State of Department of Environmental Quality Memorandum

Date: 2/1/2018

To: FILE

Through: Dan Hafley, Lead Worker, Northwest Region Cleanup Section Paul Seidel, Acting Section Manager, Northwest Region Cleanup Section

From: Madi Novak, Project Manager, Northwest Region Cleanup Section

Subject: Zidell Waterfront Property ECSI # 689; Staff Memorandum in support of a Certificate of Completion and No Further Action Determination

This document presents the basis for the Oregon Department of Environmental Quality’s (DEQ’s) recommended Certificate of Completion and No Further Action for the Zidell Waterfront Property, in Portland. As discussed in this memorandum, contamination in soil and sediment has been remedied consistent with requirements in the General Judgment on Stipulation and Consent, Case No. 0609-09344 (Consent Judgment); site restrictions are applied as indicated in the Easement and Equitable Servitude (EES) and amendment; and required maintenance and monitoring is ongoing, consistent with the Site Management Plan (SMP; MFA, 2018),the Upland Soil Cap Inspection and Maintenance Plan (IMP; MFA, 2013a, Appendix B to SMP), and the Bank and Sediment Remedy Operations, Maintenance, and Monitoring Plan (OMMP; MFA, 2013b)1.

The proposed Certificate of Completion and No Further Action (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 in Section 8.

1. BACKGROUND

Site location. The site’s location can be described as follows: 3121 SW Moody Avenue, Portland Oregon. - Latitude 45.4999o North, longitude -122.6693o West - Tax lot(s) 300 and 200, Township 1South, Range 1 East, Section 10 See Figure 1 for a vicinity map of the site.

1 The SMP describes requirements and processes during future site development, the IMP describes upland cap monitoring and maintenance requirements, and the OMMP describes riverbank and in-water (sediment) monitoring and maintenance requirements. Zidell Waterfront Property, ECSI 689 Staff Memorandum 1/2/2018 Page 2 of 15

Site setting. The site consists of two tax lots in downtown Portland that are approximately 14 and 16 acres, respectively, in size. The site is bounded by SW Moody Avenue on the west, the Oregon Health & Science University and the to the north and an Oregon Health & Science University facility and the Central District section of the South Waterfront Greenway to the south. Two bridges, the Bridge and the , cross over the site. The upland portion of the site is zoned CX – Central Commercial, described by the City of Portland as a zone intended to provide for commercial development within Portland’s most urban and intensely-developed areas. The site is owned by ZRZ Realty Company, and was operated upon by Zidell Marine Corporation, and Tube Forgings of America, Inc., collectively referred to herein as Zidell. Zidell was formerly engaged in the construction of barges on-site and, as of 2017, the upland portions of the site are largely vacant and planned for redevelopment.

Current and historical site features prior to remediation are depicted in Figure 2. Currently, structures include an office building, surface parking areas, a large (approximately 17,000 square foot) covered construction area, and slipway formerly utilized for launching of completed barges most of which are located in the southern portion of the site. Features north of the are limited to parking areas and working surfaces for material storage.

Zidell barge building operations ceased on the site in June 2017. Site structures will be demolished or repurposed and additional structures constructed as part of site redevelopment. Future site use is expected to be mixed commercial and residential. Site redevelopment will proceed in accordance with various applicable City of Portland requirements and under DEQ oversight to ensure construction activities are consistent with requirements in the ROD and SMP (MFA, 2018).

Physical setting. The site setting including topography, geology, groundwater, and surface water is described in the 2006 ROD and is summarized briefly. The upland portion of the site is located in Portland’s South Waterfront district, immediately south of the downtown area. The site is generally flat, and the topography has been modified over the years by fill placement, and again more recently by completion of remedial actions. The site has approximately 3,000 lineal feet of frontage on the west bank of the .

The in-water portion of the site is located between River Miles 13 and 15 on the west bank of the Willamette River, south of the Marquam Bridge. Along this reach, the river flows northwest and is 1,400 to 1,500 feet wide. During periods of low and medium flows, tidal effects are evident to river mile 26.5 (Willamette Falls); reverse flow has been measured as far upstream as Ross Island (river mile 15) during low-flow periods. Near shore river currents support deposition of fine-grained sediment in the northern portion of the site, while the southern reach exhibits higher velocities and steeper slopes that are less prone to sediment accretion. Detailed bathymetric surveys have been completed for the site before and after sediment cap construction, most recently in 2016.

Zidell Waterfront Property, ECSI 689 Staff Memorandum 1/2/2018 Page 3 of 15

The upland portion of the site is underlain by alluvial sediments composed of up to 200 feet of younger alluvium and up to 1,100 feet of older alluvium. The site is underlain by Troutdale Formation gravels and basalts. Fill material overlies the native alluvium and is now covered with the upland cap.

The following groundwater aquifers are interpreted to be present at or near the site: the unconsolidated sedimentary aquifer (generally underlying fill material from 34 feet to 100 feet below ground surface [bgs]); within the cemented sand and gravel deposits comprising the Troutdale gravel aquifer (generally below 100 feet bgs); within deeper undifferentiated fine- grained sediments (generally below 200 feet bgs); and within the Columbia River Basalt Group (below 200 feet bgs), most prominently within flow interbeds and fractures. The Troutdale Formation aquifer is an important and productive aquifer in the Portland Basin, in which many public-supply, industrial, and domestic wells are completed. Shallow perched groundwater is present in the fill material at depths ranging from about 5 feet and 30 feet depending on the season. The depth to water varies seasonally, with the greatest fluctuations observed near the Willamette River. In general, groundwater flow is to the east toward the Willamette River, which represents a regional discharge boundary.

Site history. Historically, the site was used for building, dismantling, converting, repairing, and salvaging ships and barges. It was also used for scrap metal operations, wire burning and aluminum smelting, and housing construction. The south part of the site was, until 2017, used for barge construction. The northern upland site is currently vacant or used to store fill materials. As described in the 2006 Consent Judgment, various businesses occupied and operated on the site beginning in 1926. By 1947, the Zidell ship dismantling company and numerous other businesses were operating on site. The barge construction business began in 1968 and ship dismantling, including wire burning and secondary aluminum smelting, ceased by the 1970s. Since that time, most site activity has occurred south of the Ross Island Bridge associated with barge construction.

In 1994, Zidell entered into a Voluntary Cleanup Program agreement (WMCVC-NWR-94-23) with DEQ to conduct a remedial investigation and feasibility study. In 2005, DEQ issued a Record of Decision (ROD) for the site, and in 2006 Zidell entered into a Consent Judgment for Remedial Design and Remedial Action (0609-09344). As is discussed below, the ROD identified a combination of actions to address environmental contamination in both the upland site (including riverbank), and in sediments lying adjacent to the site (under the ownership of the Oregon Department of State Lands). Remedial actions selected by DEQ included removal and either re-location or off-site disposal of contamination hot spots, and upland and in-water capping.

Zidell Waterfront Property, ECSI 689 Staff Memorandum 1/2/2018 Page 4 of 15

2. BENEFICIAL LAND AND WATER USE DETERMINATIONS

Land use. The Zidell property has been in heavy industrial use since at least 1947 until the present time. The property is zoned Central Commercial (CX) by the City of Portland (COP), which is intended to provide for commercial development within Portland’s most intensely developed areas. Future redevelopment plans by Zidell are expected to include commercial, retail and residential development. Future use of the site for industrial purposes is not contemplated.

The upland site contains both “greenway” and “non-greenway” areas as governed by COP planning agencies. The greenway zoning designation provides for a setback that extends 100 feet landward from the pre-remedy construction top of bank. Within this area, exposure to ecological receptors, as well as human receptors, is expected to occur. As described in the ROD, the non- greenway area is anticipated to be developed such that there will be an absence of ecologically important habitat. Therefore, unless land use changes, only human exposure is considered complete in the non-greenway area.

Groundwater use. The Zidell site and adjoining properties are supplied with water by the COP municipal water supply, originating in the Bull Run watershed or COP well fields. Consistent with the EES, Groundwater at and in the vicinity of the site is not used as a source of drinking water, and drinking water will continue to be supplied to the site by COP for the foreseeable future. The only beneficial use of groundwater is discharge to the Willamette River.

Surface water use. The Willamette River is the only surface water body at or near the site. Beneficial uses of the Willamette River water include aesthetic quality, recreation, transportation, wetland areas, fishing, anadromous fish , and fish and wildlife habitat.

3. INVESTIGATION WORK

The site has an extensive history of environmental investigations dating from 1987, when DEQ completed a preliminary assessment for the property on the behalf of the US Environmental Protection Agency (EPA). In 1990, DEQ prepared a strategy recommendation, recommending an expanded preliminary assessment that was subsequently conducted by EMCON between 1994 and 1996. A remedial investigation (RI) was conducted on behalf of Zidell by Maul, Foster and Alongi, Inc (MFA) between 1997 and 2004 (MFA, 2003b, 2004a). Extensive work was completed both upland and in-water for the RI. Figure 3 shows locations of investigative work. Numerous soil samples were collected from temporary borings and test pits to characterize the lateral and vertical extent of contamination within the site upland, while multiple ground water wells were installed to characterize shallow groundwater. In the Willamette River offshore of the site, bulk sediment and pore water samples were collected to characterize sediment chemistry and toxicity to benthic invertebrates. The results of the RI work are summarized below and also in the 2005 DEQ Staff Report recommending remedial action, and in the ROD identifying the Zidell Waterfront Property, ECSI 689 Staff Memorandum 1/2/2018 Page 5 of 15

selected remedy (DEQ 2005a, 2005b). See Section 7 below for a more complete accounting of investigation and remedy-related reports.

Nature and extent of contamination. Environmental contaminants identified during site investigation work included metals, polycyclic aromatic hydrocarbons (PAHs), polychlorinated biphenyls (PCBs), petroleum hydrocarbons, and asbestos in soil. Soil contamination north of the Ross Island Bridge was more widespread than south of the Bridge. Significant contamination was generally limited to less than 5 feet below ground surface (bgs), except on the riverbank north of the Ross Island Bridge near the shoreline, where contamination extended deeper. Contaminant concentrations in (pre- remedy) soil are summarized in the attached Tables 1 (non-greenway) and 2 (greenway and riverbank).

Shallow groundwater was determined to be contaminated with metals, PAHs, PCBs, volatile organic compounds (VOCs), and petroleum hydrocarbons. Generally, groundwater impacts are concentrated in the interior of the site and attenuate as they reach the site riverbank. Remedial investigation shallow groundwater contaminant levels are summarized in Table 3.

Site-related sediment and pore water contamination were evaluated offshore in the Willamette River. Metals, PAHs, PCBs, petroleum hydrocarbons, and butyltins were identified as both elevated and site-related. Significant levels of contamination were identified within 200 feet of the shoreline, although lesser impacts extended to approximately 500 feet from shoreline. Sediment and pore water contamination was evident in surface sediment (i.e., ~top 10 inches), including indication of toxic conditions for benthic invertebrates. Sediment contamination increased with depth in some locations. Remedial investigation sediment and pore water concentrations are summarized in Tables 4 and 5, respectively.

4. RISK EVALUATION

Human health and ecological risk assessments (HHRA and ERA, respectively) were completed for the site (MFA 2003a,b) and protectiveness evaluations were conducted upon completion of remedial actions (MFA 2017). The table below summarizes pathways assessed for human health and ecological receptors.

Pathway Receptor Evaluated in Basis for exclusion risk assessment? SOIL Direct Contact Residential Yes Urban residential No See Note 1. Occupational No Construction worker Yes Excavation worker Yes Terrestrial plants, birds, Yes See Note 2. mammals, invertebrates Zidell Waterfront Property, ECSI 689 Staff Memorandum 1/2/2018 Page 6 of 15

Pathway Receptor Evaluated in Basis for exclusion risk assessment? Volatilization to Residential No See Note 3. outdoor air Urban residential No Occupational No Vapor intrusion Residential No See Note 3. into buildings Urban residential No Occupational No Leaching to Residential No See Note 4. groundwater Urban residential No Occupational No GROUNDWATER Ingestion and Residential No See Note 4. inhalation from Urban residential No tap water Occupational No Volatilization to Residential Yes outdoor air Urban residential No See Note 1. Occupational No Vapor intrusion Residential Yes into buildings Urban residential No See Note 1. Occupational No Groundwater in Construction and Yes excavation excavation worker Groundwater Aquatic organisms Yes discharge to Recreational fishers surface water (human) SEDIMENT Ingestion of fish Recreational fishers Yes (human) Ingestion of fish Birds and Mammals Yes Direct contact Benthic invertebrates Yes with sediment and pore water

Notes: 1. Assessment of urban residential and occupational exposure was not conducted because the risk assessment for residential receptors is protective of urban residential and occupational exposure. 2. Ecological risk was evaluated in the greenway, as the only site location for which ecological exposure is applicable and relevant. 3. Volatiles contaminants were not detected in soil above default screening values. 4. Groundwater is not used for drinking or other purposes, nor is it expected to be used in the future. City water is provided. Groundwater discharge to surface water is considered the only “beneficial use”.

The HHRA concluded that contaminant concentrations of metals, PAHs, and PCBs in soil resulted in unacceptable risk for future residents, construction workers, and excavation workers Zidell Waterfront Property, ECSI 689 Staff Memorandum 1/2/2018 Page 7 of 15

via direct contact. Further, sediment contaminant concentrations of bioaccumulative chemicals, PCBs and some PAHs, resulted in unacceptable risk to recreational fishers who consume their catch. No unacceptable human health risks for exposure to groundwater were identified in the HHRA and subsequent groundwater evaluations (MFA, 2003a,b; 2017).

Risk to the environment was assessed for terrestrial species of plants, soil invertebrates, birds, and small mammals. Risk associated with nearshore sediment and pore water were evaluated for benthic invertebrates and higher trophic organisms such as birds and mammals. The ERA concluded that portions of the upland site posed an unacceptable risk to ecological receptors given concentrations of metals, PCBs, and some PAHs in soil. In sediment, unacceptable risk was identified for sediment-dwelling organisms, and birds and mammals, through direct contact and food web exposures for metals, PCBs, some PAHs, and tributyltin (TBT).

Cleanup levels protective of human health and the environment were developed for the following media, contaminants of concern (COCs), and pathways:

Soil. Residents and construction workers, and ecological receptors, in direct contact with metals, PAHs, and PCBs in soil. Further, the ROD required excavation of asbestos- containing material (ACM) in soil.

Sediment. Recreational fisher exposed to PCBs and PAHs accumulated in fish tissue and benthic biota in direct contact with metals, PAHs, PCBs, and tributyltin in sediment.

5. REMEDY SELECTION AND DESIGN

Based on a Feasibility Study that described remedial alternatives available to address unacceptable risk to human health and the environment (MFA, 2004b), DEQ completed a Staff Report selecting a recommended remedial action for the site (DEQ 2005a). The Staff Report was submitted for public comment. Subsequently, DEQ issued a ROD that described the selected remedy and included a responsiveness summary to public comments on the Staff Report (DEQ 2005b). The remedial actions were selected to attain cleanup levels protective of human health and the environment for the media, COCs, and pathways described in Section 4, and included actions for soil and sediment. Remedial action objectives identified in the ROD are:

Soil • Prevent future resident and worker exposure to soil containing constituents exceeding acceptable risk-based concentration values. • Prevent ecological receptors from exposure to soil containing chemicals of potential ecological concern exceeding DEQ screening level values. • Prevent transport of chemicals of concern in soil to the Willamette River through stabilization of shoreline and stormwater runoff controls. • Remediate soil hot spots to the extent feasible. Sediment Zidell Waterfront Property, ECSI 689 Staff Memorandum 1/2/2018 Page 8 of 15

• Protect humans against exposure to site-related COCs above protective levels. • Minimize transport of sediment containing COCs above cleanup levels to downstream areas of the river. • Ensure that sediments contaminated with COCs above protective levels do not become accessible to benthic organisms or to aquatic and terrestrial organisms through food-chain exposure. • Remediated hot spots of contamination in sediment by reducing their concentration, volume, or mobility to the extent feasible and practical. • Protect ecological habitat and beneficial uses of surface water adjacent to the facility.

The selected action for soil required 1) excavation and off-site disposal of human health hot spot soils and other hazardous materials from the site; 2) excavation and on-site consolidation of ecological-based hot spot soils on the non-greenway portion of the site; 3) engineering controls involving capping the site to reduce potential exposure to residual contamination; 4) placement of institutional controls to ensure long-term effectiveness of engineering controls; and 5) source control measures to protect the Willamette River from further releases of hazardous substances.

The selected action for sediment required 1) selective dredging of hot spot sediments in the area used to launch barges; 2) engineering controls involving placement of a sediment cap over impacted sediments; 3) performing periodic monitoring of sediment conditions outside of the final cap area to assess capping reliability and natural restoration of marginally impacted sediments that exceed cleanup levels; and 4) institutional controls to ensure long-term effectiveness of the cap.

The upland remedy was designed in several phases to be compatible with changing site operations and uses. • Final upland remedial design report (MFA, 2010) • Phase III A & B upland cap remedial action plan (MFA, 2012b) • Phase III remedial action work plan for 2016 cap construction (MFA, 2016a) The bank and sediment remedy design was developed iteratively with DEQ review and input, as is common on complex in-water remedial designs. The final design is memorialized in the Final Bank and Sediment Remedial Design Report (MFA, 2012a).

The remedial actions implemented to meet ROD requirements are described below.

6. WORK PERFORMED

Upland, bank, and sediment remedial actions were performed in multiple phases on the site between 2007 and 2016. Upland greenway and non-greenway (see Section 2.1 for a description of greenway versus non-greenway areas); bank; and sediment remedial areas are shown on Figure 4. The following work was accomplished: Zidell Waterfront Property, ECSI 689 Staff Memorandum 1/2/2018 Page 9 of 15

• 5,500 cubic yards of human health hotspot soil in the upland and riverbank were excavated and disposed offsite at a Subtitle D landfill. • 16,500 cubic yards of soil in the greenway and riverbank with contaminant concentrations exceeding ecological hotspot levels were excavated and placed in non- greenway areas (3,100 cubic yards); placed in a TriMet Containment Cell in the western landing of the Tilikum Crossing Bridge (10,300 cubic yards); or disposed of at a subtitle D landfill (4,300cubic yards). • A total of approximately 16,000 cubic yards of soil (hotspot and non-hotspot) soils were disposed at a subtitle D landfill. Approximately 4,000 cubic yards of soil required treatment on-site before transport to the landfill. • Seventy tons of ACM in soil was segregated and disposed of within the designated asbestos area at a subtitle D landfill. • Demarcation fabric was placed over impacted soil remaining on site as a delineation boundary in areas where clean imported fill was placed as part of an engineered cap. This included riverbank areas extending to elevation +10-feet (City of Portland vertical datum), representing the top of the in-water sand cap fill. • Engineered caps were placed or existing infrastructure (cement, asphalt, steel plates) was determined to be an acceptable cap over contaminated soil (non-hotspot) in all upland areas. Upland caps consist of a minimum of 2-feet of clean soil, 2-feet of gravel, asphalt, or concrete. See Figure 5 for the final cap configuration. Following capping, soil caps were vegetated for stabilization purposes. • In two design reaches (Slipway and Bridge), the riverbank was stabilized through excavation of over-steepened contaminated soils, or placement of clean imported fill at a stable slope. A rock armor layer (max 24 inch diameter) was placed on the bank and a vegetated soil cap was placed above the armor. The soil cap was between 2 and 10 feet thick, including an 18-inch-thick cover of topsoil that was heavily vegetated using bioengineering and biotechnical techniques. • 200 cubic yards of hot spot sediments were selectively dredged in the slipway and disposed of off-site. • Thirteen acres of sediment was capped below ordinary high water, using two different types of caps, as described further below and as shown in Figure 5.

o The majority of the cap (12 acres) is a sand cap, consisting of material obtained from the Columbia River that was tested and determined to be clean. The sand cap is at least 2 feet in depth, but ranges up to 18 feet, in some areas close to shore.

o A low-profile cap was placed in the area formerly used to launch barges, a 1 acre area. The low-profile cap consists of a reactive core mat (RCM) with activated carbon and apatite to limit movement of organic and inorganic contaminants.

o A geosynthetic clay liner (GCL) (approximately 0.5 acres) was used to supplement the sediment cap in two locations: at City Outfall 07b and in the North Bridge Reach. GCL was placed under the rock armor at the City Outfall 7B location in Zidell Waterfront Property, ECSI 689 Staff Memorandum 1/2/2018 Page 10 of 15

order to maintain outfall stormwater flow across the cap area during times of low water. GCL was placed in the northern bridge reach in an area under the sand where the sand cap layer was projected to be thinner than the required 2-feet. • The entire sediment cap was armored with rock to protect it from erosion. Rock armor was selected from Oregon Department of Transportation standard riprap specifications: Class 700 (max 24 inch diameter) in steep areas (southern portions of the cap), Class 200 (max 15 inch diameter) in all other design areas, and Class 100 (max 10 inch diameter) in a limited area of the slipway ramp. • A significant portion of the sediment cap armor (8 acres) was covered with rounded 2.5-inch-minus rounded gravel for habitat enhancement. • Upland sources of contamination associated with industrial operations were controlled through implementation of best management practices, cleaning and upgrades to existing infrastructure, construction of infiltration facilities, stabilization of riverbank slopes, and compliance with a 1200-Z stormwater permit (which is terminated due to cessation of barge construction operations at the site). The following reports document the completion of remedial activities and were approved by DEQ: • The upland remedial action completion report (MFA, 2011) documents the removal of upland hotspots, monitoring well decommissioning, stormwater system conveyance modifications, and construction of the infiltration basin. • The bank and sediment remediation construction completion report (MFA, 2012a) documents the removal of riverbank hotspots, slipway dredging, outfall modifications decommissioning, sediment cap placement, and riverbank cap placement. A minor area of the riverbank remained incomplete because it had been leased to TriMet for bridge construction activities. • The greenway cap construction completion report (MFA. 2013c) documents construction of the upland soil cap in the greenway area, except in areas that were leased to TriMet for bridge construction activities. • The 2014 greenway cap and bank cap restoration area construction completion report (MFA, 2015) documents the construction of the riverbank fill and cap, and the upland greenway cap in the areas that previously had been leased to TriMet to support construction of the Tilikum Crossing Bridge. • The upland cap construction completion report (MFA, 2016b) documents the phases of upland cap construction to the west of the greenway between 2012 and 2016.

7. ONGOING REQUIREMENTS

The ROD requires ongoing inspections, monitoring, maintenance, reporting, controls, and reviews to ensure the remedy remains effective. Ongoing requirements are listed below, and will be a condition of the Certificate of Completion and No Further Action determination.

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Periodic Review. In general accordance with EPA’s Comprehensive Five-Year Review Guidance (EPA 540-R-01-007; June 2001), at least once every five years, DEQ will review the remedy to ensure that the Site remains protective of public health, safety, and welfare and the environment. Periodic reviews will include evaluation of monitoring data, progress reports, inspection and maintenance reports, land and water uses, compliance with institutional controls, and any other relevant information. As part of the 5-year review, DEQ will coordinate with Oregon Department of Human Services on the continued use of institutional controls in the form of fish advisories for the lower Willamette River.

Upland Site Restrictions. An Easement and Equitable Servitude (EES) is filed with the County Clerk, Multnomah County (recorded on October 24, 2006 as Document No. 2006-197624) in compliance with the Consent Judgment. The EES requires the following site restrictions:

• Groundwater may not be used for consumption. • The soil cap must be maintained consistent with a DEQ-approved Inspection and Maintenance Plan (IMP) and Soil Management Plan (SMP). • Food crops may not be grown on site. • The property may not be occupied unless above controls are maintained and continue to protect public health and the environment. • Reports on the maintenance and efficacy of the controls listed above are required annually for the first 10 years after remediation completion, and every five years thereafter. • DEQ must be notified, in advance, of any transfer of interest in or occupancy of the property. • DEQ must be notified 30 days in advance of filing any document initiating a rezone of the property that would change the base zone of the property.

The EES was amended on January 31, 2011 as Document No. 2011-014620 to update the description of the property to reflect property transactions.

Upland Engineering and Institutional Controls Maintenance and Monitoring. Specific requirements are provided in the following two plans:

• The IMP specifies the long-term inspection and maintenance requirements for the cap and other engineering controls. • The SMP guides future excavation activities that could potentially encounter impacted soil; the SMP outlines specific requirements for managing soil as part of future redevelopment.

Copies of both documents are available for review at DEQ’s on-site ECSI database (see “Webdocs”).

Bank and Sediment Institutional Controls, Maintenance, and Monitoring. By terms of the Submerged and Submersible Land Lease, 45591-ML, Zidell leases the state-owned submerged Zidell Waterfront Property, ECSI 689 Staff Memorandum 1/2/2018 Page 12 of 15

lands in the Willamette River (adjacent to the property it owns) on which the bank and sediment cap was constructed. The land lease identifies DSL-approved uses and restrictions:

• Following completion of construction of the sediment cap, the area shall be returned to public entry for recreational and other transient uses, except where the cap has been constructed, where anchoring, grounding, and all vessels equipped with a propeller or motor of any kind.

• Maintain the cap in good repair through compliance with the ROD.

• Respond immediately to the release of hazardous substances attributable to failure of the sediment cap function as designed or from damage, regardless of cause.

The perimeter of the cap is established as a Regulated Navigation Area (RNA) in order to prohibit commercial activities that may damage the cap, including restrictions on anchoring, dredging, or dragging. Zidell placed three (3) buoys flanking the cap RNA after receiving permission from the USCG and the Oregon Marine Board to place Private Aids to Navigation.

A Bank and Sediment Remedy Operations, Maintenance, and Monitoring Plan (OMMP) (MFA, 2013b) was developed to address elements required in the ROD. The OMMP describes required routine cap performance monitoring, an emergency response plan to be implemented should an environmental release occur, and a contingency plan that will identify actions to be taken if the cap fails to meet performance criteria. The OMMP requires visual inspections and bathymetric surveys of the cap and monitoring of the natural recovery of low-level sediment contamination outside the cap boundary. A copy of the OMMP is also provided at DEQ’s ECSI website.

8. PROTECTIVENESS EVALUATION

The Zidell remedy, as described above, meets the requirements set forth in the ROD and Consent Judgement and is protective of human health and the environment. A detailed evaluation of the remedy elements, as implemented, demonstrates consistency with all relevant ROD requirements (MFA, 2018). Further, the SMP, IMP, and OMMP provide comprehensive requirements and guidelines for maintaining the effectiveness of the upland remedy long-term, including as redevelopment of the upland site occurs. These documents identify ongoing inspections, monitoring, and maintenance required to ensure effectiveness of the upland, bank, and in-water remedy in perpetuity (MFA, 2018).

The ROD requires reevaluation of sediment cleanup levels for the fish-ingestion pathway as part of the five-year review of remedy protectiveness. At the time of ROD issuance (2005), evaluation of PCBs and other contaminants in Willamette River sediment was being conducted as part of Portland Harbor Superfund Site (PH) characterization activities. DEQ anticipated that the PH findings could inform more reliable sediment cleanup levels for the fish ingestion exposure pathway. Evaluation of the PH ROD shows that the Zidell remedy, i.e., cleaning up PCBs to meet background conditions, is consistent with the PH approach.

Zidell Waterfront Property, ECSI 689 Staff Memorandum 1/2/2018 Page 13 of 15

9. RECOMMENDATION

On September 12, 2006, Zidell and DEQ entered a Consent Judgment with DEQ for cleanup of environmental contamination at the Zidell site. The Consent Judgment specifies that Zidell would implement the selected remedy described in the ROD and DEQ would issue a Certificate of Completion upon DEQ’s determination that the remedial action for the site had been fully and satisfactorily performed.

Based on the findings documented in this memorandum, pursuant to OAR 340-122-0072 (5)(d), a Certificate of Completion and No Further Action determination is recommended, in accordance with the Oregon Environmental Cleanup Law, ORS 465.200 et seq, except to conform with on-going requirements listed in Section 6.

10. ADMINISTRATIVE RECORD

Cited Documents

DEQ. 2005a. Staff Report, Zidell Waterfront Property, ECSI no. 689. Oregon Department of Environmental Quality, Northwest Region—Voluntary Cleanup Program. January 20.

DEQ. 2005b. Remedial Action Record of Decision, Zidell Waterfront Property, ECSI no. 689. Oregon Department of Environmental Quality, Northwest Region—Voluntary Cleanup Program. June.

MFA. 2003a. Human Health Risk Assessment Addendum: Risk Related to Indirect Exposure of Recreational Anglers to Willamette River S ediment through Fish Ingestion, Zidell W aterfront Property, Portland, Oregon. Prepared for ZRZ Realty Company, Inc. Maul Foster & Alongi, Inc. January 6.

MFA. 2003b. Remedial Investigation and Risk Assessment, Zidell Waterfront Property. Prepared for ZRZ Realty Company, Inc. Maul Foster & Alongi, Inc. July 11.

MFA. 2004a. Supplemental Remedial Investigation Report: Riverbank Characterization. Zidell Waterfront Property, 3121 SW Moody Avenue, Portland, Oregon. Prepared for ZRZ Realty Company, Inc. Maul Foster & Alongi, Inc. October 8.

MFA. 2004b. Feasibility Study Report. Zidell waterfront property, 3121 SW Moody Avenue, Portland, Oregon. ECSI #689. Prepared for ZRZ Realty Company, Portland, Oregon. Maul Foster & Alongi, Inc., Portland, Oregon. December 2.

MFA. 2010. Final Upland Remedial Design Report, Zidell Waterfront Property, 3121 SW Moody Avenue, Portland, Oregon, ECSI no. 689. Prepared for ZRZ Realty Company. Maul Foster & Alongi, Inc., Portland, Oregon. July 19.

Zidell Waterfront Property, ECSI 689 Staff Memorandum 1/2/2018 Page 14 of 15

MFA. 2011. Upland Remedial Action Completion Report, Zidell Waterfront Property, ECSI no. 689. Prepared for ZRZ Realty Company. Maul Foster & Alongi, Inc., Portland, Oregon. April 7.

MFA. 2012a. Construction Completion Report, Zidell Bank and Sediment Remediation Project, Zidell W aterfront Property, 3121 SW Moody Avenue, Portland, Oregon, ECSI no. 689. Prepared for ZRZ Realty Company. Maul Foster & Alongi, Inc., Portland, Oregon. April 26.

MFA. 2012b. Phase III A & B Upland Cap Remedial Action Plan, Zidell Waterfront property, 3121 SW Moody Avenue, Portland, Oregon. Prepared for ZRZ Realty Company. Maul Foster & Alongi, Inc., Portland, Oregon. November 9.

MFA. 2013a. Zidell Interim Site Management Plan, 3121 SW Moody Avenue, Portland, Oregon, ECSI no. 689. Prepared for ZRZ Realty Company. Maul Foster & Alongi, Inc., Portland, Oregon. May 2.

MFA. 2013b. Bank and Sediment Remedy Operations, Maintenance, and Monitoring Plan, Zidell Waterfront Property, Portland, Oregon. Prepared for ZRZ Realty Company. Maul Foster & Alongi, Inc., Portland, Oregon. June 12.

MFA. 2013c. Letter (re: greenway cap construction completion report, Zidell waterfront property, 3121 SW Moody Avenue, Portland, Oregon, ECSI no. 689) to S. Manzano, Oregon Department of Environmental Quality, from E. Bakkom, Maul Foster & Alongi, Inc., Portland, Oregon. August 20.

MFA. 2015. Letter (re: 2014 Greenway cap and bank cap restoration area construction completion report, Zidell waterfront property, Portland, Oregon, ECSI No. 689) to S. Manzano, Oregon Department of Environmental Quality, from E. Bakkom, Maul Foster & Alongi, Inc., Portland, Oregon. June 30.

MFA. 2016a. Letter (re: Phase III remedial action work plan for 2016 cap construction, Zidell waterfront property, Portland, Oregon, ECSI No. 689) to S. Manzano, Oregon Department of Environmental Quality, from E. Bakkom, Maul Foster & Alongi, Inc., Portland, Oregon. May 10.

MFA. 2016b. Letter (re: Upland cap construction final completion report, Zidell bank and sediment remediation project, Zidell Waterfront Property, 3121 SW Moody Avenue, Portland, Oregon, ECSI No. 689) to S. Manzano, Oregon Department of Environmental Quality, from J. Faust and E. Bakkom, Maul Foster & Alongi, Inc., Portland, Oregon. December 14.

MFA. 2017. Annual Site Activity Summary Report – 2016, Zidell Waterfront Property, 3121 SW Moody Avenue, Portland OR, ECSI No. 689 to M. Novak, Oregon Department of Environmental Quality, from J. Faust and E. Bakkom, Maul Foster & Alongi, Inc., Portland, Oregon. December 6.

Zidell Waterfront Property, ECSI 689 Staff Memorandum 1/2/2018 Page 15 of 15

MFA. 2018. Zidell Upland Site Management Plan, 3121 SW Moody Avenue, Portland, Oregon, ECSI no. 689. Prepared for ZRZ Realty Company. Maul Foster & Alongi, Inc., Portland, Oregon. January.

Other Site Documents

MFA. 2007a. Remedial Design/Remedial Action Work Plan, Zidell Waterfront Property, 3121 SW Moody Avenue, Portland, Oregon, ECSI no. 689. Prepared for ZRZ Realty Company. Maul Foster & Alongi, Inc., Portland, Oregon. April 10.

MFA. 2007b. Interim S ource Control Measures P lan, Zidell Waterfront P roperty, 3121 SW Moody Avenue, Portland, Oregon, ECSI no. 689. Prepared for ZRZ Realty Company. Maul Foster & Alongi, Inc., Portland, Oregon. April 13.

MFA. 2007c. Supplemental Remedial Investigation: Sampling and Analysis Plan for Additional Sediment Assessment, Zidell Waterfront Property, Portland, Oregon, Oregon Department of Environmental Quality, ECSI no. 689. Prepared for ZRZ Realty Company. Maul Foster & Alongi, Inc., Portland, Oregon. May 24.

11. ATTACHMENTS

Figure 1 Vicinity map Figure 2 Facility Features Figure 3 Soil, Groundwater, and Sediment Sample Locations Figure 4 Remediation Areas Figure 5 Final Cap Areas

Table 1 Pre-Remedy Contaminant Concentrations in On-Site Soil – Non-Greenway Area Zidell Waterfront Property Concentration1 Range Location of Maximum Number of Concentration Compound Samples Min. Max. Average

Metals Antimony 52 3 350 40 S-54 Arsenic 98 1 186 13 B-3B Cadmium 57 0.25 74 5.4 S-50 Chromium 68 0.07 568 71 S-50 Copper 48 12.2 40,700 1370 S-51 Lead 163 0.02 58,000 948 S-51 Nickel 48 0.12 2690 161 S-54 Zinc 49 32.4 19,900 1979 S-51 PAHs Benz(a)anthracene 86 2.5 86,000 1861 S-48 Benzo(a)pyrene 86 2.5 63,000 1586 S-48 Benzo(b)fluoranthene 86 2.5 100,000 1972 S-48 Benzo(k)floranthene 86 2.5 37,000 1172 S-48 Chrysene 86 2.5 87,000 1889 S-48 Dibenz(a,h)anthracene 58 2.5 7,500 222 S-48 Indeno(1,2,3-c,d)pyrene 77 2.5 2,800 541 S-48 PCBs Aroclor 1242 126 0.05 17 0.35 HS-17 Aroclor 1254 126 0.05 50 1.63 MW-12 Aroclor 1260 126 0.05 88 2.9 S-23 Notes: 1 Concentrations reported in micrograms per kilogram (ug/kg) Table 2 Pre-Remedy Contaminant Concentrations in On-Site Soil – Greenway & Riverbank Area Zidell Waterfront Property Concentration1 Number of Range Location of Maximum Compound Samples Min. Max. Average Concentration

Metals Antimony 82 1.54 2,460 118 HS-3 Arsenic 100 0.5 78 9.7 R-47 Cadmium 83 0.11 132 5.4 R-12 Chromium 83 7.3 1,540 120 S-5 Copper 75 17 10,900 582 S-8 Lead 129 5 20,800 1,051 R-12 Mercury 80 0.05 20.2 1.6 R-50 Nickel 74 3.9 11,500 294 R-50 Zinc 75 1 26,100 1,903 S-8 PAHs Benz(a)anthracene 97 2.5 4,700 860 S-90 Benzo(a)pyrene 95 2.5 3,800 505 S-90 Benzo(b)fluoranthene 94 2.5 4,330 558 R-20 Benzo(k)floranthene 97 2.5 1,300 773 HS-2 Chrysene 97 8.0 7,400 947 S-90 Dibenz(a,h)anthracene 85 2.5 500 79 S-90 Indeno(1,2,3-c,d)pyrene 94 2.5 1,200 318 HS2 PCBs Aroclor 1242 115 0.002 23 0.45 S-12 Aroclor 1254 115 0.002 31 1.35 S-12 Aroclor 1260 115 0.02 23 1.52 HS-3 Notes: 1 Concentrations reported in micrograms per kilogram (ug/kg) Table 3 Pre-Remedy Contaminant Concentrations in Groundwater Zidell Waterfront Property Concentration Range Number (ug/L) of Min. Max Location of Maximum Compound Samples Concentration Metals Antimony 99 2 148 MW-5 Arsenic 105 1 170 MW-6 Cadmium 105 0.133 7 MW-5 Chromium 99 1.8 169 MW-2 Copper 105 0.5 3440 MW-5 Lead 106 0.25 986 MW-8 Mercury 92 0.05 2.2 MW-8 Nickel 105 0.04 318 MW-5 Zinc 99 5 2620 MW-5 PAHs Benz(a)anthracene 69 0.046 0.16 MW-5 Benzo(a)pyrene 69 0.046 0.16 MW-5 Benzo(b)fluoranthene 69 0.046 0.19 MW-5 Benzo(k)floranthene 69 0.046 0.11 MW-5 Chrysene 69 0.046 0.18 MW-5 PCBs Aroclor 1254 82 0.08 2 MW-9 Aroclor 1260 82 0.08 2.3 MW-9 Notes: 1 Concentrations reported in micrograms per liter (ug/L) Table 4 Pre-Remedy Contaminant Concentrations in Willamette River Sediments Zidell Waterfront Property Concentration1 Number of Range Location of Maximum Compound Samples Min. Max. Average Concentration

Metals Antimony 88 5 287 9.3 WRS-10 Arsenic 96 1.9 25 3.9 WRS-9 Cadmium 96 0.12 6.5 1.4 WRS-38 Chromium 96 11.2 143 31.6 WRS-6 Copper 96 1.6 1,210 76.5 WRS-9 Lead 96 2 2,290 94.4 WRS-18 Mercury 90 0.016 1.4 0.16 WRS-26 Nickel 96 11.5 151 27.7 WRS-6 Zinc 96 35 2,270 183 WRS-7 PAHs Benz(a)anthracene 79 0.0055 3,000 153 WRS-16 Benzo(a)pyrene 79 0.0055 130 118 WRS-15 Benzo(b)fluoranthene 792 0.01 1,700 131 WRS-15 Benzo(k)floranthene 79 0.0055 1,500 111 WRS-16 Chrysene 79 0.0055 3,300 167 WRS-16 Dibenz(a,h)anthracene 79 0.0044 190 65 WRS-16 Indeno(1,2,3-c,d)pyrene 79 0.0044 630 99 WRS-16 PCBs Aroclor 1254 79 0.12 5000 167 WRS-9 Aroclor 1260 79 0.12 2600 138 WRS-10 Notes: 1 Concentrations reported in micrograms per kilogram (ug/kg) Table 5 Pre-Remedy Contaminant Concentrations in Willamette River Sediment Pore Water Zidell Waterfront Property

Compound Number of Range Location of Maximum Samples Min. Max. Average Concentration

Metals Arsenic 9 0.5 4.2 2.17 WRS-28 Cadmium 9 0.25 0.25 0.25 NA2 Chromium 9 1.4 8 3.87 WRS-31 Copper 9 0.5 12 2.63 WRS-28 Lead 9 0.25 3.2 0.62 WRS-28 Mercury 9 1 1 1 NA Nickel 9 1.9 6.3 3.96 WRS-31 Tributyltin 19 0.03 0.6 0.14 WRS-22 Zinc 9 2 26 6.73 WRS-28 Notes: 1 Concentrations reported in micrograms per liter (ug/L). 2 Not applicable – compound not detected in sediment pore water samples. File: X:\8014.01 ZRZ Realty Company\32\Projects\06\Fig1-1_Site Location.mxd

Site

TILIKUM CROSSING Print Date:03/02/2012 Approved By: L. Ovelar

Site Address: 3121 SW Moody Ave, Portland, Oregon Source: US Geological Survey (1990) 7.5-minute Legend Figure 1 topographic quadrangle: Portland Zidell Property Boundary Section 10, Township 1 South, Range 1 East Site Location Programmatic Remedial Action Plan Produced By: rroberts ZRZ Realty Company Portland, Oregon

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This product is for informational purposes and may not have been prepared for, or be suitable for legal, engineering, or surveying purposes. Users of this information should review or consult the primary data and information sources to ascertain the usability of the information. Feet Project: 8014.01.32/06CG DATE 05/04/04 Figure Vancouver: (360) 694-2691 ZRZ REALTY COMPANY Portland: (971) 544-2139 DWN. JLN APPR. SW MOODY AVENUE REVIS. 11/29/04 PORTLAND, OREGON PROJECT NO. FACILITY FEATURES S-72 S-71

S-70 B-10AMW-1 S-69

S-76 S-73S27

S-74

S-68 S-56

S-77 S-75 S-66 HS-16 HS-19 S31 S17 S18B S-55S18

Path: X:\8014.01 ZRZRealty Company\32\Projects\06\Fig2-3_RISample Locations.mxd S-86 S-54 Former ZRZ Property HS-17 S-53 S16 S-67 S-65 S30 S15 HS-18 S-85 HS-13 GP-25 S-52 S-64 GP-23 S-78 GP-21 GP-1 S35 S24GP-4GP-2 S25 S-51 GP-22 GP-20 GP-30 S22 B-9A GP-3 S-50 MW-14 MW-13 HS-14 S13 S14 S-63 GP-18 S12 GP-9 GP-11 AREA 3 Former OHSU Property S-44 S-49 GP-28 S-40 S-88B HS-10 S10 S-88A S-79 S29 GP-29 B-7A S-42 S-62 B-3BMW-5 S-28 S-39MW-4 S-41 HS-9S-43 S-31 HS-15 S21 S34 S-26 T S-1(V) HS-11 S-93 S-27 AREA 1 S-45 S37 GP-5 S-84 S-46 S40 S-82 V-2 S7 MW-12 GP-6S41 S-80 S-83 S-34 GP-7GP-8 S-81 AREA 2 HS-8 S-24 MW-2B-5D HS-20S-47 S-29 S26 S20 S-32 S36 HS-6S-25 GP-14S-22 S-23 GP-32 S-16 S28 S-30 GP-15 S-89 S-48 HS-12 TP-7 S-18 TP-6 MW-6 GP-10 V-1 GP-16 S-15 HS-1 MW-15 GP-27 S-38 S-12 S-14 S-17 S-19HS-2 S-21 B-6AS32 S-87 S-11 S23 HS-5 HS-3 RB-4 S-20S33 R2 S-91 S-5 HS-4 MW-11 B-11A TP-3 R1 S-6 S-92 S-10 S1 R7 S39 GP-26 S-7 S3 S2 S-13 TP-1 R8 R5 WRS-9 S-59 HS-7 RB-1 R6 R4 R34 R17 R13 R11 TP-2R9 RB-2 WRS-94 WRS-47 WRS-87 S-4 S4 S-8 S-9 WRS-10 R3 WRS-54 R33 B-4BMW-3 S6 S-1 S-36 S-37 MW-7B-1F WRS-13 R15 R12 R10 WRS-11 R35 S-57 MW-10 R14 WRS-55-DUP S5 S-3 R19 R16 WRS-12 WRS-93 R36 S-58 S-33 S-90 R21 R50 WRS-76 V-3 R18 WRS-72 WRS-75 WRS-95 WRS-82 S-60 MW-8 R23 R20 WRS-81 WRS-55 R37 R25 WRS-14 WRS-40WRS-86 S-35 B-2B R22 WRS-97 WRS-56-DUP R38 MW-9 S-2 R27 R24 WRS-92 WRS-21 R49 R26 WRS-15WRS-96 WRS-20 R39 B-8A S38 R40 S19 R28 WRS-16 WRS-37 WRS-56 R42 R46 R29 WRS-49 WRS-78 WRS-57 R41 R44 WRS-83 WRS-85 R43 R45 R32 R31 R30 WRS-6 WRS-73 R47 R48 WRS-90 WRS-58 T WRS-2 WRS-91 WRS-4 WRS-80 WRS-22 WRS-19 WRS-5 WRS-18 WRS-3 WRS-59 WRS-88 WRS-77 WRS-48 WRS-17 WRS-89 WRS-79 WRS-8 WRS-34 WRS-84 WRS-60 WRS-69 WRS-7 WRS-31 WRS-50 WRS-63 WRS-68 WRS-74 WRS-61 WRS-66 Print Date:12/14/2017 WRS-25 WRS-64 WRS-70 WRS-71 WRS-38 WRS-62 WRS-28 WRS-51 WRS-23 WRS-67 WRS-65

Source: Aerial photograph obtained from ESRI, Inc. ArcGIS Online/Bing Maps Legend Figure 3 Approved By: L. Ovelar Sample Location within Hot Spot Top of Bank 2011 (Divides Zidell Property Boundary RI Sample Locations Removal Areas (Removed) 2010 & 2011 Excavation Work) NOT FOR CONSTRUCTION Former Property Areas Site Management Plan Sample Location ROD Greenway Extent ZRZ Realty Company Area Boundary Portland, Oregon Produced By: Padilla

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This product is for informational purposes and may not have been prepared for, or be suitable Note: All identified otspot soils for legal, engineering, or surveying purposes. Users of this information should review or consult the primary data and information sources to ascertain the usability of the information. have been removed. Feet Project: 8014.01.32/06CG Figure 4 I-5 FREEWAY Remediation Areas Site Management Plan ZRZ Realty Company Portland, Oregon

NOT FOR CONSTRUCTION

SW GROVER ST ZRZ Realty Company SW BOND AVE SW RIVER PKWY File: X:\8014.01 ZRZ Realty Company\32\Projects\06\Fig1-2_SiteBoundaries.mxd TLID 1S1E10-00400 Legend SW MOODY AVE Current Top of Bank ROD Greenway Boundary

SW CURRY ST Interior Site Area SW RIVER PKWY Upland ROD Greenway Area

SW WHITAKER ST Bank Area ZRZ Realty Company Sediment Cap Area TLID 1S1E10AC -00200 SW HALL ST OHSU Zidell Property Boundary (Formerly referenced TLID 1S1E10 -00200 as Tax Lot 42)

ZRZ Realty Company

29+00

28+00

27+00

TLID 1S1E10 -00300 26+00

25+00

24+00 (Formerly referenced 23+00 22+00

21+00

20+00 as Tax Lot 1) 19+00 18+00

17+00

16+00

15+00

-1+00 14+00

13+00 0-00

12+00

1+00 11+00

2+00 10+00

3+00

9+00 Ross Island Bridge Right of Way (ODOT) 4+00 8+00

5+00

6+00

7+00 Notes: 1. The location, configuration and size of the greenway area will ultimately be determined by MARQUAM BRIDGE Zidell's redevelopment plans. The greenway is shown to be 100 feet from the 2002 top of bank, consistent with assumptions used in the Feasibility Study, ROD and Consent Judgment. Tilikum Crossing (TriMet) However, because redevelopment plans for the

Print Date: 03/02/2012 site have not been finalized, the configuration of the greenway areas may change.

0 150 300 Approvedby: L. Ovelar

ROSS ISLAND BRIDGE Feet Willamette River Source: Aerial photograph (2011) obtained from ESRI, Inc. ArcGIS Online/Bing Maps; property boundary and upland bridge support locations surveyed by Olson Engineering (December 2007); tax lot data (2009) obtained from Metro Data Resource Center Producedby: HinesA. /Padilla

p. 971 544 2139 | www.maulfoster.com

This product is for informational purposes and may not have been prepared for, or be suitable for legal, engineering, or surveying purposes. Users of this information should review or consult the primary data and information sources to ascertain the usability of the information. Project: 8014.01.32/06CG Path: X:\8014.01 ZRZRealty Company\61\Fig2-2_Proposed Bank andSediment Cap.mxd

Vegetation to 11 FT

Vegetation to 15 FT

Slipway Reach Downstream Reach

Bridge Reach Print Date:12/15/2017

Source: Aerial photograph obtained from ESRI, Approved By:A.Clary Inc. ArcGIS Online/Bing Maps Legend Figure 5 Notes: Top of Bank Riverbank Cap Material Sediment Cap Material Upland Cap Material Upland and In-Water Caps SWH = Shallow Water Habitat Vegetation Area Habitat Gravel Over Armor Steel Decking OHW = Ordinary High Water 100-foot Greenway Setback Site Management Plan Proposed SWH (-17 ft COP) Bank Fill & Vegetated Soil Cap Type B Armor Concrete ZRZ Realty Company Proposed OHW (18 ft COP) Bank Cut & Vegetated Soil Cap Type C Armor Asphalt Cap Portland, Oregon Produced By: rroberts Low Profile Cap Boundary Armor Repair Area Type D Armor Soil Cap (2' min) Armored Sand Cap Boundary Steel Plates Type E Armor Gravel Cap (2' min)

!!!!!!!!!!!!

p. 360 694 2691 | www.maulfoster.com !!!!!!!!!!!! !!!!!!!!!!!! 0 125 250

!!!!!!!!!!!!

!!!!!!!!!!!!

!!!!!!!!!!!!

!!!!!!!!!!!! Gravel Thin Cap

Zidell Property Boundary !!!!!!!!!!!! This product is for informational purposes and may not have been prepared for, or be suitable for legal, engineering, or surveying purposes. Users of this information should review or consult the primary data and information sources to ascertain the usability of the information. Feet Project: 8014.01.32/04