter; therefore, this substance is deemed RBC = risk-based concentration

not to pose a risk in this scenario. RBCsi = RBC for the Vapor Intrusion into Buildings pathway 1 Depth in feet below ground surface. RBCso = RBC for the Volatilization to Outdoor Air pathway 2 Analyzed by Northwest Methods NWTPH-Dx and NWTPH-Gx. RBCss = RBC for the Soil Ingestion, Dermal Contact, and Inhalation Pathway 3 RBCs are from http://www.deq.state.or.us/lq/pubs/docs/RBDMTable.pdf. RBCsw = RBC for the Leaching to Groundwater pathway 4RBC is the lowest RBC for this exposure pathway.

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