HAHN AND ASSOCIATES, INC. ENVIRONMENTAL CONSULTANTS

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1 HAHN AND ASSOCIATES, INC. ENVIRONMENTAL CONSULTANTS DATE: November 11, 2015 MEMORANDUM TO: Mike Greenberg Oregon Department of Environmental Quality Northwest Region Emergency Response Program 700 NE Multnomah Street, Suite 600 Portland, Oregon FROM:Mr. Ben Uhl Inc. 434 NW 6 th Avenue, Suite 203 Portland, Oregon cc: Mr. Bob Wyatt, NW Natural Ms. Natalie Bower, NW Natural Mr. Wayne Pipes, NW Natural Mr. Kevin Buffum, Pacific Terminal Services, Inc. Ms. Patty Dost, Pearl Legal Group, PC Ms. Rachel Melissa, Pearl Legal Group, PC Ms. Sarah Riddle, Pearl Legal Group, PC Mr. Ben Hung, Anchor QEA, LLC Mr. Rob Ede,, Inc. Mr. Dana Bayuk, Oregon DEQ SUBJECT: Truck Fuel Rack Area Pipeline Leak Response, Pacific Terminal Services, Inc. Leasehold, NW Natural Gasco Property, 7900 NW Saint Helens Road, Portland, Oregon 1.0 INTRODUCTION, Inc. (HAI) has prepared this memorandum documenting activities relating to an underground petroleum pipeline leak at the truck rack area of the Pacific Terminal Services, Inc. (PacTerm) leasehold on the NW Natural Gasco property (Figures 1 and 2). The Gasco property is an Environmental Cleanup Site (ECSI Site ID No. 84) undergoing a Remedial Investigation (RI) and Feasibility Study (FS) in the Department of Environmental Quality (DEQ) Voluntary Cleanup Program (VCP). The truck fuel rack area on the PacTerm leasehold property is used for transferring petroleum between tanker trucks and the adjacent tank farm to the north, with three underground lines extending between these two features. Two additional lines also feed into the system to allow transfer of fuel from barge traffic at the existing dock and also from the PacTerm tank farm to the east (Figures 2 and 3). These two additional lines connect with above-ground portions of the pipeline at a location north of the truck rack area. The footprint of the truck rack concrete pad area is approximately 900 square feet with the three underground petroleum pipelines exiting the ground at the truck rack system to the south and at the edge of the tank farm containment basin to the north. The 434 NW 6th AVENUE, SUITE 203 PORTLAND, OREGON TEL FAX OR CCB #

2 Memorandum Spill Report No Pac-Term Spill Response Activities Page 2 of 6 November 11, 2015 underground portion of these pipelines extend approximately 35 feet between the truck rack and the northern tank farm at a depth of approximately 5 feet below ground surface (bgs). All three pipelines, when uncovered, were found to be of 6-inch diameter steel construction. Of the three truck rack lines, the southern pipeline is used to transfer No. 6 fuel oil between Tanks No. 1 and/or No. 3 and the truck rack; the center pipeline is used to transfer No. 5 fuel oil (also called PS-300) between Tank 7 and the truck rack; and the northern line is used to transfer distillates (Marine Gas Oil) between Tank 2 and the truck rack. Of these three lines, only the center line (No. 5 fuel oil) had reportedly been active in the recent past. This memorandum documents response activities related to a March 30, 2015 discovery of leakage associated with the fuel rack. 2.0 INITIAL RESPONSE ACTIONS AND REGULATORY AGENCY INTERFACE During a PacTerm employee evening shift walk on March 30, 2015 at approximately 4:55 PM, soft ground conditions and a dark oily stain were observed near the fuel rack at the location where the northern end of the No. 5 fuel oil pipeline (e.g., center pipeline) exits the ground. Upon digging into the soft soil adjacent to the center pipeline, and 6- inches into the gravel base layer, approximately 1-gallon of oil was observed pooling into the excavation (see photographs, Appendix A). On March 30, 2015, PacTerm immediately reported the pipeline release at 6:15 PM to the Oregon Emergency Response System with follow-up to Mr. Mike Greenberg of the Oregon DEQ Northwest Region Emergency Response Section. The incident was issued Spill Report Number (Appendix B). The No. 5 fuel oil pipeline was isolated and vacated by PacTerm shortly after discovery of the leak. NRC International Services, Ltd (NRC) was dispatched to the site on the date of the discovery and worked overnight on behalf of PacTerm to vacuum excavate free product and petroleum-contaminated soils surrounding the pipeline in effort to expose the pipeline for identification of the point of leakage. NRC s excavation began at the point of discovery (northern end where the oil encroached the surface) and worked south toward the truck rack in an effort to identify the location of the leak. Excavated oily soil (fill sand) was transported via vacuum excavation truck to Waste Management s Hillsboro Landfill under generic PacTerm Permit No OR, dated September 3, This generic permit (Appendix C) addresses disposal of cleanup / spill residue derived from releases of PacTerm product. Documentation of the disposal of recovered oil and of initial soils transported to the landfill under Permit No OR are included in Appendix C. Mr. Mike Greenberg, DEQ Northwest Region Emergency Response Program Coordinator, visited the site on March 31, 2015 to observe the initial response and to meet with PacTerm representatives. During the visit, DEQ indicated satisfaction with the progress of the response and agreement with the path forward (excavation of soils to expose the pipeline). As per an April 2, (Mike Greenberg to Kevin Buffum), DEQ described the truck rack area as having been adequately stabilized with very little free product appearing to remain. In consultation with Mr. Dana Bayuk (DEQ Cleanup Program NOV PacTerm Pipeline Memo.docx HAHN AND ASSOCIATES, INC.

3 Memorandum Spill Report No Pac-Term Spill Response Activities Page 3 of 6 November 11, 2015 Project Manager for the RI/FS at the site), Mr. Greenberg indicated that due to the presence of previously characterized historical manufactured gas plant contamination at the property, there would be no need for verification soil sample collection as part of the release response. Instead, removal of accessible oily / odiferous soil as attributable to the pipeline release would be sufficient with removal to be based on visual indications instead of chemical testing. 3.0 CONTAMINATED SOIL REMOVAL AND DISPOSAL After the initial response action was completed with stabilization of the area as described above (complete by April 7, 2015), the open excavation was covered with plastic and monitored while logistical items relating to planned pipeline inspection and repair could be put into place. NRC resumed excavation activities on April 13, 2015 involving the removal of a portion of the concrete pad at the truck rack area to facilitate continued excavation / exposure of the failed pipeline. Overburden soils that exhibited no evidence of potential contamination (i.e., typically tan/brown hydraulically placed fill sands) were segregated from soils from around the pipeline that were stained with oil. All soils were placed drop boxes provided by West Coast Marine Cleaning, Inc., of Vancouver, Washington. On April 14, 2015, the location of the leak within the No. 5 fuel oil line was exposed, with the hole identified by the presence of escaping steam and pooled oil beneath the line at the leak (see photographs, Appendix A). Based on the observed staining along the pipeline trench it was concluded that the oil leakage had preferentially migrated along the exterior of the full length of the pipeline between the truck rack and where it exits the ground near the northern tank farm. The approximate leak location is depicted on Figure 3. Hand exploration conducted after exposing the line suggested that stained soils extended no more than approximately 1 to 2 feet beyond the exposed excavation sidewall. On April 17, 2015 NW Natural made the decision that all three pipelines feeding the truck rack would be exposed such that inspection and repair of the overall system could be completed. The project area was again covered and monitored while coordination efforts related to the necessary pipeline inspection and repair / replacement work were conducted. Because exposing all three pipelines would necessitate excavation of soils beyond those visually impacted by No. 5 fuel oil, it was determined that additional disposal profiling would be necessary to include constituents typical of manufactured gas plant (MGP) wastes. As such, on April 17, 2015, HAI collected a 5-part composite sample from the exposed trench within the truck rack area. This composite sample was deemed representative of those soils yet to be excavated, inclusive of soils beyond the limits of No. 5 fuel oil staining. None of the exposed soils exhibited the presence of MGPO residuals. The composite sample ( ) was submitted to, LLC (Apex) for analysis of: total cyanide (EPA 9013M/9014) total metals: arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver (EPA 6020) NOV PacTerm Pipeline Memo.docx HAHN AND ASSOCIATES, INC.

4 Memorandum Spill Report No Pac-Term Spill Response Activities Page 4 of 6 November 11, 2015 total petroleum hydrocarbons: diesel- and oil-range (NWTPH-Dx), and gasoline range (NWTPH-Gx) volatile organic compounds (EPA 8260B) polyaromatic hydrocarbons (EPA 8270D SIM) Analytical results for this testing are included in Appendix D and are summarized on Tables 1 and 2. Based on the analytical testing, it was concluded that soil generated during the repair project would be acceptable for disposal as petroleum-contaminated soil at a Resource Conservation and Recovery Act (RCRA) Subtitle D non-hazardous waste disposal facility. Upon landfill review and approval, a letter of approval (Permit No OR) was provided to NW Natural for soil disposal at the Waste Management, Inc. Hillsboro Landfill (Appendix C). On May 4, 2015, Harder Mechanical Contractors, Inc (Harder), of Portland, Oregon, removed additional surficial truck rack concrete, asphalt, and a storm water catch basin and continued excavating soils to expose the remaining two petroleum lines. Soil removal continued using an excavator, vacuum truck, and hand tools, and as previously conducted, stained soils were segregated from soils with no field screening evidence of impact (e.g., tan/brown fill sands). All three pipelines were fully exposed by May 5, Inspection and leak testing did not reveal the presence of leakage related to the northern or southern pipelines, although none of the three lines were found to contain proper cathodic protection. The completed excavation measured approximately 30 feet by 20 feet, with sloped sidewalls down to a maximum depth in the center of the excavation (middle pipeline) at approximately six feet bgs. The additional excavation work as necessary to expose all three pipelines resulted in the removal of all stained soils that were formerly present along the length of the middle (No. 5 fuel oil) pipeline, with the exception of a small pocket of stained soil located immediately beneath the truck rack where the center pipeline elbows toward the surface. The estimated extent of these inaccessible stained soils, estimated to be approximately 2.5 cubic yards in volume, are depicted on Figure 3. To document the quality of the remaining pocket of contaminated soil, on May 21, 2015 HAI collected a soil sample ( ) of the discolored soil for chemical testing identical to that completed for disposal profiling purposes (described above). Analytical results are summarized on Tables 1 and 2 and are included in Appendix D. During initial response activities performed by NRC, a total of tons of soil were disposed of at the Hillsboro Landfill (PacTerm Permit OR) as petroleumcontaminated soil. Additional excavating activities performed by Harder to expose the remaining pipelines for repair and pipeline repair generated an additional tons of soil that were disposed of at the Hillsboro landfill as petroleum-contaminated soil (NW Natural Permit OR). Soil disposal documentation for both initial response and pipeline repair activities is included within Appendix C. In addition to the soil disposal described above, 80 gallons of oily water, recovered over the course of the excavation and repair activities, were transported by Cowlitz Clean Sweep (CCS) of Portland, Oregon for re-refining at Oil Re-Refining Company, Inc. (ORRCO) in Portland, Oregon. Documentation of the transport of the oily water fro rerefining is included within Appendix C. NOV PacTerm Pipeline Memo.docx HAHN AND ASSOCIATES, INC.

5 Memorandum Spill Report No Pac-Term Spill Response Activities Page 5 of 6 November 11, PIPELINE REPAIR ACTIVITIES All pipeline repairs and installations were performed by Harder, under the direction of NW Natural. Pipeline repair activities commenced on May 12, 2015 with the re-wrapping of the northern diesel fuel line. This method was determined adequate for the ambient temperature diesel line, whereas the other lines that handle heated product were subsequently fitted with an epoxy coating capable of handling product at elevated temperatures. On May 13, 2015, removal of the No. 5 fuel oil center pipeline occurred, with the new replacement section welded into place on May 14, Upon installation, the new section of pipeline underwent x-ray and hydrostatic testing to verify a proper seal with no leaks. Magnesium anodes (cathodic protection) were placed on each of the three truck rack pipelines by NW Natural on May 15, The new section of pipeline and the southern No. 6 fuel oil pipeline were sandblasted and epoxy coated on May 26 and 27, Appendix A contains photographs of the full extent of the exposed pipelines, as well as of the completed repairs. 5.0 BACKFILL AND SITE RESTORATION In correspondence dated May 5, 2015 (Mike Greenberg to Kevin Buffum), the DEQ Emergency Response Program provided concurrence of the acceptability to use excavated soils with no field screening evidence of impact for use as backfill within the excavation from where they were derived. Mr. Dana Bayuk, in a telephone conversation with Mr. Rob Ede of HAI on May 4, 2015 similarly indicated DEQ approval with re-use of segregated soils within the excavation from which they came. Harder conducted backfill activities in the truck rack excavation on May 28 and 29, 2015, using 26 cubic yards of clean imported washed silica sand at the base of the excavation, above which 27 cubic yards of segregated soil with no visual evidence of contamination was placed. Imported ¾-inch minus aggregate was placed above the soil backfill, upon which a grade and framing was set for the concrete truck pad installation. On June 2, 2015, Harder poured concrete and completed leveling the new concrete truck pad. Photographs depicting the backfilling of the excavation are included in Appendix A. At the time of this writing, and with the completion of all repair and restoration activities as described herein, the truck rack has been returned to full functionality. NOV PacTerm Pipeline Memo.docx HAHN AND ASSOCIATES, INC.

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7 TABLES HAHN AND ASSOCIATES, INC.

8 Table 1 - Summary of Soil Testing Results for Removed and In-Place Soils: TPH, Metals, and VOCs PacTerm Leasehold Area Pipe Repair Activities NW Natural, Gasco Property Portland, Oregon PacTerm Leasehold Oil Pipeline Repair Activities: TPH and Metals in Soil Waste Sample Sample Sample Origin Analytical Data Generation Number Date mg/kg Area Total Petroleum Hydrocarbons Total Metals NW TPH-Gx NW TPH-Dx EPA Method 6020 Gasoline Diesel Oil Arsenic Barium Cadmium Chromium Lead Selenium Silver Mercury RCRA D-list Maximum Concentrations 1 => NE NE NE 100 2, PacTerm Pipeline Repair Trench Apr-15 5-part Composite (Removed) 2 2, ,600. <2, <1.16 <0.232 < PacTerm Pipeline Repair Trench May-15 Grab (In-place) 3 1, , ,500. < <1.09 < <10.9 <1.09 <0.435 PacTerm Leasehold Oil Pipeline Repair Activities: VOCs in Soil Waste Sample Sample Sample Origin Analytical Data Generation Number Date mg/kg Area VOCs Total Cyanide Benzene Toluene Ethylbenzene Xylenes n-butylbenzene sec-butylbenzene n-propylbenzene Naphthalene EPA Method 8260B 1,2,4- Trimethylbenzene 1,3,5- Trimethylbenzene Trichloroethene cis 1,2-DCE trans 1,2-DCE 1,1-DCE Vinyl Chloride All Others EPA Method 9013M/9014 RCRA D-list Maximum Concentrations 1 => 10 NE NE NE NE NE NE NE NE NE 10 NE NE NE PacTerm Pipeline Repair Trench Apr-15 5-part Composite (Removed) < <1.090 <1.090 <1.090 <1.090 <1.090 ND <0.111 PacTerm Pipeline Repair Trench May-15 Grab (In-place) <1.060 < <4.26 < <2.13 <2.13 <2.13 <2.13 <2.13 <0.103 Notes: 1 = Toxicity Characteristic Leaching Procedure Regulatory Levels (40 CFR ), multiplied by a factor of 20 to account for attenuation 2 = Soil was removed and disposed during excavation activities 3 = Soil sample collected to document concentrations of left in-place soil DCE = dichloroethene EPA = U.S. Environmental Protection Agency mg/kg = milligrams/kilogram ND = not detected above method reporting level NE = not established NW = Northwest Method TPH = total petroleum hydrocarbons VOCs = volatile organic compounds Updated: 8/21/15, Inc. File Name: PacTerm Pipe Repair Soil IDW_Tables.xls Page 1 of 1

9 Table 2 - Summary of Soil Testing Results for Removed and In-Place Soils: PAHs PacTerm Leasehold Area Pipe Repair Activities NW Natural, Gasco Property Portland, Oregon Laboratory Testing Results (mg/kg) Sample Location ==> PacTerm Pipeline Repair Trench Sample Number ==> Sample Date ==> 17-Apr May-15 Analyte Sample Origin ==> RCRA D-list Maximum Concentrations 1 5-part Composite (Removed) 2 Grab (In-place) 3 Acenaphthene NE Acenaphthylene NE 4.7 <3.2 Anthracene NE Benz[a]anthracene NE Benzo[a]pyrene NE Benzo[b+k]fluoranthene NE Benzo(g,h,i)perylene NE Carbazole NE 6.73 <2.91 Chrysene NE Dibenz[a,h]anthracene NE Dibenzofuran NE Fluoranthene NE Fluorene NE Indeno[1,2,3-cd]pyrene NE Methylnaphthalene NE Methylnaphthalene NE Naphthalene NE Phenanthrene NE Pyrene NE Notes: 1 = Toxicity Characteristic Leaching Procedure Regulatory Levels (40 CFR ), multiplied by a factor of 20 to account for attenuation 2 = Soil was removed and disposed during excavation activities 3 = Soil sample collected to document concentrations of left in-place soil EPA = U.S. Environmental Protection Agency mg/kg = milligrams per kilogram NE = not established PAHs = polynuclear aromatic hydrocarbons Updated By: BAU PacTerm Pipeline Repair 8/21/15 PacTerm Pipe Repair Soil IDW_Tables.xls HAHN AND ASSOCIATES, INC.

10 FIGURES HAHN AND ASSOCIATES, INC.

11 Subject Property Gasco Siltronic 0.5-Mile Radius Note: Base Map from the Portland (1990), Oregon, and Linnton (1990) USGS 7.5-Minute Quadrangles Contour Interval: 10 Feet FIGURE 1 Location Map NW Natural Gasco Property Pacific Terminal Services, Inc NW St. Helens Road Portland, Oregon NORTH 0 1=2000' Scale in Feet HAHN AND ASSOCIATES, INC. Project No July 2015

12 NORTH Truck Rack Area (Figure 3) LEGEND 0 Approximate Pacific Terminal Services Operational Area 1=200' Scale in Feet FIGURE 2 Site Map NW Natural Gasco Property Pacific Terminal Services, Inc NW Saint Helens Road Portland, Oregon HAHN AND ASSOCIATES, INC. Project No September 2015

13 To Tank Farm NORTH Above Ground Pipelines X X Below Ground Pipelines Driveway Compromised Section of Oil Pipeline (Repaired) X Driveway X X 3.0' bgs 1=10' Scale in Feet Petroleum Pipeline X bgs Soil Sample Location (In-place) Discrete Soil Sample Location for 5-part Composite Sample (Removed) below ground surface mg/kg milligrams per kilogram

14 Appendix A Photographs HAHN AND ASSOCIATES, INC.

15 Photograph No. 1 Date Taken: April 9, 2015 Direction Facing: Northeast diesel fuel line #5 fuel oil line #6 fuel oil line Comments: Truck rack station at top of photo showing northern diesel fuel pipeline, center #5 fuel oil pipeline, and southern #6 fuel oil pipeline. Observe ponded oil at bottom of photo where initial leak was discovered. Photograph No. 2 Date Taken: April 9, 2015 Direction Facing: North Comments: View of ponded oil surrounding #5 fuel oil center pipeline. An approximate 6-inch excavation was installed surrounding the pipeline. HAHN AND ASSOCIATES, INC. 434 NW 6th Avenue, Suite 203 Portland, Oregon Appendix A Site Photographs Fuel Rack Area Pipeline Leak Response PacTerm Leasehold - NW Natural Gasco Property 7900 NW Saint Helens Road Portland, Oregon Project No August 2015

16 Photo No. 3 Photo No. 4 Photo No. 5 Photograph Nos. 3 and 4 Date: April 16 and 17, 2015 Direction Facing: Northwest and northeast, respectively Bucket Comments: View of exposed #5 fuel oil center pipeline. Note black stained soil and oil on excavation floor beneath pipeline. Photograph No. 5 Date: April 17, 2015 Direction Facing: South Comments: View of exposed #5 fuel oil center pipeline. Note black bucket placed under leaking section of pipeline. HAHN AND ASSOCIATES, INC. 434 NW 6th Avenue, Suite 203 Portland, Oregon Appendix A Site Photographs Fuel Rack Area Pipeline Leak Response PacTerm Leasehold - NW Natural Gasco Property 7900 NW Saint Helens Road Portland, Oregon Project No August 2015

17 Photograph No. 6 Date: May 4, 2015 Direction Facing: Northeast Comments: View of removed concrete truck pad and beginning to uncover all three petroleum lines. Photograph No. 7 Date: May 5, 2015 Direction Facing: South Comments: View of crews using hand tools and vacuum truck to remove black stained and odoriferous soils under #5 fuel oil center pipeline. HAHN AND ASSOCIATES, INC. 434 NW 6th Avenue, Suite 203 Portland, Oregon Appendix A Site Photographs Fuel Rack Area Pipeline Leak Response PacTerm Leasehold - NW Natural Gasco Property 7900 NW Saint Helens Road Portland, Oregon Project No August 2015

18 Photograph No. 8 Date: May 5, 2015 Direction Facing: North Comments: View all three pipelines prior to removal of the center line and retro fitting of northern and southern lines. Photograph No. 9 Date: May 5, 2015 Direction Facing: Northeast Comments: View all three pipelines prior to removal/replacement of the center line and retro fitting of northern and southern lines. HAHN AND ASSOCIATES, INC. 434 NW 6th Avenue, Suite 203 Portland, Oregon Appendix A Site Photographs Fuel Rack Area Pipeline Leak Response PacTerm Leasehold - NW Natural Gasco Property 7900 NW Saint Helens Road Portland, Oregon Project No August 2015

19 Soil Sample Photograph No. 10 Date: May 21, 2015 Direction Facing: Northeast Comments: View of estimated 2.5 yards of inaccessible petroleum-contaminated (stained) soil left in place under truck rack and soil sample location. Photograph No. 11 Date: May 26, 2015 diesel fuel line Direction Facing: Northeast Comments: View all three pipelines after repair activities. Note the southern (far left) and center pipelines were sandblasted and epoxy coated. The northern (far right) pipeline was re-wrapped. #6 fuel oil line #5 fuel oil line HAHN AND ASSOCIATES, INC. 434 NW 6th Avenue, Suite 203 Portland, Oregon Appendix A Site Photographs Fuel Rack Area Pipeline Leak Response PacTerm Leasehold - NW Natural Gasco Property 7900 NW Saint Helens Road Portland, Oregon Project No August 2015

20 Photograph No. 12 Date: May 29, 2015 Direction Facing: Southwest Comments: View of segregated overburden with no field screening evidence of contamination being used as backfill. Photograph No. 13 Date: June 1, 2015 Direction Facing: Southwest Comments: View of gravel backfill and concrete pad framing. HAHN AND ASSOCIATES, INC. 434 NW 6th Avenue, Suite 203 Portland, Oregon Appendix A Site Photographs Fuel Rack Area Pipeline Leak Response PacTerm Leasehold - NW Natural Gasco Property 7900 NW Saint Helens Road Portland, Oregon Project No August 2015

21 Photograph No. 14 Date: June 3, 2015 Direction Facing: North Comments: Crew completing smoothing of concrete truck pad restoration. Photograph No. 15 Date: July 15, 2015 Direction Facing: Southeast Comments: View of completed truck fuel rack concrete pad restoration. HAHN AND ASSOCIATES, INC. 434 NW 6th Avenue, Suite 203 Portland, Oregon Appendix A Site Photographs Fuel Rack Area Pipeline Leak Response PacTerm Leasehold - NW Natural Gasco Property 7900 NW Saint Helens Road Portland, Oregon Project No August 2015

22 Appendix B Oregon Emergency Response System Spill Report Documentation HAHN AND ASSOCIATES, INC.

23 Oregon Emergency Response System (OERS) Mailing Address: PO Box Salem, OR Nationwide: Local: Fax: (503) OERS Incident Number: Incident Type: CBT Received: 03/30/2015 at 1817Taken By: Bowyer, Occurred: 03/30/2015 at 1817 Carol Location: 7900 NW Saint Helens Road Coordination Time: City: County: Portland Multnomah Contact Type: Paged: Answered:Contact Name Organization: Phone Caller Comments Kevin Buffum Pager 1825 deq DEQ Comments Notification 1844 Kimberlee VanPattenDEQ Comments CBT DEQ Comments Other/Related 1844 NRC Environmental Other Comments General Manger Pacific Terminal Services Incident Description: Business reports 1 gal of Heavy Marine Oil seeping from underground pipe. Pipe is under excavation at this time to determine saturation amount to soil. NRC responding with vac truck and initiate clean up. Material: Unit Of Measure: Quantity Released: 1 Release Source: Potential for further spillage: Heavy Marine oil GAL FIX Unknown

24 Site secured for safety: Yes Threat to public waterways: Threat to public safety: Unknown Threat to property: Containment steps taken: None Unknown Yes

25 Appendix C Disposal Documentation HAHN AND ASSOCIATES, INC.

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27 Non-Hazardous WAM Approval Requested Management Facility: Hillsboro Landfill Profile Number: OR Waste Approval Expiration Date: 04/29/2016 APPROVAL DETAILS Approval Decision: Approved Not Approved Profile Renewal: Yes No Management Method: Alternate Daily Cover (ADC) Generator Name: NW Natural Material Name: Petroleum-contaminated soil Management Facility Precautions, Special Handling Procedures or Limitation on approval: Generator Conditions - Shall not contain free liquids. - Waste manifest or applicable shipping document must accompany load. - The waste profile number must appear on the shipping papers. WM Authorization Name: Kristin Castner Title: Waste Approval Manager WM Authorization Signature: Date: 04/29/2015 Agency Authorization (if Required): Date: QUESTIONS? CALL FOR ASSISTANCE Last Revised April 11, Waste Management

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34 Appendix D Laboratory Report and Chain-of-Custody Documentation Soil Samples HAHN AND ASSOCIATES, INC.

35 Laboratory Analytical Report Soil Samples (Removed and Disposed) HAHN AND ASSOCIATES, INC.

36 Monday, April 27, 2015 Rob Ede Portland, OR RE: Pacterm Pipe Repair / i Enclosed are the results of analyses for work order A5D0520, which was received by the laboratory on 4/17/2015 at 2:30:00PM. Thank you for using Apex Labs. We appreciate your business and strive to provide the highest quality services to the environmental industry. If you have any questions concerning this report or the services we offer, please feel free to contact me by at: pnerenberg@apex-labs.com, or by phone at Page 1 of 35

37 Project: Pacterm Pipe Repair Project Number: i 04/27/15 16:54 ANALYTICAL REPORT FOR SAMPLES SAMPLE INFORMATION Sample ID Laboratory ID Matrix Date Sampled Date Received A5D Soil 04/17/15 11:30 04/17/15 14:30 Page 2 of 35

38 Project: Pacterm Pipe Repair Project Number: i 04/27/15 16:54 ANALYTICAL SAMPLE RESULTS Diesel and Oil Hydrocarbons by NWTPH-Dx Analyte Result MDL Reporting Limit Units Dilution (A5D ) Matrix: Soil Batch: Diesel Date Analyzed mg/kg dry 50 04/24/15 00:40 Oil ND Surrogate: o-terphenyl (Surr) Recovery: % Limits: % Method NWTPH-Dx Notes F-13 S-01 Page 3 of 35

39 Project: Pacterm Pipe Repair Project Number: i 04/27/15 16:54 ANALYTICAL SAMPLE RESULTS Gasoline Range Hydrocarbons (Benzene through Naphthalene) by NWTPH-Gx Analyte Result Reporting Limit Dilution (A5D RE1) Matrix: Soil Batch: MDL Units Date Analyzed Method Notes V-15 Gasoline Range Organics mg/kg dry /23/15 14:47 NWTPH-Gx (MS) Surrogate: 4-Bromofluorobenzene (Sur) Recovery: 100 % Limits: % 1 1,4-Difluorobenzene (Sur) 96 % Limits: % Page 4 of 35

40 Project: Pacterm Pipe Repair Project Number: i 04/27/15 16:54 ANALYTICAL SAMPLE RESULTS Volatile Organic Compounds by EPA 8260B Analyte Result MDL Reporting Limit Units Dilution (A5D RE1) Matrix: Soil Batch: Date Analyzed Acetone ND ug/kg dry /23/15 14:47 Benzene ND Bromobenzene ND Bromochloromethane ND Bromodichloromethane ND Bromoform ND Bromomethane ND Butanone (MEK) ND n-butylbenzene sec-butylbenzene tert-butylbenzene ND Carbon tetrachloride ND Chlorobenzene ND Chloroethane ND Chloroform ND Chloromethane ND Chlorotoluene ND Chlorotoluene ND ,2-Dibromo-3-chloropropane ND Dibromochloromethane ND ,2-Dibromoethane (EDB) ND Dibromomethane ND ,2-Dichlorobenzene ND ,3-Dichlorobenzene ND ,4-Dichlorobenzene ND Dichlorodifluoromethane ND ,1-Dichloroethane ND ,2-Dichloroethane (EDC) ND ,1-Dichloroethene ND cis-1,2-dichloroethene ND trans-1,2-dichloroethene ND ,2-Dichloropropane ND ,3-Dichloropropane ND ,2-Dichloropropane ND ,1-Dichloropropene ND Method 5035/8260B Notes M-02 V-15 Page 5 of 35

41 Project: Pacterm Pipe Repair Project Number: i 04/27/15 16:54 ANALYTICAL SAMPLE RESULTS Volatile Organic Compounds by EPA 8260B Analyte Result MDL Reporting Limit Units Dilution (A5D RE1) Matrix: Soil Batch: Date Analyzed cis-1,3-dichloropropene ND ug/kg dry 2000 trans-1,3-dichloropropene ND Ethylbenzene Hexachlorobutadiene ND Hexanone ND Isopropylbenzene ND Isopropyltoluene ND Methyl-2-pentanone (MiBK) ND Methyl tert-butyl ether (MTBE) ND Methylene chloride ND Naphthalene n-propylbenzene Styrene ND ,1,1,2-Tetrachloroethane ND ,1,2,2-Tetrachloroethane ND Tetrachloroethene (PCE) ND Toluene ,2,3-Trichlorobenzene ND ,2,4-Trichlorobenzene ND ,1,1-Trichloroethane ND ,1,2-Trichloroethane ND Trichloroethene (TCE) ND Trichlorofluoromethane ND ,2,3-Trichloropropane ND ,2,4-Trimethylbenzene 1,3,5-Trimethylbenzene Vinyl chloride ND m,p-xylene o-xylene Surrogate: Dibromofluoromethane (Surr) Recovery: 98 % Limits: % 1 1,4-Difluorobenzene (Surr) 100 % Limits: % Toluene-d8 (Surr) 101 % Limits: % 4-Bromofluorobenzene (Surr) 100 % Limits: % Method 5035/8260B Notes Q-31 V-15 Page 6 of 35

42 Project: Pacterm Pipe Repair Project Number: i 04/27/15 16:54 ANALYTICAL SAMPLE RESULTS Cyanide - Total (Non-aqueous) Analyte Result Reporting Limit Dilution (A5D ) Matrix: Soil Batch: MDL Units Date Analyzed Cyanide, Total ND mg/kg dry 1 04/23/15 13:49 Method EPA 9013M/9014 Notes Page 7 of 35

43 Project: Pacterm Pipe Repair Project Number: i 04/27/15 16:54 ANALYTICAL SAMPLE RESULTS Polyaromatic Hydrocarbons (PAHs) by EPA 8270D SIM Analyte Result Reporting Limit Dilution (A5D ) Matrix: Soil Batch: MDL Units Date Analyzed Method Notes Acenaphthene ug/kg dry 20 04/21/15 17:09 EPA 8270D (SIM) Acenaphthylene Anthracene Benz(a)anthracene Benzo(a)pyrene Benzo(b+k)fluoranthene(s) Q-26 Benzo(g,h,i)perylene Carbazole Chrysene Dibenz(a,h)anthracene Dibenzofuran Fluoranthene Fluorene Indeno(1,2,3-cd)pyrene Naphthalene Phenanthrene Pyrene Surrogate: 2-Fluorobiphenyl (Surr) Recovery: 137 % Limits: % p-terphenyl-d14 (Surr) 246 % Limits: % S-04 S-04 Page 8 of 35

44 Project: Pacterm Pipe Repair Project Number: i 04/27/15 16:54 ANALYTICAL SAMPLE RESULTS Polyaromatic Hydrocarbons (PAHs) by EPA 8270D SIM Analyte Result Reporting Limit Dilution (A5D RE1) Matrix: Soil Batch: MDL Units Date Analyzed Method Notes 1-Methylnaphthalene ug/kg dry /22/15 11:45 EPA 8270D (SIM) 2-Methylnaphthalene Page 9 of 35

45 Project: Pacterm Pipe Repair Project Number: i 04/27/15 16:54 ANALYTICAL SAMPLE RESULTS Total Metals by EPA 6020 (ICPMS) Analyte Result MDL Reporting Limit Units Dilution Date Analyzed Method Notes (A5D ) Matrix: Soil Batch: Arsenic Barium Cadmium Chromium Lead mg/kg dry 10 04/23/15 15:13 Mercury ND Selenium ND Silver ND EPA 6020A Page 10 of 35

46 Project: Pacterm Pipe Repair Project Number: i 04/27/15 16:54 ANALYTICAL SAMPLE RESULTS Percent Dry Weight Analyte Result MDL Reporting Limit Units Dilution (A5D ) Matrix: Soil Batch: Date Analyzed Method Notes % Solids % by Weight 1 04/22/15 09:54 EPA 8000C Page 11 of 35

47 Project: Pacterm Pipe Repair Project Number: i 04/27/15 16:54 QUALITY CONTROL (QC) SAMPLE RESULTS Diesel and Oil Hydrocarbons by NWTPH-Dx Reporting Analyte Result MDL Limit Units Dil. Spike Amount Source Result Limits RPD RPD Limit Notes Batch EPA 3546 (Fuels) Soil Blank ( BLK1) Prepared: 04/23/15 08:51 Analyzed: 04/23/15 22:41 NWTPH-Dx Diesel ND mg/kg wet Oil ND Surr: o-terphenyl (Surr) Recovery: 113 % Limits: % Dilution: 1x LCS ( BS1) Prepared: 04/23/15 08:51 Analyzed: 04/23/15 23:01 NWTPH-Dx Diesel mg/kg wet % Surr: o-terphenyl (Surr) Recovery: 106 % Limits: % Dilution: 1x Page 12 of 35

48 Project: Pacterm Pipe Repair Project Number: i 04/27/15 16:54 QUALITY CONTROL (QC) SAMPLE RESULTS Gasoline Range Hydrocarbons (Benzene through Naphthalene) by NWTPH-Gx Reporting Analyte Result MDL Limit Units Dil. Spike Amount Source Result Limits RPD RPD Limit Notes Batch EPA 5035A Soil Blank ( BLK1) Prepared: 04/22/15 08:30 Analyzed: 04/22/15 12:42 NWTPH-Gx (MS) Gasoline Range Organics ND mg/kg wet Surr: 4-Bromofluorobenzene (Sur) Recovery: 92 % Limits: % Dilution: 1x 1,4-Difluorobenzene (Sur) 94 % % LCS ( BS2) Prepared: 04/22/15 08:30 Analyzed: 04/22/15 12:15 NWTPH-Gx (MS) Gasoline Range Organics mg/kg wet % Surr: 4-Bromofluorobenzene (Sur) Recovery: 92 % Limits: % Dilution: 1x 1,4-Difluorobenzene (Sur) 95 % % Page 13 of 35

49 Project: Pacterm Pipe Repair Project Number: i 04/27/15 16:54 QUALITY CONTROL (QC) SAMPLE RESULTS Gasoline Range Hydrocarbons (Benzene through Naphthalene) by NWTPH-Gx Reporting Analyte Result MDL Limit Units Dil. Spike Amount Source Result Limits RPD RPD Limit Notes Batch EPA 5035A Soil Blank ( BLK1) Prepared: 04/23/15 09:00 Analyzed: 04/23/15 11:51 NWTPH-Gx (MS) Gasoline Range Organics ND mg/kg wet Surr: 4-Bromofluorobenzene (Sur) Recovery: 93 % Limits: % Dilution: 1x 1,4-Difluorobenzene (Sur) 94 % % LCS ( BS2) Prepared: 04/23/15 09:00 Analyzed: 04/23/15 11:24 NWTPH-Gx (MS) Gasoline Range Organics mg/kg wet % Surr: 4-Bromofluorobenzene (Sur) Recovery: 90 % Limits: % Dilution: 1x 1,4-Difluorobenzene (Sur) 93 % % Page 14 of 35

50 Project: Pacterm Pipe Repair Project Number: i 04/27/15 16:54 QUALITY CONTROL (QC) SAMPLE RESULTS Volatile Organic Compounds by EPA 8260B Reporting Analyte Result MDL Limit Units Dil. Spike Amount Source Result Limits RPD RPD Limit Notes Batch EPA 5035A Soil Blank ( BLK1) Prepared: 04/22/15 08:30 Analyzed: 04/22/15 12: /8260B Acetone ND ug/kg wet Benzene ND Bromobenzene ND Bromochloromethane ND Bromodichloromethane ND Bromoform ND Bromomethane ND Butanone (MEK) ND n-butylbenzene ND sec-butylbenzene ND tert-butylbenzene ND Carbon tetrachloride ND Chlorobenzene ND Chloroethane ND Chloroform ND Chloromethane ND Chlorotoluene ND Chlorotoluene ND ,2-Dibromo-3-chloroprop ND ane Dibromochloromethane ND ,2-Dibromoethane (EDB) ND Dibromomethane ND ,2-Dichlorobenzene ND ,3-Dichlorobenzene ND ,4-Dichlorobenzene ND Dichlorodifluoromethane ND ,1-Dichloroethane ND ,2-Dichloroethane (EDC) ND ,1-Dichloroethene ND Q-30 Page 15 of 35

51 Project: Pacterm Pipe Repair Project Number: i 04/27/15 16:54 QUALITY CONTROL (QC) SAMPLE RESULTS Volatile Organic Compounds by EPA 8260B Reporting Analyte Result MDL Limit Units Dil. Spike Amount Source Result Limits RPD RPD Limit Notes Batch EPA 5035A Soil Blank ( BLK1) Prepared: 04/22/15 08:30 Analyzed: 04/22/15 12:42 cis-1,2-dichloroethene ND ug/kg wet trans-1,2-dichloroethene ND ,2-Dichloropropane ND ,3-Dichloropropane ND ,2-Dichloropropane ND ,1-Dichloropropene ND cis-1,3-dichloropropene ND trans-1,3-dichloropropene ND Ethylbenzene ND Hexachlorobutadiene ND Hexanone ND Isopropylbenzene ND Isopropyltoluene ND Methyl-2-pentanone ND (MiBK) Methyl tert-butyl ether ND (MTBE) Methylene chloride ND Naphthalene ND n-propylbenzene ND Styrene ND ,1,1,2-Tetrachloroethane ND ,1,2,2-Tetrachloroethane ND Tetrachloroethene (PCE) ND Toluene ND ,2,3-Trichlorobenzene ND ,2,4-Trichlorobenzene ND ,1,1-Trichloroethane ND ,1,2-Trichloroethane ND Trichloroethene (TCE) ND Trichlorofluoromethane ND ,2,3-Trichloropropane ND Q-31 Page 16 of 35

52 Project: Pacterm Pipe Repair Project Number: i 04/27/15 16:54 QUALITY CONTROL (QC) SAMPLE RESULTS Volatile Organic Compounds by EPA 8260B Reporting Analyte Result MDL Limit Units Dil. Spike Amount Source Result Limits RPD RPD Limit Notes Batch EPA 5035A Soil Blank ( BLK1) Prepared: 04/22/15 08:30 Analyzed: 04/22/15 12:42 1,2,4-Trimethylbenzene ND ,3,5-Trimethylbenzene ND Vinyl chloride ND m,p-xylene ND o-xylene ND Surr: Dibromofluoromethane (Surr) Recovery: 97 % Limits: % Dilution: 1x 1,4-Difluorobenzene (Surr) 100 % % Toluene-d8 (Surr) 104 % % 4-Bromofluorobenzene (Surr) 105 % % LCS ( BS1) Prepared: 04/22/15 08:30 Analyzed: 04/22/15 11: /8260B Acetone ug/kg wet % Benzene Bromobenzene Bromochloromethane Bromodichloromethane Bromoform Bromomethane Butanone (MEK) n-butylbenzene sec-butylbenzene tert-butylbenzene Carbon tetrachloride Chlorobenzene Chloroethane Chloroform Chloromethane Chlorotoluene Chlorotoluene ,2-Dibromo-3-chloroprop ane Q-41 Page 17 of 35

53 Project: Pacterm Pipe Repair Project Number: i 04/27/15 16:54 QUALITY CONTROL (QC) SAMPLE RESULTS Volatile Organic Compounds by EPA 8260B Reporting Analyte Result MDL Limit Units Dil. Spike Amount Source Result Limits RPD RPD Limit Notes Batch EPA 5035A Soil LCS ( BS1) Prepared: 04/22/15 08:30 Analyzed: 04/22/15 11:48 Dibromochloromethane ug/kg wet ,2-Dibromoethane (EDB) Dibromomethane ,2-Dichlorobenzene ,3-Dichlorobenzene ,4-Dichlorobenzene Dichlorodifluoromethane ,1-Dichloroethane ,2-Dichloroethane (EDC) ,1-Dichloroethene cis-1,2-dichloroethene trans-1,2-dichloroethene ,2-Dichloropropane ,3-Dichloropropane ,2-Dichloropropane ,1-Dichloropropene cis-1,3-dichloropropene trans-1,3-dichloropropene Ethylbenzene Hexachlorobutadiene Hexanone Isopropylbenzene Isopropyltoluene Methyl-2-pentanone (MiBK) Methyl tert-butyl ether (MTBE) Methylene chloride Naphthalene n-propylbenzene Styrene ,1,1,2-Tetrachloroethane Q-30 Page 18 of 35

54 Project: Pacterm Pipe Repair Project Number: i 04/27/15 16:54 QUALITY CONTROL (QC) SAMPLE RESULTS Volatile Organic Compounds by EPA 8260B Reporting Analyte Result MDL Limit Units Dil. Spike Amount Source Result Limits RPD RPD Limit Notes Batch EPA 5035A Soil LCS ( BS1) Prepared: 04/22/15 08:30 Analyzed: 04/22/15 11:48 1,1,2,2-Tetrachloroethane Tetrachloroethene (PCE) Toluene ,2,3-Trichlorobenzene ,2,4-Trichlorobenzene ,1,1-Trichloroethane ,1,2-Trichloroethane Trichloroethene (TCE) Trichlorofluoromethane ,2,3-Trichloropropane ,2,4-Trimethylbenzene ,3,5-Trimethylbenzene Vinyl chloride m,p-xylene o-xylene Q-31 Surr: Dibromofluoromethane (Surr) Recovery: 95 % Limits: % Dilution: 1x 1,4-Difluorobenzene (Surr) 99 % % Toluene-d8 (Surr) 103 % % 4-Bromofluorobenzene (Surr) 104 % % Page 19 of 35

55 Project: Pacterm Pipe Repair Project Number: i 04/27/15 16:54 QUALITY CONTROL (QC) SAMPLE RESULTS Volatile Organic Compounds by EPA 8260B Reporting Analyte Result MDL Limit Units Dil. Spike Amount Source Result Limits RPD RPD Limit Notes Batch EPA 5035A Soil Blank ( BLK1) Prepared: 04/23/15 09:00 Analyzed: 04/23/15 11: /8260B Acetone ND ug/kg wet Benzene ND Bromobenzene ND Bromochloromethane ND Bromodichloromethane ND Bromoform ND Bromomethane ND Butanone (MEK) ND n-butylbenzene ND sec-butylbenzene ND tert-butylbenzene ND Carbon tetrachloride ND Chlorobenzene ND Chloroethane ND Chloroform ND Chloromethane ND Chlorotoluene ND Chlorotoluene ND ,2-Dibromo-3-chloroprop ND ane Dibromochloromethane ND ,2-Dibromoethane (EDB) ND Dibromomethane ND ,2-Dichlorobenzene ND ,3-Dichlorobenzene ND ,4-Dichlorobenzene ND Dichlorodifluoromethane ND ,1-Dichloroethane ND ,2-Dichloroethane (EDC) ND ,1-Dichloroethene ND Page 20 of 35

56 Project: Pacterm Pipe Repair Project Number: i 04/27/15 16:54 QUALITY CONTROL (QC) SAMPLE RESULTS Volatile Organic Compounds by EPA 8260B Reporting Analyte Result MDL Limit Units Dil. Spike Amount Source Result Limits RPD RPD Limit Notes Batch EPA 5035A Soil Blank ( BLK1) Prepared: 04/23/15 09:00 Analyzed: 04/23/15 11:51 cis-1,2-dichloroethene ND ug/kg wet trans-1,2-dichloroethene ND ,2-Dichloropropane ND ,3-Dichloropropane ND ,2-Dichloropropane ND ,1-Dichloropropene ND cis-1,3-dichloropropene ND trans-1,3-dichloropropene ND Ethylbenzene ND Hexachlorobutadiene ND Hexanone ND Isopropylbenzene ND Isopropyltoluene ND Methyl-2-pentanone ND (MiBK) Methyl tert-butyl ether ND (MTBE) Methylene chloride ND Naphthalene ND n-propylbenzene ND Styrene ND ,1,1,2-Tetrachloroethane ND ,1,2,2-Tetrachloroethane ND Tetrachloroethene (PCE) ND Toluene ND ,2,3-Trichlorobenzene ND ,2,4-Trichlorobenzene ND ,1,1-Trichloroethane ND ,1,2-Trichloroethane ND Trichloroethene (TCE) ND Trichlorofluoromethane ND ,2,3-Trichloropropane ND Q-31 Page 21 of 35