HUMAN HEALTH RISK ASSESSMENT

Transcription

1 HUMAN HEALTH RISK ASSESSMENT AMARGOSA PORTFOLIO NW 10 th Street Corvallis, Oregon January 29, 2015 Partner Project Number Prepared for: AMARGOSA PALMDALE INVESTMENTS, LLC 433 North Camden Drive, Suite 500 Beverly Hills, California 90210

2 TABLE OF CONTENTS 1.0 INTRODUCTION PHASE II SUBSURFACE INVESTIGATION VAPOR INTRUSION RISK-BASED EVALUATION... 5 Data Evaluation and Identification of COPCs... 5 Exposure Assessment and Toxicity Assessment... 5 Risk Characterization... 6 Risk Characterization for Carcinogens... 6 Risk Characterization for Noncarcinogens RISK ASSESSMENT RESULTS UNCERTAINTY ANALYSIS FINDINGS AND CONCLUSIONS SIGNATURES OF PARTICIPATING PROFESSIONALS REFERENCES Tables 1. Summary Statistics for VOCs in Sub-slab Soil Gas 2. Cancer Risk and Noncancer Health Hazard Estimates for Current and Future Commercial Worker from Volatile Organic Compounds in Sub-slab Soil Gas

3 Human Health Risk Assessment Amargosa Portfolio NW 10 th Street Corvallis, Oregon Partner Project Number January 29, 2015 Page INTRODUCTION This Human Health Risk Assessment (HHRA) report has been prepared to evaluate potential health risks to current and future receptors at the property located at NW 10 th Street in Corvallis, Oregon (the subject property). According to a Phase I Environmental Site Assessment (Phase I) Report dated October 23, 2014, prepared by Partner Engineering & Science, Inc. (Partner), the subject property consists of a 2.93-acre parcel of land located on the southwest corner of Northwest Beca Avenue and Northwest 10 th Street in a mixed commercial and residential area of Corvallis, Oregon (Partner, 2014). The subject property is developed with a multi-tenant retail center. According to the Partner Phase I ESA, one of the suites is occupied by a dry cleaning tenant, Campbell s Cleaners, who generated still bottoms from the percolation of tetrachloroethylene (PCE) from 1983 until 2002, when the facility switched to an aqueous-based solvent. A Phase II Subsurface Investigation (Phase II) was conducted at the subject property in 2013, which included soil gas and groundwater sampling (Johnson Consulting, 2013). Soil gas was sampled beneath the concrete floor of the southern portion of the main building in the Campbell s Cleaners tenant space. The samples were two locations where solvent-based dry cleaning equipment had been located between 1983 and PCE was detected in both samples at concentrations of 660 and 24,000 micrograms per cubic meter (µg/m 3 ); trichloroethylene (TCE) was detected at concentrations of 320 and 3,100 µg/m 3 ; cis- 1,2-dichloroethene (DCE) was detected at concentrations of 10,000 and 7,600 µg/m 3 ; and trans-1,2-dce was detected at concentrations of 290 and 120 µg/m 3. The report indicated that TCE, at a concentration of 3,100 µg/m 3, exceeded the applicable Oregon Department of Environmental Quality (ODEQ) Riskbased Concentration (RBC) for occupational exposure of 2,900 µg/m 3. The documented release of TCE at concentrations exceeding the ODEQ RBC is considered a recognized environmental condition.

4 Human Health Risk Assessment Amargosa Portfolio NW 10 th Street Corvallis, Oregon Partner Project Number January 29, 2015 Page PHASE II SUBSURFACE INVESTIGATION Partner subsequently conducted a Phase II to provisionally investigate the current concentrations of chlorinated solvents, particularly PCE and daughter compounds (TCE, cis-1,2- DCE, trans-1,2-dce, and vinyl chloride) in soil gas, soil, and/or groundwater as a consequence of a release or releases from the former usage of PCE in connection with the on-site dry cleaning operations. The scope of the Phase II Subsurface Investigation included the advancement of four borings (SB1 through SB4) for the collection of representative soil and groundwater samples and the installation of three sub-slab soil gas probes (SV1 through SV3) for the collection of representative soil gas samples. Borings SB1 through SB3 were advanced to the west-southwest exterior, south exterior, and north interior (and adjacent to a floor drain) of previous soil gas probe SS2, located adjacent to the southwest of the dry cleaning machine, respectively, where the peak PCE concentration was previously detected. Boring SB-4 was advanced adjacent to previous soil gas probe SS2. Sub-slab soil gas probe SV1 was proposed to be installed within the eastern interior of the suite along the sewer lateral; however, Partner was not provided access to this location. Alternatively, sub-slab soil gas probe SV1 was installed to the eastern exterior, along the sewer lateral. Sub-slab soil gas probes SV2 and SV3 were installed adjacent to previous soil gas sampling locations SS1 and SS2, respectively. Please see Figure 3 of the Phase II (Appendix A) for a map indicating boring locations. Soil, groundwater, and soil gas concentrations were compared to the applicable RBCs. RBCs are generic, risk-based chemical concentrations developed by the ODEQ for use in initial screening-level evaluations (ODEQ, 2012). RBCs combine human health toxicity values with standard exposure factors to estimate contaminant concentrations that are considered to be health protective of human health or the environment. RBCs have been developed for soil, groundwater, and soil gas for various endpoints, including direct-contact exposure pathways (e.g., via inhalation and/or ingestion of and/or dermal contact with impacted soil), protection of aquatic resources, and vapor intrusion to indoor air. RBCs are not legally enforceable standards, but rather are considered guidelines to determine if potential risks associated with encountered contamination may warrant further evaluation. Of the compounds detected in soil, soil samples SB4-S1-5 and SB4-S2-8 contained concentrations of PCE that exceeded the risk-based concentrations based on soil vapor intrusion into buildings (RBC si ) and risk-based concentrations based on soil leaching to groundwater (RBC sw ) and soil sample SB4-S1-5 contained a concentration of TCE exceeding the RBC sw. None of the remaining soil concentrations exceeded their respective RBCs. Of the compounds detected in groundwater, PCE, TCE, cis-1,2-dce, and vinyl chloride concentrations in groundwater sample SB3-W1 exceeded the risk-based concentrations based on ingestion and inhalation of tapwater (RBC tw ) and PCE and TCE concentrations in groundwater sample SB4-W1 exceeded the RBCtw. None of the remaining groundwater concentrations exceeded their respective RBCs.

5 Human Health Risk Assessment Amargosa Portfolio NW 10 th Street Corvallis, Oregon Partner Project Number January 29, 2015 Page 4 Of the compounds detected in soil gas, the TCE concentration in soil gas sample SV2 exceeded the RBC sv. None of the remaining soil gas concentrations exceeded their respective RBCs. Based on the Phase II, Partner recommended the performance of an Indoor Air Quality Survey and/or HHRA to assess the potential risk to subject property occupants as a result of the chlorinated solvent impacts. Partner subsequently was retained to conduct this HHRA.

6 Human Health Risk Assessment Amargosa Portfolio NW 10 th Street Corvallis, Oregon Partner Project Number January 29, 2015 Page VAPOR INTRUSION RISK-BASED EVALUATION This HHRA has been prepared in accordance with the ODEQ document Guidance for Assessing and Remediating Vapor Intrusion in Buildings, dated March 25, 2010 (ODEQ 2010). The document presents a framework for vapor intrusion investigations. Unlike prior guidance, which relied heavily on predictive models such as the Johnson & Ettinger (J&E) vapor intrusion model to determine RBCs for vapor intrusion from soil and groundwater, the ODEQ approach is an empirical approach based on information provided in the EPA national database of vapor intrusion sites (EPA, 2012). The framework of this HHRA consists of the following steps: (1) data evaluation and identification of chemicals of potential concern (COPCs); (2) exposure assessment; (3) toxicity assessment; and (4) risk characterization. These steps are discussed in the subsections below. Data Evaluation and Identification of COPCs The first step of the HHRA process consisted of reviewing and evaluating data and identifying COPCs in media at the subject property. As discussed previously, VOCs have been detected in soil, sub-slab soil gas, and groundwater samples collected at the subject property. For the purposes of this HHRA, only the soil gas data is used to quantitatively estimate risks. This is consistent with ODEQ guidance, which states that sub-slab vapor data have the strongest correlation to, and are the best predictor of, vapor intrusion into existing buildings. Based on an initial compilation of the sub-slab soil gas data from the Phase II, PCE, TCE, cis-1,2-dce, and trans-1,2-dce were identified as COPCs. Please see Table 1 for a summary of the detected VOCs in sub-slab soil gas. The entire data set is included in the Phase II (Attachment A). Exposure Assessment and Toxicity Assessment The exposure assessment identifies potential human receptors that could be exposed to site-related chemicals, as well as the routes, magnitudes, frequency, and duration of the potential exposures. The assessment includes a description of the exposure setting and land use, identification of individuals using the subject property or who may potentially use the subject property in the future (i.e., receptors ), identification of exposure pathways by which those receptors may come into contact with COPCs, and calculation of the chemical concentration at the point of exposure (i.e., the exposure point concentration [EPC]), and the daily intake rates associated with each exposure pathway. The toxicity assessment determines the relationship between the magnitude of exposure to a COPC and the nature and magnitude of adverse health effects that may result from such exposure. The toxicity assessment includes the hazard identification, which is the evaluation of available information regarding the potential for a COPC to cause cancer or adverse noncancer health effects to a receptor; and the doseresponse assessment, which estimates the relationship between the magnitude of exposure and the increased likelihood of cancer or adverse noncancer health effects.

7 Human Health Risk Assessment Amargosa Portfolio NW 10 th Street Corvallis, Oregon Partner Project Number January 29, 2015 Page 6 The ODEQ RBCs combine the exposure assessment and toxicity elements of the HHRA. RBCs for vapor intrusion have been developed for residential, urban residential, and occupational receptors. RBCs are calculated by applying a soil gas to indoor air attenuation factor (the fraction of the COPC in the subsurface assumed to migrate to indoor air) and combining with standard default, receptor-specific exposure parameters. Risk Characterization Risk characterization involves estimating the magnitude of the potential adverse health effects associated with the COPCs. It also involves making summary judgments about the nature of the human health threat to the defined receptor populations. The risk characterization combines the results of the dose-response assessment (toxicity assessment) and the exposure assessment to calculate cancer risks and noncancer health. Risk characterization is conducted separately for carcinogens and noncarcinogens, as outlined in the following sections. Risk Characterization for Carcinogens Risks are estimated as probabilities for COPCs to elicit a carcinogenic response. The excess lifetime cancer risk (ELCR) is the incremental increase in the probability of developing cancer associated with exposures to contaminated media at the subject property. A risk of , for example, represents the probability that one person in one million exposed to a carcinogen over a lifetime (70 years) will develop cancer. EPA (1991) provides guidance on the role of an HHRA in supporting risk management decisions, and in particular, whether remedial action is necessary at a site. Specifically, the guidance states Where cumulative carcinogenic site risk to an individual based on reasonable maximum exposure for bother current and future land use is less than 10-4, and the noncancer HQ is less than 1, action is generally not warranted unless there are adverse environmental impacts. Similarly, ODEQ outlines acceptable risk in its Human Health Risk Assessment Guidance (ODEQ, 2010b). According to ODEQ, the acceptable ELCR for individual carcinogens is , and the acceptable ELCR for exposure to multiple carcinogens is The acceptable noncancer hazard index is 1. Using RBCs, the equation used to calculate the ELCR from inhalation exposure to a volatile chemical is expressed as: where: Risk = EPC / RBC sv 10-6 EPC = exposure point concentration, based on the maximum detected concentration (µg/m 3 ) RBC sv = risk-based concentration based on the cancer endpoint (µg/m 3 ) Consistent with ODEQ guidance and based on the size of the sub-slab soil gas data set, the maximum detected concentrations of each COPC were used in the evaluation. To calculate the ELCR from inhalation exposure to multiple COPCs, the individual cancer risks are summed.

8 Human Health Risk Assessment Amargosa Portfolio NW 10 th Street Corvallis, Oregon Partner Project Number January 29, 2015 Page 7 Risk Characterization for Noncarcinogens For chemicals that are not classified as carcinogens and for those carcinogens known to cause adverse health effects other than cancer, the potential for exposure to result in adverse health effects other than cancer is evaluated by comparing the intake with an RfD or RfC. The ratio of this intake is termed the hazard quotient (HQ). The equation used to calculate the HQ from inhalation exposure to a volatile chemical is expressed as: HQ = EPC / RBC where: EC nc = exposure point concentration (µg/m 3 ) RBC sv = risk-based concentration based on the noncancer endpoint (µg/m 3 ) An HQ of one or less indicates no potential for adverse noncancer health effects. The hazard index (HI) for the receptor is the sum of the chemical-specific HQs.

9 Human Health Risk Assessment Amargosa Portfolio NW 10 th Street Corvallis, Oregon Partner Project Number January 29, 2015 Page RISK ASSESSMENT RESULTS This section discusses the results for cumulative cancer risks and noncancer adverse health effects to current and future commercial workers at NW 10 th Street in Corvallis, Oregon. As previously discussed, risks from VOCs in indoor air were estimated using sub-slab soil gas data from the Phase II Subsurface Investigation. The results of the HHRA are presented in Table 2. Consistent with EPA guidance, risk estimates are presented to one significant figure. Based on the results of the HHRA, and using the maximum detected sub-slab soil gas concentrations, the cumulative lifetime risk from exposure to residual chemicals in indoor air at the subject property was estimated to be for current and future commercial workers, and the hazard index does not exceed 1. TCE is the only COPC exceeding an individual cancer risk of , and contributes greater than 85 percent of the risk.

10 Human Health Risk Assessment Amargosa Portfolio NW 10 th Street Corvallis, Oregon Partner Project Number January 29, 2015 Page UNCERTAINTY ANALYSIS This section summarizes the uncertainties associated with the HHRA. Uncertainties associated with the HHRA fall into two general categories: (1) parameter uncertainty (uncertainty related to exposure variables) and (2) model uncertainty (uncertainty related to the methods and models used to calculate EPCs and risk). Some of the assumptions made in the risk assessment which may contribute to the overall uncertainty in the evaluation are briefly outlined below: Twenty five years of exposure are assumed for the current and future commercial worker. This may overestimate actual exposure because average exposure could be less than that assumed in the risk evaluation. The assumption that commercial workers will be employed at the same location for 25 years is a very conservative estimate. The toxicity assessment included human epidemiological studies in addition to animal studies. Because toxicity values are typically the most conservative values available, risks are more likely to be overestimated than underestimated.

11 Human Health Risk Assessment Amargosa Portfolio NW 10 th Street Corvallis, Oregon Partner Project Number January 29, 2015 Page FINDINGS AND CONCLUSIONS The objective of this report is to evaluate whether VOCs detected in subsurface media at the subject property result in unacceptable health risks to current and future occupants. Based on the assumptions and methodology outlined in this document, the following conclusions can be drawn: The cumulative lifetime cancer risk for commercial workers at the subject property, using the maximum detected sub-slab soil gas data collected from the subject property, is Based on ODEQ HHRA guidance, the individual cancer risk of TCE slightly exceeds the acceptable level of ; however, the cumulative cancer risk is considered acceptable. The noncancer hazard index does not exceed the acceptable level of 1. The ODEQ vapor intrusion guidance includes a decision tree to determine if vapor intrusion mitigation is required. ODEQ indicates that if sub-slab or soil gas concentrations exceed RBCs, indoor and ambient air sampling should be conducted, and the results of the indoor air sampling should be used to determine if additional investigation and/or mitigation is required. However, based on the slight exceedance of the RBCs, use of the maximum detected concentrations in the risk calculations, the health-protective assumptions inherent in development of the RBCs, and the acceptable cumulative risk based on ODEQ HHRA guidelines, VOCs in the subsurface do not appear to present a significant health risk to current receptors, and no further investigation of the subject property appears warranted at this time.

12 Human Health Risk Assessment Amargosa Portfolio NW 10 th Street Corvallis, Oregon Partner Project Number January 29, 2015 Page SIGNATURES OF PARTICIPATING PROFESSIONALS Thank you for the opportunity to be of service. If you have any questions regarding this investigation, please contact the undersigned at (415) Sincerely, Erik Brown Toxicologist

13 Human Health Risk Assessment Amargosa Portfolio NW 10 th Street Corvallis, Oregon Partner Project Number January 29, 2015 Page REFERENCES Johnson Consulting, Phase II Sampling Report, Environmental Site Assessment Review, May 12. Oregon Department of Environmental Quality (ODEQ), 2010a. Guidance for Assessing and Remediating Vapor Intrusion in Buildings, March 25. ODEQ, 2010b. Human Health Risk Assessment Guidance, October. ODEQ, Table of Risk-Based Concentrations, Updated June 7, Available online at: Partner Engineering & Science, Inc. (Partner), Phase I Environmental Site Assessment, Amargosa Portfolio, NW 10 th Street, Corvallis, Oregon, October 23. U.S. Environmental Protection Agency (EPA), Risk Assessment Guidance for Superfund (RAGS), Vol. I, Human Health Evaluation Manual, Part C, Risk Evaluation of Remedial Alternatives, Interim Final, Office of Emergency and Remedial Response, EPA 9285,7-01C. EPA, EPA s Vapor Intrusion Database: Evaluation and Characterization of Attenuation Factors for Chlorinated Volatile Organic Compounds in Residential Buildings, March 16. EPA, Regional Screening Values (RSLs), Updated November Available online at:

14 Appendix A Phase II Subsurface Investigation Report (January 14, 2015)

15 PHASE II SUBSURFACE INVESTIGATION REPORT Amargosa Portfolio NW 10th Street Corvallis, Oregon January 14, 2015 Partner Project Number: Prepared for: Amargosa Palmdale Investments, LLC 4330 North Camden Drive, Suite 500 Beverly Hills, California Engineers who understand your business

16 January 14, 2015 Mr. James Ginsburg Amargosa Palmdale Investments, LLC 4330 North Camden Drive, Suite 500 Beverly Hills, California Subject: Phase II Subsurface Investigation Report Amargosa Portfolio NW 10th Street Corvallis, Oregon Partner Project No Dear Mr. Ginsburg: The following letter report describes the field activities, methods, and findings of the Phase II Subsurface Investigation conducted by Partner Engineering and Science, Inc. (Partner) at the above-referenced property. The purpose of the investigation was to provisionally investigate the current concentrations of chlorinated solvents, particularly tetrachloroethene (PCE) and daughter compounds (trichloroethene [TCE], cis-1,2-dichloroethene [DCE], trans-1,2-dce, and vinyl chloride) in soil gas, soil, and/or groundwater as a consequence of a release or releases from the former usage of PCE in connection with the on-site dry cleaning operations. Amargosa Palmdale Investments, LLC provided project authorization through a signed copy of Partner Proposal Number P and Change Order P A. Site Description The subject property consists of a single parcel of land located at the southwest corner of Northwest Beca Avenue and Northwest 10 th Street within a mixed commercial and residential area of Corvallis, Oregon. The site is improved with two single-story commercial structures that total 34,527 square feet and were constructed in the mid-1950s and 1990s. In addition to the current structures, the subject property is also improved with asphalt-paved parking areas and landscaping. The subject property is currently occupied by Natural Grocers, The Arc thrift shop, Campbell s Laundry, and Campbell s Cleaners for commercial use. On-site operations consist of retail sales, a coin-operated laundry, and a dry cleaning operation. The equipment currently utilized in the dry cleaning operation uses aqueous-based cleaning products. The immediately surrounding properties consist of residences and offices to the north, across Northwest Beca Avenue; residences to the south; a photocopy shop and a restaurant to the east, across Northwest 9th Street; and residences to the west, across northwest 10 th Street. Please see Figure 1 for a site plan showing site features and surrounding properties. 111 Pine Street, Suite 1750, San Francisco, CA Phone Fax

17 Phase II Subsurface Investigation Report Amargosa Portfolio NW 10th Street Corvallis, Oregon Partner Project No January 14, 2015 Page 2 Site History The following recognized environmental condition (REC) was identified for the subject property: A dry cleaner has operated in the southern portion of the main building at the subject property since at least Although no spills or releases were reported in connection with this dry cleaner, records provided online by the Oregon Department of Environmental Quality (ODEQ) indicate that this facility generated still bottoms from the distillation of tetrachloroethene (PCE) from 1983 until 2002, when the facility, currently occupied by Campbell s Cleaners, switched to an aqueous-based cleaning agent. Chlorinated compounds including PCE, trichloroethene (TCE), and vinyl chloride were detected at concentrations of 1,040 parts per billion (ppb), 89.8 ppb, and 119 ppb, respectively, in a temporary groundwater monitoring well (designated TW-6) located due east of a former on-site gasoline station and approximately 300 feet northeast of the Campbell s Cleaners tenant space during a 2010 subsurface investigation. The source of the chlorinated solvents was speculated as originating from Campbell s Cleaners on the subject property. Johnson Consulting (JC) prepared a Phase II Summary Report dated May 12, 2013, which summarized the results of soil gas sampling and soil and groundwater sampling performed in April 2013 by another consultant. The cover letter of the report was addressed to the ODEQ Land Quality Division, Dry Cleaner Program Coordinator. Soil gas was sampled beneath the concrete floor of the southern portion of the main building in the Campbell s Cleaners tenant space. The samples were collected from two locations (SS1 and SS2) where solventbased dry cleaning equipment had been located between 1983 and PCE was detected in both samples at concentrations of 660 and 24,000 micrograms per cubic meter (ug/ m 3 ) within SS1 and SS2, respectively; TCE was detected at concentrations of 320 and 3,100 ug/m 3 within SS1 and SS2, respectively; cis-1,2-dichloroethene was detected at concentrations of 10,000 and 7,600 ug/m 3 within SS1 and SS2, respect ively; and t rans- 1,2- dichloroethene was detected at concentrations of 290 and 120 ug/m 3 within SS1 and SS2, respectively. The report indicated that TCE, at a concentration of 3,100 ug/m 3, exceeded the applicable Risk-Based Concentration (RBC) for vapor intrusion into buildings in an occupational setting (2,900 ug/ m 3 ). The concentrations of the remaining compounds were reported to be below the applicable RBCs for occupational inhalation. The report stated that the concentration of TCE, when averaged between both samples, did not exceed applicable Risk-based Concentrations for occupational inhalation. A hand auger soil boring was advanced adjacent east of the dry cleaning tenant space and soil samples were collected at depths of 9.25 and 12 feet below ground surface (bgs). Partner notes that these soil samples may have been saturated samples as groundwater was reported to be at a depth of approximately 8 feet bgs at the site. Neither PCE nor TCE were detected in soil above the analytical method detection limits of ppb. PCE was detected in groundwater at a concentration of 1.51 ppb; TCE, cis-1,2-dichloroethene (DCE), trans-1,2-dce, and vinyl chloride were not detected in groundwater. Based upon an evaluation of the results of the April 2013 subsurface investigation, no further assessment was recommended by Johnson Consultants. Partner contacted Mr. Joe Westersund of the ODEQ Drycleaner Program for further information concerning the JC report. Mr. Westersund stated that Campbell s Cleaners is a registered dry cleaning facility in the Drycleaner

18 Phase II Subsurface Investigation Report Amargosa Portfolio NW 10th Street Corvallis, Oregon Partner Project No January 14, 2015 Page 3 Program. Mr. Westersund stated that he has not received a copy of the April 2013 Phase II Sampling Report. M r. Westersund stated that he did not have the most recent compliance inspection results for Campbell s Cleaners readily available; however, they are not currently listed as a Dry Cleaner remediation site. Mr. Westersund stated that the Phase II report could be submitted for review by the ODEQ with a request for a letter of No Further Action (NFA). Review of the ODEQ Guidance for Assessing and Remediating Vapor Intrusion in Buildings, dated March 25, 2010 indicates the following in Section 4 Risk Based Evaluation: With respect to soil gas, because of the heterogeneities in subsurface media, variability between and potentially limited accessibility of soil vapor sampling locations, using site data to develop a mean concentration of soil vapor underlying an exposure unit can be difficult. Moreover, soil gas investigations sample a small fraction of the total volume of soil vapor underlying a building, leading to uncertainty in representativeness of the analytical results. Therefore, a statistical estimator of the mean is used, rather than the mean from the samples, to avoid underestimating the true mean concentration in the soil vapor. The exceedance of the RBC for TCE, as reported in April 2013, is considered to be a REC. Additionally, Partner is of the opinion that the April 2013 subsurface investigation is not sufficient to rule out a vapor intrusion concern at the subject property. Furthermore, Partner notes that groundwater sampling was not conducted in the presumed source area (adjacent to the dry cleaning machine). Geology and Hydrogeology Based on a review of the United States Geological Survey (USGS) Corvallis, Oregon Quadrangle topographic map (created 1986), the subject property is situated at an elevation approximately 225 feet above mean sea level, and the local topography is sloping gently to the west. Please see Figure 2 for a topographic map of the site vicinity. The subject property is situated within the Willamette Valley physiographic province of the State of Oregon. Located in the state's northwest, the valley is surrounded by mountain ranges to the east, west and south. The valley's floor is broad, flat and fertile because of floods at the end of the last glacial period. Located centrally inside the large alluvial-deposited soils of the Willamette River drainage basin, the valley spreads far from the river banks to both the east and west barrier ranges. The southern end of the valley is near the confluence of its Coast and Middle forks near Eugene, and the northern end is at the Willamette River's mouth on the Columbia River in Portland. Based on borings advanced during this investigation, the underlying subsurface consists predominantly of a mixture of silt (ML) and clay (CL) from the ground surface to approximately 15 feet below ground surface (bgs), underlain by silt and fine sand to at least 16 feet bgs. Static groundwater was encountered during this investigation between 3.9 and 10.9 feet bgs. Please see Appendix A for boring logs from this investigation.

19 Phase II Subsurface Investigation Report Amargosa Portfolio NW 10th Street Corvallis, Oregon Partner Project No January 14, 2015 Page 4 Subsurface Investigation Scope of Work Please see Table 1 for a summary of the borings, sampling schedule and laboratory analyses for this investigation. The scope of the Phase II Subsurface Investigation included the advancement of four borings (SB1 through SB4) for the collection of representative soil and groundwater samples and the installation of three sub-slab soil gas probes (SV1 through SV3) for the collection of representative soil gas samples. Field Activities Utility Clearance Partner notified Oregon Utility Notification Center (OUNC) to clear public utility lines as required by law at least 48 hours prior to drilling activities. OUNC issued ticket number for the project. Health and Safety Plan Partner reviewed the site-specific Health and Safety Plan with on-site personnel involved in the project prior to the commencement of drilling activities. Drilling Equipment On January 6, 2015, Partner subcontracted with Point Source Solutions (PSS) (State of Oregon CCB License Number ) to provide and operate drilling equipment. PSS, under t he direct ion of Part ner, advanced borings SB1 and SB2 with a truck-mounted direct-push Geoprobe 6600 drill rig and Borings SB3 and SB4 with a probe rod jack hammer and installed sub-slab soil gas probes using a rotary hammer hand drill. Drilling rods and sampling equipment were decontaminated between samples and borings to prevent cross-contamination. Boring/ Probe Locations Borings SB1 through SB3 were advanced to the west-southwest exterior, south exterior, and north interior (and adjacent to a floor drain) of previous soil gas probe SS2, located adjacent to the southwest of the dry cleaning machine, respectively, where the peak PCE concentration was detected. Boring SB-4 was advanced adjacent to previous soil gas probe SS2. Sub- slab soil gas probe SV1 was proposed t o be installed within the eastern interior of the suite along the sewer lateral; however, Partner was not provided access to this location. Alternatively, sub-slab soil gas probe SV1 was installed to the eastern exterior, along the sewer lateral. Sub-slab soil gas probes SV2 and SV3 were installed adjacent to previous soil gas sampling locations SS1 and SS2, respectively. Please see Figure 3 for a map indicating boring locations.

20 Phase II Subsurface Investigation Report Amargosa Portfolio NW 10th Street Corvallis, Oregon Partner Project No January 14, 2015 Page 5 Sampling Dept hs Boring SB1 was advanced to a terminal depth of 16 feet bgs, with a soil sample collected at 12 feet bgs. Boring SB2 was advanced to a terminal depth of 8 feet bgs, with a soil sample collected at 4 feet bgs. Boring SB3 was advanced to a terminal depth of 14 feet bgs, with a soil sample collected at 2 feet bgs. Boring SB4 was advanced to a terminal depth of 14 feet bgs, with soil samples collected at 5 and 8 feet bgs. Groundwater samples were also collected from temporary well points screened at 4-foot intervals set at the terminal depth of each boring. Soil gas samples were collect ed from just beneat h t he concrete slab from soil gas probes SV1 through SV3. Soil Sampling Met hodology Boring SB1 was unpaved. Boring B2 was overlain by asphalt and Borings SB3 and SB4 were overlain by concrete, which was penetrated using with a rotary hammer hand drill. Soil gas probe locations SV1 through SV3 were overlain by concrete, which was penetrated using a rotary hammer hand drill. Soil samples were collect ed using a 2- or 4- foot long by 2-inch diameter MacroCore sampler with a 2- or 4-foot long acetate liner, which was advanced by the probe rod jack hammer using 2- to 3-foot long by 1.5-inch diameter drill rods. The sampler was driven into the subsurface to allow undisturbed soil to enter the open MacroCore barrel and retrieved in 2- or 4-foot intervals to recover the soil-filled liners. A lengthwise section of each acetate liner was removed with a splitting tool to expose the soil. The soil column was visually inspected for discoloration, monitored for odors, and classified in accordance with the Unified Soil Classification System (USCS). Soil screened from 3 to 6 feet bgs from soil boring SB4 exhibited a solvent-like odor. Please refer to the boring logs in Appendix B for specific borings and depths where the solvent-like odor was observed. Soil dept hs select ed for laborat ory analysis was collect ed by transferring soil into a laboratory-supplied, 4- ounce, wide-mouth, unpreserved glass jar, which was sealed with a threaded, Teflon-lined lid. The jars were filled with soil to capacity to minimize headspace and reduce the potential for volatilization. The jars were labeled for identification and stored in an iced cooler. Groundwater Sampling Methodology After soil sampling to the terminal depth, a temporary monitoring well was installed within the drill rods by advancing the sampler fitted with an expendable steel point to the terminal depth and retracting the rods to expose a steel well screen. Groundwater samples were retrieved from each temporary monitoring well using a new section of 3/8- inch diameter polyethylene tubing fed through a peristaltic pump and conveyed into three hydrochloric acid-preserved volatile organics analysis (VOA) vials. Each vial was filled wit h no observable headspace or air bubbles to minimize the potential for volatilization, labeled for identification, and stored in an iced cooler.

21 Phase II Subsurface Investigation Report Amargosa Portfolio NW 10th Street Corvallis, Oregon Partner Project No January 14, 2015 Page 6 The temporary monitoring wells were removed from the boreholes and each boring was backfilled with hydrated bentonite chips and capped with concrete or asphalt patch to match surrounding ground cover after of sampling. Soil Gas Sampling Met hodology Each sub- slab soil gas probe, consist ing of a pre- fabricated stainless steel screen and casing, was manually inserted into a 1-inch diameter hole drilled within the concrete building slab using the rotary hammer hand drill. Sand was poured into the annulus to form a sand pack around the probe screen and approximately 2 inches of dry, granular bentonite was placed atop the sand pack. The annulus was backfilled with hydrated bentonite to the ground surface to form a seal and the barbed sampling end of the probe was fitted with a cap prior to sampling. Soil gas samples were collect ed using 1- lit er, stainless-steel, cylindrical SUMMA canisters. The sampling containers were provided by SunStar Laboratories (SunStar) in Lake Forest, California, which subjected each canister to a rigorous cleaning process using a combination of dilution, heat, and high vacuum. After cleaning, the canisters were batch-certified to be free of target contaminants to a specified reporting limit via gas chromatography/mass spectroscopy prior to delivery. Partner received the SUMMA canisters evacuated to approximately 30 inches of mercury. The SUMMA canisters were fitted with stainless-steel flow controllers, which Sunstar calibrated to maintain constant flow (approximately 0.1 liter per minute) for approximately 5-10 minutes of sampling time. Each probe was allowed t o equilibrat e for a minimum of 30 minut es aft er inst allat ion prior t o sampling. Tracer gas isopropanol was placed around each probe at the ground surface while sampling to detect ambient air intrusion. The sampling end of the tubing was fitted to the sampling canister and the port valve was opened, causing air to enter the sample container due to the pressure differential. Partner closed the valves after the canister was evacuated to approximately 4 to 5 inches of mercury and disconnected the canister from the tubing. Pertinent data (e.g., time, canister vacuum) was recorded at the start and end of sampling. The SUMMA canisters were labeled for identification prior to analysis. Boring/ Soil Gas Probe Abandonment Temporary monitoring wells and soil gas probes were removed from the subsurface and the boreholes were backfilled with hydrated bentonite chips following sampling activities. Boreholes advanced in improved areas were capped with concrete or asphalt patch to match existing ground cover after being backfilled. No significant amounts of derived wastes were generated during this investigation.

22 Phase II Subsurface Investigation Report Amargosa Portfolio NW 10th Street Corvallis, Oregon Partner Project No January 14, 2015 Page 7 Pertinent Regulatory Agency Guidance The regulatory guidance used by Partner as part of the Phase II Subsurface Investigat ion is present ed below. Risk- Based Concentrations Risk- Based Concentrations (RBCs) are generic, risk-based chemical concentrations developed by the ODEQ for use in initial screening-level evaluations. RBCs combine human health toxicity values with standard exposure factors to estimate contaminant concentrations that are considered to be health protective of human exposures over a lifetime through direct-contact exposure pathways (e.g., via inhalation and/or ingestion of and/ or dermal contact with impacted soil). RBCs are not legally enforceable standards, but rather are considered guidelines to determine if potential risks associated with encountered contamination may warrant further evaluation. Laboratory Analysis Partner collected five soil samples, four groundwater samples, and three soil gas samples on January 6, 2015, which were transported in an iced cooler under proper chain-of-custody protocol to Sunstar for analysis on January 7, Each soil and groundwater sample (five soil and four groundwater samples total) was analyzed for PCE and daughter compounds in accordance with EPA Method 8260B and each soil gas sample was analyzed for PCE and daughter compounds in accordance with EPA Method TO-15. Sunst ar report ed t he laborat ory analysis result s on January 9, Please see Tables 2 through 4 for a comparison of the soil, groundwater, and soil gas laboratory results and available occupational RBCs. Please see Appendix B for the full laboratory analysis reports, which include chain-of-custody and laboratory quality assurance/quality control (QA/ QC) documentation. Laboratory QA/QC data were within acceptable limits. Soil Sample Analyt ical Result s As indicated in Table 2, three of the five analyzed soil samples (SB3-S1-2, SB4-S1-5, and SB4-S2-8) contained detectable concentrations of PCE, TCE, and cis-1,2-dce. Groundwater Sample Analytical Results As indicated in Table 3, each of the analyzed groundwater samples contained detectable concentrations of PCE, TCE, cis-1,2-dce, trans-1,2-dce, and/or vinyl chloride. Soil Gas Sample Analyt ical Result s As indicated in Table 4, each of the analyzed soil gas samples contained detectable concentrations of PCE, TCE, cis-1,2-dce, and/or trans-1,2-dce.

23 Phase II Subsurface Investigation Report Amargosa Portfolio NW 10th Street Corvallis, Oregon Partner Project No January 14, 2015 Page 8 The tracer gas was detected in two of the soil gas samples, indicating a potential breach in the sampling train, which would cause introduction of ambient air into the sampling train. Therefore, the detected concentrations of target compounds may be an underestimation of actual conditions. Partner notes that the concentrations of isopropanol do not appear to be significantly elevated, and, based on the soil and groundwater analytical results, are not anticipated to significantly alter the findings of this investigation. Discussion Soil Result s Of the compounds detected in soil, soil samples SB4-S1-5 and SB4-S2-8 contained concentrations of PCE that exceeded the risk-based concentrations based on soil vapor intrusion into buildings (RBCsi) and riskbased concentrations based on soil leaching to groundwater (RBCSw) and soil sample SB4-S1-5 contained a concentration of TCE exceeding the RBCsw. None of the remaining soil concentrations exceeded their respective RBCs. Groundwater Results Of the compounds detected in groundwater, PCE, TCE, cis-1,2-dce, and vinyl chloride concentrations in groundwater sample SB3-W1 exceeded the risk-based concentrations based on ingestion and inhalation of tapwater (RBCtw) and PCE and TCE concentrations in groundwater sample SB4-W1 exceeded the RBCtw. None of the remaining groundwater concentrations exceeded their respective RBCs. Soil Gas Result s Of the compounds detected in soil gas, the TCE concentration in soil gas sample SV2 exceeded the RBCsv. None of the remaining soil gas concentrations exceeded their respective RBCs. Summary and Conclusions Partner conducted a Phase II Subsurface Investigation at the subject property to provisionally investigate the current concentrations of chlorinated solvents, particularly PCE and daughter compounds in soil gas, soil, and/or groundwater as a consequence of a release or releases from the former usage of PCE in connection with the on-site dry cleaning operations. The scope of the Phase II Subsurface Investigation included the advancement of four borings (SB1 through SB4) for the collection of representative soil and groundwater samples and the installation of three sub-slab soil gas probes (SV1 through SV3) for the collection of representative soil gas samples. Lithological material encountered during this investigation consisted of a mixture of silt (ML) and clay (CL) from the ground surface to approximately 15 feet below ground surface (bgs), underlain by silt and fine sand to at least 16 feet bgs. Static groundwater was encountered during this investigation between 3.9 and 10.9 feet bgs.

24 Phase II Subsurface Investigation Report Amargosa Portfolio NW 10th Street Corvallis, Oregon Partner Project No January 14, 2015 Page 9 Based on the field observations and analysis of soil, soil gas, and groundwater samples, it appears that a release or releases from the former on-site dry cleaning operations has impacted the subject property subsurface. Laboratory analytical results suggests that the source of impacts is from the dry cleaning machine as indicated in detections of target compounds in soil samples collected from boring SB4. PCE and TCE soil concentrations exceeded the RBCsw and RBCsi, which are based on soil leaching to groundwater and soil vapor intrusion into buildings, respectively. Groundwater analytical data suggests that, although target compounds exceeded the RBCtw, based on ingestion and inhalation of tapwater, Partner notes that the subject property is serviced by a municipal water supply, and therefore, this pathway is considered incomplete. None of the remaining groundwater RBCs (groundwat er volat ilizat ion t o out door air, groundwater vapor intrusion into buildings, and groundwater in excavation) were exceeded. Soil gas analyt ical dat a suggests t hat TCE in soil gas sample SV2, located adjacent to previous soil gas probes SS1, was detected at a concentration in exceedence of RBCsv, which is based on vapor intrusion into buildings. Based on the Subsurface Investigation, it appears that a vapor intrusion concern exists at the subject property. Partner recommends the performance of an Indoor Air Quality Survey and/ or Human Health Risk Assessment (HHRA) to assess the potential risk to subject property occupants as a result of the documented chlorinated solvent impacts. Limitations This Report presents a summary of work conducted by Partner. The work includes observations of site conditions encountered and the analytical results provided by an independent third party laboratory of samples collected during the course of the project. The number and location of samples were selected to provide the required information. However, it cannot be assumed that the limited available data are representative of subsurface conditions in areas not sampled. Conclusions and/ or recommendations are based on the observations, laboratory analyses, and the governing regulations. Conclusions and/or recommendations beyond those stated and reported herein should not be inferred from this document. Partner warrants that the environmental consulting services contained herein were accomplished in accordance with generally accepted practices in the environmental engineering, geology, and hydrogeology fields that existed at the time and location of work. No other warranties are implied or expressed. Reports, both verbal and written, as they pertain to the property located at NW 10 th Street in the City of Corvallis, Oregon, are for the sole use and benefit of Amargosa Palmdale Investments, LLC. This report has no other purpose and may not be relied upon by another person or entity without the written consent of Partner.

25 Phase II Subsurface Investigation Report Amargosa Portfolio NW 10th Street Corvallis, Oregon Partner Project No January 14, 2015 Page 10 Signatures of Participating Professionals Thank you for the opportunity to be of service. If you have questions regarding this investigation, please contact the undersigned at (310) Sincerely, Terri Men, CEM Senior Project M anager Gil Cobb, RG (Oregon G1440) Senior Reviewer Attachments: Tables Figures Appendices 1. Summary of Investigation Scope 2. Soil Sample PCE & Daughter Compounds Laboratory Results 3. Groundwater Sample PCE & Daughter Compounds Laboratory Results 4. Soil Gas Sample PCE & Daughter Compounds Laboratory Results 1. Site Plan 2. Topographic Map 3. Boring Locations A. Boring Logs B. Laboratory Reports

26 TABLES

27 Table 1: Summary of Investigation Scope Boring Identification Location Terminal Depth (feet bgs) Matrix Sampled Sampling Depths* (feet bgs) Target Contaminants SB1 West-Southwest Exterior of Previous Soil Gas Probe SS2 16 Soil Groundwater 10.9 PCE & Daughter Compounds SB2 South Exterior of Previous Soil Gas Probe SS2 8 Soil 4.00 Groundwater 3.9 PCE & Daughter Compounds SB3 North Interior of Previous Soil Gas Probe SS2 14 Soil 2.00 Groundwater 10.9 PCE & Daughter Compounds SB4 Adjacent to Previous Soil Gas Probe SS2 14 Soil 5, 8 Groundwater 10.8 PCE & Daughter Compounds SV1 Eastern Exterior of Dry Cleaning Suite, Along Sewer Lateral 0.5 Soil Gas 0.5 PCE & Daughter Compounds SV2 Adjacent to Previous Soil Gas Probe SS1 0.5 Soil Gas 0.5 PCE & Daughter Compounds SV3 Adjacent to Previous Soil Gas Probe SS2 0.5 Soil Gas 0.5 PCE & Daughter Compounds Notes: *Depths in bold analyzed for tetrachloroethene (PCE) and daughter compounds trichloroethene, cis-1,2-dichloroethene, trans-1,2- dichloroethene, and vinyl chloride in accordance with United States Environmental Protection Agency (EPA) Method 8260B (soil and groundwater) and/or TO-15 (soil gas). **Refusal encountered at the terminal depth bgs = below ground surface Phase II Subsurface Investigation Amargosa Portfolio NW 10th Street Corvallis, Oregon Partner Project No January 2015

28 Table 2: Soil Sample PCE Daughter Compounds Laboratory Results EPA Method Units PCE & Daughter Compounds via 8260B (mg/kg) Sample Tetrachloroethenethenethene Dichloro-ethene Trichloro- cis-1,2-dichloro- trans-1,2- Identification Vinyl chloride SB1-S1-12 < < < < < SB2-S1-4 < < < < < SB3-S < < SB4-S < < SB4-S < < RBCss ,000 9, RBCso NE 96 NE NE 89 RBCsi NE RBCsw Notes: PCE = tetrachloroethene EPA = United States Environmental Protection Agency RBCss = Risk-based concentrations based on soil ingestion, dermal contact, and inhalation RBCso = Risk-based concentrations based on soil volatilization to outdoor air RBCsi = Risk-based concentrations based on soil vapor intrusion into buildings RBCsw = Risk-based concentrations based on soil leaching to groundwater < = not detected above indicated laboratory Reporting Limit (RL) Concentrations highlighted in yellow exceeds one or more screening level. Phase II Subsurface Investigation Amargosa Portfolio NW 10th Street Corvallis, Oregon Partner Project No January 2015

29 Table 3: Groundwater Sample PCE Daughter Compounds Laboratory Results EPA Method Units PCE & Daughter Compounds via 8260B ( g/l) Sample Identification Tetrachloroethene Trichloro-ethene cis-1,2-dichloroethene trans-1,2- Dichloroethene Vinyl chloride Notes: SB1-W1 1.7 <1.0 <1.0 <1.0 <1.0 SB2-W1 1.9 < <1.0 <1.0 SB3-W1 28,000 2,600 2, SB4-W1 7, <1.0 RBCtw RBCwo NE 19,000 NE 1,800,000 6,800 RBCwi 32,000 3,300 NE 350, RBCwe 5, ,000 14,000 1,200 PCE = tetrachloroethene EPA = United States Environmental Protection Agency RBCtw = Risk-based concentrations based on ingestion and inhalation of tapwater RBCwo = Risk-based concentrations based on groundwater volatilization to outdoor air RBCwi = Risk-based concentrations based on groundwater vapor intrusion into buildings RBCwe = Risk-based concentrations based on groundwater in excavation < = not detected above indicated laboratory Reporting Limit (RL) NE = not established Concentrations highlighted in yellow exceeds one or more screening level. Phase II Subsurface Investigation Amargosa Portfolio NW 10th Street Corvallis, Oregon Partner Project No January 2015

30 Table 4: Soil Gas Sample PCE Daughter Compounds Laboratory Results EPA Method Units PCE & Daughter Compounds via TO-15 ( g/m 3 ) Sample Identification Tetrachloroethene Trichloroethene cis-1,2-dichloroethene trans-1,2- Dichloroethene Vinyl chloride Isopropyl alcohol Notes: SV1 12 < <4.0 < SV2 1,500 4,500 36,000 2,400 <2.6 <13 SV3 8,900 1,700 4,000 <4.0 < RBCsv 47,000 2,900 NE 260,000 2,800 NE PCE = tetrachloroethene g/m 3 = micrograms per cubic meter RBCsv = Risk-based concentration as based on vapor intrusion into buildings < = not detected above indicated laboratory Reporting Limit (PQL) NE = not established Phase II Subsurface Investigation Amargosa Portfolio NW 10th Street Corvallis, Oregon Partner Project No January 2015

31 FIGURES

32

33

34

35 APPENDIX A: BORING LOGS

36 Boring Number: SB1 Page 1 of 1 Location: West Southwest Exterior of Previous Soil Gas Probe SS2 Date Started: 1/6/2015 Site Address: NW 10th Street Date Completed: 1/6/2015 Corvallis, Oregon Depth to Groundwater: 10.9' Project Number: Field Technician: S. Cobb Drill Rig Type: Probe Rod Jack Hammer w/ Geoprobe Tooling Partner Engineering and Science Sampling Equipment: Macrocore Sampler 2154 Torrance Boulevard, Suite 200 Borehole Diameter: 2 inches Torrance, California Depth Sample PID USCS Description Notes 1 2 Unpaved 3 10% recovery rock stuck in drill shoe 4 ML Clayey silt, brown ML Clayey silt, tan CL Silty clay, light brown, damp 12 1 SB1 S SB1 W1 CL Silt/fine sand, light brown, wet Static 10.9' Groundwater screened from 12' to 16' bgs; boring 16' bgs

37 Boring Number: SB2 Page 1 of 1 Location: South Exterior of Previous Soil Gas Probe SS2 Date Started: 1/6/2015 Site Address: NW 10th Street Date Completed: 1/6/2015 Corvallis, Oregon Depth to Groundwater: 3.90' Project Number: Field Technician: S. Cobb Drill Rig Type: Probe Rod Jack Hammer w/ Geoprobe Tooling Partner Engineering and Science Sampling Equipment: Macrocore Sampler 2154 Torrance Boulevard, Suite 200 Borehole Diameter: 2 inches Torrance, California Depth Sample PID USCS Description Notes 1 Gravel base Asphalt cover 2 CL Clay with some silt, tan, stiff SB2 S1 4 5 CL Silty clay, light brown 6 SW Coarse sand with small gravel SB2 W1 ML 9 Clayey silt, light brown, damp Static 3.90 Groundwater screened from 4' to 8' bgs; boring 8' bgs

38 Boring Number: SB3 Page 1 of 1 Location: North Interior of Previous Soil Gas Probe SS2 Date Started: 1/6/2015 Site Address: NW 10th Street Date Completed: 1/6/2015 Corvallis, Oregon Depth to Groundwater: 10.9' Project Number: Field Technician: S. Cobb Drill Rig Type: Probe Rod Jack Hammer w/ Geoprobe Tooling Partner Engineering and Science Sampling Equipment: Macrocore Sampler 2154 Torrance Boulevard, Suite 200 Borehole Diameter: 2 inches Torrance, California Depth Sample PID USCS Description Notes 1 Gravel base Concrete cover 2 1 SB3 S1 2 ML 3 ML Clayey silt, brown Clayey silt, some gray staining 4 ML Clayey silt, light brown 5 6 ML Clayey silt, tan SB3 W1 15 Static 10.9' Groundwater screened from 10' to 14' bgs; boring 14' bgs

39 Boring Number: SB4 Page 1 of 1 Location: Adjacent to Previous Soil Gas Probe SS2 Date Started: 1/6/2015 Site Address: NW 10th Street Date Completed: 1/6/2015 Corvallis, Oregon Depth to Groundwater: 10.8' Project Number: Field Technician: S. Cobb Drill Rig Type: Probe Rod Jack Hammer w/ Geoprobe Tooling Partner Engineering and Science Sampling Equipment: Macrocore Sampler 2154 Torrance Boulevard, Suite 200 Borehole Diameter: 2 inches Torrance, California Depth Sample PID USCS Description Notes 1 Gravel base Concrete cover 2 ML Clayey silt, brown 3 4 Strong solvent odor Strong solvent odor 5 1 SB4 S1 5 6 Strong solvent odor SB4 S2 8 CL 9 Silty clay, light brown No odor 10 CL Silty clay, tan SB4 W Static 10.8' Groundwater screened from 10' to 14' bgs; boring 14' bgs

40 APPENDIX B: LABORATORY REPORTS

41 25712 Commercentre Drive Lake Forest, California Phone Fax 09 January 2015 Terri Men Partner Engineering & Science, Inc.--San Francisco 111 Pine St. Suite 1750 San Francisco, CA RE: Campbells Enclosed are the results of analyses for samples received by the laboratory on 01/08/15 10:50. If you have any questions concerning this report, please feel free to contact me. Sincerely, Daniel Chavez Project Manager

42 25712 Commercentre Drive Lake Forest, California Phone Fax Partner Engineering & Science, Inc.--San Francisco Project: Campbells 111 Pine St. Suite 1750 Project Number: San Francisco CA, Project Manager: Terri Men Reported: 01/09/15 16:37 ANALYTICAL REPORT FOR SAMPLES Sample ID Laboratory ID Matrix Date Sampled Date Received SB1-S1-12 T Soil 01/06/15 01:09 01/08/15 10:50 SB1-W1 T Water 01/06/15 01:47 01/08/15 10:50 SB2-S1-4 T Soil 01/06/15 02:35 01/08/15 10:50 SB2-W1 T Water 01/06/15 02:47 01/08/15 10:50 SB3-S1-2 T Soil 01/06/15 06:22 01/08/15 10:50 SB3-W1 T Water 01/06/15 08:47 01/08/15 10:50 SB4-S1-5 T Soil 01/06/15 09:50 01/08/15 10:50 SB4-S2-8 T Soil 01/06/15 10:05 01/08/15 10:50 SB4-W1 T Water 01/06/15 11:02 01/08/15 10:50 The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Daniel Chavez, Project Manager Page 1 of 15

43 25712 Commercentre Drive Lake Forest, California Phone Fax Partner Engineering & Science, Inc.--San Francisco Project: Campbells 111 Pine St. Suite 1750 Project Number: San Francisco CA, Project Manager: Terri Men Reported: 01/09/15 16:37 DETECTIONS SUMMARY Sample ID: SB1-S1-12 Laboratory ID: T No Results Detected Sample ID: SB1-W1 Laboratory ID: T Reporting Analyte Result Limit Units Method Tetrachloroethene ug/l EPA 8260B Notes Sample ID: SB2-S1-4 Laboratory ID: T No Results Detected Sample ID: SB2-W1 Laboratory ID: T Reporting Analyte Result Limit Units Method cis-1,2-dichloroethene ug/l EPA 8260B Tetrachloroethene ug/l EPA 8260B Notes Sample ID: SB3-S1-2 Laboratory ID: T Reporting Analyte Result Limit Units Method Notes cis-1,2-dichloroethene mg/kg EPA 8260B Tetrachloroethene mg/kg EPA 8260B E Trichloroethene mg/kg EPA 8260B Sample ID: SB3-W1 Laboratory ID: T Reporting Analyte Result Limit Units Method Notes The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Daniel Chavez, Project Manager Page 2 of 15

44 25712 Commercentre Drive Lake Forest, California Phone Fax Partner Engineering & Science, Inc.--San Francisco Project: Campbells 111 Pine St. Suite 1750 Project Number: San Francisco CA, Project Manager: Terri Men Reported: 01/09/15 16:37 Sample ID: SB3-W1 Laboratory ID: T Reporting Analyte Result Limit Units Method cis-1,2-dichloroethene ug/l EPA 8260B trans-1,2-dichloroethene ug/l EPA 8260B Tetrachloroethene ug/l EPA 8260B Trichloroethene ug/l EPA 8260B Vinyl chloride ug/l EPA 8260B Notes Sample ID: SB4-S1-5 Laboratory ID: T Reporting Analyte Result Limit Units Method Notes cis-1,2-dichloroethene mg/kg EPA 8260B Tetrachloroethene mg/kg EPA 8260B E Trichloroethene mg/kg EPA 8260B Sample ID: SB4-S2-8 Laboratory ID: T Reporting Analyte Result Limit Units Method cis-1,2-dichloroethene mg/kg EPA 8260B Tetrachloroethene mg/kg EPA 8260B Trichloroethene mg/kg EPA 8260B Notes Sample ID: SB4-W1 Laboratory ID: T Reporting Analyte Result Limit Units Method cis-1,2-dichloroethene ug/l EPA 8260B trans-1,2-dichloroethene ug/l EPA 8260B Tetrachloroethene ug/l EPA 8260B Trichloroethene ug/l EPA 8260B Notes The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Daniel Chavez, Project Manager Page 3 of 15

45 25712 Commercentre Drive Lake Forest, California Phone Fax Partner Engineering & Science, Inc.--San Francisco Project: Campbells 111 Pine St. Suite 1750 Project Number: San Francisco CA, Project Manager: Terri Men Reported: 01/09/15 16:37 SB1-S1-12 T (Soil) Reporting Analyte Result Limit Units Dilution Batch Prepared Analyzed Method Notes Volatile Organic Compounds by EPA Method 8260B cis-1,2-dichloroethene ND mg/kg /08/15 01/08/15 EPA 8260B trans-1,2-dichloroethene ND Tetrachloroethene ND Trichloroethene ND Vinyl chloride ND Surrogate: 4-Bromofluorobenzene Surrogate: Dibromofluoromethane Surrogate: Toluene-d % 134 % 92.9 % The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Daniel Chavez, Project Manager Page 4 of 15

46 25712 Commercentre Drive Lake Forest, California Phone Fax Partner Engineering & Science, Inc.--San Francisco Project: Campbells 111 Pine St. Suite 1750 Project Number: San Francisco CA, Project Manager: Terri Men Reported: 01/09/15 16:37 SB1-W1 T (Water) Reporting Analyte Result Limit Units Dilution Batch Prepared Analyzed Method Notes Volatile Organic Compounds by EPA Method 8260B cis-1,2-dichloroethene ND 1.0 ug/l /08/15 01/08/15 EPA 8260B trans-1,2-dichloroethene ND 1.0 Tetrachloroethene Trichloroethene ND 1.0 Vinyl chloride ND 1.0 Surrogate: 4-Bromofluorobenzene Surrogate: Dibromofluoromethane Surrogate: Toluene-d % 113 % 92.8 % The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Daniel Chavez, Project Manager Page 5 of 15

47 25712 Commercentre Drive Lake Forest, California Phone Fax Partner Engineering & Science, Inc.--San Francisco Project: Campbells 111 Pine St. Suite 1750 Project Number: San Francisco CA, Project Manager: Terri Men Reported: 01/09/15 16:37 SB2-S1-4 T (Soil) Reporting Analyte Result Limit Units Dilution Batch Prepared Analyzed Method Notes Volatile Organic Compounds by EPA Method 8260B cis-1,2-dichloroethene ND mg/kg /08/15 01/08/15 EPA 8260B trans-1,2-dichloroethene ND Tetrachloroethene ND Trichloroethene ND Vinyl chloride ND Surrogate: 4-Bromofluorobenzene Surrogate: Dibromofluoromethane Surrogate: Toluene-d % 127 % 91.5 % The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Daniel Chavez, Project Manager Page 6 of 15

48 25712 Commercentre Drive Lake Forest, California Phone Fax Partner Engineering & Science, Inc.--San Francisco Project: Campbells 111 Pine St. Suite 1750 Project Number: San Francisco CA, Project Manager: Terri Men Reported: 01/09/15 16:37 SB2-W1 T (Water) Reporting Analyte Result Limit Units Dilution Batch Prepared Analyzed Method Notes Volatile Organic Compounds by EPA Method 8260B cis-1,2-dichloroethene ug/l /08/15 01/08/15 EPA 8260B trans-1,2-dichloroethene ND 1.0 Tetrachloroethene Trichloroethene ND 1.0 Vinyl chloride ND 1.0 Surrogate: 4-Bromofluorobenzene 94.0 % Surrogate: Dibromofluoromethane 120 % Surrogate: Toluene-d8 102 % The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Daniel Chavez, Project Manager Page 7 of 15

49 25712 Commercentre Drive Lake Forest, California Phone Fax Partner Engineering & Science, Inc.--San Francisco Project: Campbells 111 Pine St. Suite 1750 Project Number: San Francisco CA, Project Manager: Terri Men Reported: 01/09/15 16:37 SB3-S1-2 T (Soil) Reporting Analyte Result Limit Units Dilution Batch Prepared Analyzed Method Notes Volatile Organic Compounds by EPA Method 8260B cis-1,2-dichloroethene mg/kg /08/15 01/08/15 EPA 8260B trans-1,2-dichloroethene ND Tetrachloroethene E Trichloroethene Vinyl chloride ND Surrogate: 4-Bromofluorobenzene 94.1 % Surrogate: Dibromofluoromethane 129 % Surrogate: Toluene-d % The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Daniel Chavez, Project Manager Page 8 of 15

50 25712 Commercentre Drive Lake Forest, California Phone Fax Partner Engineering & Science, Inc.--San Francisco Project: Campbells 111 Pine St. Suite 1750 Project Number: San Francisco CA, Project Manager: Terri Men Reported: 01/09/15 16:37 SB3-W1 T (Water) Reporting Analyte Result Limit Units Dilution Batch Prepared Analyzed Method Notes Volatile Organic Compounds by EPA Method 8260B cis-1,2-dichloroethene ug/l /08/15 01/08/15 trans-1,2-dichloroethene Tetrachloroethene Trichloroethene Vinyl chloride Surrogate: 4-Bromofluorobenzene 107 % Surrogate: Dibromofluoromethane 120 % Surrogate: Toluene-d8 116 % EPA 8260B The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Daniel Chavez, Project Manager Page 9 of 15

51 25712 Commercentre Drive Lake Forest, California Phone Fax Partner Engineering & Science, Inc.--San Francisco Project: Campbells 111 Pine St. Suite 1750 Project Number: San Francisco CA, Project Manager: Terri Men Reported: 01/09/15 16:37 SB4-S1-5 T (Soil) Reporting Analyte Result Limit Units Dilution Batch Prepared Analyzed Method Notes Volatile Organic Compounds by EPA Method 8260B cis-1,2-dichloroethene mg/kg /08/15 01/08/15 EPA 8260B trans-1,2-dichloroethene ND Tetrachloroethene E Trichloroethene Vinyl chloride ND Surrogate: 4-Bromofluorobenzene 106 % Surrogate: Dibromofluoromethane 122 % Surrogate: Toluene-d % The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Daniel Chavez, Project Manager Page 10 of 15

52 25712 Commercentre Drive Lake Forest, California Phone Fax Partner Engineering & Science, Inc.--San Francisco Project: Campbells 111 Pine St. Suite 1750 Project Number: San Francisco CA, Project Manager: Terri Men Reported: 01/09/15 16:37 SB4-S2-8 T (Soil) Reporting Analyte Result Limit Units Dilution Batch Prepared Analyzed Method Notes Volatile Organic Compounds by EPA Method 8260B cis-1,2-dichloroethene mg/kg /08/15 01/08/15 EPA 8260B trans-1,2-dichloroethene ND Tetrachloroethene Trichloroethene Vinyl chloride ND Surrogate: 4-Bromofluorobenzene 102 % Surrogate: Dibromofluoromethane 135 % Surrogate: Toluene-d % The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Daniel Chavez, Project Manager Page 11 of 15

53 25712 Commercentre Drive Lake Forest, California Phone Fax Partner Engineering & Science, Inc.--San Francisco Project: Campbells 111 Pine St. Suite 1750 Project Number: San Francisco CA, Project Manager: Terri Men Reported: 01/09/15 16:37 SB4-W1 T (Water) Reporting Analyte Result Limit Units Dilution Batch Prepared Analyzed Method Notes Volatile Organic Compounds by EPA Method 8260B cis-1,2-dichloroethene ug/l /08/15 01/08/15 EPA 8260B trans-1,2-dichloroethene Tetrachloroethene Trichloroethene Vinyl chloride ND Surrogate: 4-Bromofluorobenzene 105 % Surrogate: Dibromofluoromethane 112 % Surrogate: Toluene-d % The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Daniel Chavez, Project Manager Page 12 of 15

54 25712 Commercentre Drive Lake Forest, California Phone Fax Partner Engineering & Science, Inc.--San Francisco Project: Campbells 111 Pine St. Suite 1750 Project Number: San Francisco CA, Project Manager: Terri Men Reported: 01/09/15 16:37 Volatile Organic Compounds by EPA Method 8260B - Quality Control Analyte Result Reporting Limit Units Spike Level Source Result %REC %REC Limits RPD RPD Limit Notes Batch EPA 5030 GCMS Blank ( BLK1) Prepared & Analyzed: 01/08/15 cis-1,2-dichloroethene ND mg/kg trans-1,2-dichloroethene ND Tetrachloroethene ND Trichloroethene ND Vinyl chloride ND Surrogate: 4-Bromofluorobenzene Surrogate: Dibromofluoromethane Surrogate: Toluene-d LCS ( BS1) Prepared & Analyzed: 01/08/15 Trichloroethene mg/kg Surrogate: 4-Bromofluorobenzene Surrogate: Dibromofluoromethane Surrogate: Toluene-d LCS Dup ( BSD1) Prepared & Analyzed: 01/08/15 Trichloroethene mg/kg Surrogate: 4-Bromofluorobenzene Surrogate: Dibromofluoromethane Surrogate: Toluene-d Batch EPA 5030 GCMS Blank ( BLK1) Prepared & Analyzed: 01/08/15 cis-1,2-dichloroethene ND 1.0 ug/l trans-1,2-dichloroethene ND 1.0 Tetrachloroethene ND 1.0 Trichloroethene ND 1.0 Vinyl chloride ND 1.0 Surrogate: 4-Bromofluorobenzene Surrogate: Dibromofluoromethane Surrogate: Toluene-d The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Daniel Chavez, Project Manager Page 13 of 15

55 25712 Commercentre Drive Lake Forest, California Phone Fax Partner Engineering & Science, Inc.--San Francisco Project: Campbells 111 Pine St. Suite 1750 Project Number: San Francisco CA, Project Manager: Terri Men Volatile Organic Compounds by EPA Method 8260B - Quality Control Reported: 01/09/15 16:37 Analyte Result Reporting Limit Units Spike Level Source Result %REC %REC Limits RPD RPD Limit Notes Batch EPA 5030 GCMS LCS ( BS1) Prepared & Analyzed: 01/08/15 Trichloroethene ug/l Surrogate: 4-Bromofluorobenzene Surrogate: Dibromofluoromethane Surrogate: Toluene-d LCS Dup ( BSD1) Prepared & Analyzed: 01/08/15 Trichloroethene ug/l Surrogate: 4-Bromofluorobenzene Surrogate: Dibromofluoromethane Surrogate: Toluene-d The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Daniel Chavez, Project Manager Page 14 of 15

56 25712 Commercentre Drive Lake Forest, California Phone Fax Partner Engineering & Science, Inc.--San Francisco Project: Campbells 111 Pine St. Suite 1750 Project Number: San Francisco CA, Project Manager: Terri Men Reported: 01/09/15 16:37 Notes and Definitions E DET ND NR dry RPD The concentration indicated for this analyte is above the calibration range of the instrument. This value should be considered as an estimate as the actual value may be higher. Analyte DETECTED Analyte NOT DETECTED at or above the reporting limit Not Reported Sample results reported on a dry weight basis Relative Percent Difference The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Daniel Chavez, Project Manager Page 15 of 15

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59 25712 Commercentre Drive Lake Forest, California Phone Fax 09 January 2015 Terri Men Partner Engineering & Science, Inc.--San Francisco 111 Pine St. Suite 1750 San Francisco, CA RE: Campbells Enclosed are the results of analyses for samples received by the laboratory on 01/08/15 10:50. If you have any questions concerning this report, please feel free to contact me. Sincerely, Daniel Chavez Project Manager

60 25712 Commercentre Drive Lake Forest, California Phone Fax Partner Engineering & Science, Inc.--San Francisco Project: Campbells 111 Pine St. Suite 1750 Project Number: San Francisco CA, Project Manager: Terri Men Reported: 01/09/15 16:38 ANALYTICAL REPORT FOR SAMPLES Sample ID Laboratory ID Matrix Date Sampled Date Received SV-1 T Air 01/06/15 15:24 01/08/15 10:50 SV-2 T Air 01/06/15 08:02 01/08/15 10:50 SV-3 T Air 01/06/15 08:18 01/08/15 10:50 The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Daniel Chavez, Project Manager Page 1 of 7

61 25712 Commercentre Drive Lake Forest, California Phone Fax Partner Engineering & Science, Inc.--San Francisco Project: Campbells 111 Pine St. Suite 1750 Project Number: San Francisco CA, Project Manager: Terri Men Reported: 01/09/15 16:38 DETECTIONS SUMMARY Sample ID: SV-1 Laboratory ID: T Reporting Analyte Result Limit Units Method Isopropyl alcohol ug/m³ Air TO-15 cis-1,2-dichloroethene ug/m³ Air TO-15 Tetrachloroethene ug/m³ Air TO-15 Notes Sample ID: SV-2 Laboratory ID: T Reporting Analyte Result Limit Units Method Notes cis-1,2-dichloroethene ug/m³ Air TO-15 E trans-1,2-dichloroethene ug/m³ Air TO-15 Tetrachloroethene ug/m³ Air TO-15 Trichloroethene ug/m³ Air TO-15 Sample ID: SV-3 Laboratory ID: T Reporting Analyte Result Limit Units Method Isopropyl alcohol ug/m³ Air TO-15 cis-1,2-dichloroethene ug/m³ Air TO-15 Tetrachloroethene ug/m³ Air TO-15 Trichloroethene ug/m³ Air TO-15 Notes The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Daniel Chavez, Project Manager Page 2 of 7

62 25712 Commercentre Drive Lake Forest, California Phone Fax Partner Engineering & Science, Inc.--San Francisco Project: Campbells 111 Pine St. Suite 1750 Project Number: San Francisco CA, Project Manager: Terri Men Reported: 01/09/15 16:38 SV-1 T (Air) Reporting Analyte Result Limit Units Dilution Batch Prepared Analyzed Method Notes TO-15 Isopropyl alcohol ug/m³ Air /08/15 01/09/15 TO-15 cis-1,2-dichloroethene trans-1,2-dichloroethene ND 4.0 Tetrachloroethene Trichloroethene ND 5.5 Vinyl chloride ND 2.6 Surrogate: 4-Bromofluorobenzene 49.4 % The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Daniel Chavez, Project Manager Page 3 of 7

63 25712 Commercentre Drive Lake Forest, California Phone Fax Partner Engineering & Science, Inc.--San Francisco Project: Campbells 111 Pine St. Suite 1750 Project Number: San Francisco CA, Project Manager: Terri Men Reported: 01/09/15 16:38 SV-2 T (Air) Reporting Analyte Result Limit Units Dilution Batch Prepared Analyzed Method Notes TO-15 Isopropyl alcohol ND 13 ug/m³ Air /08/15 01/08/15 TO-15 cis-1,2-dichloroethene E trans-1,2-dichloroethene Tetrachloroethene Trichloroethene Vinyl chloride ND 2.6 Surrogate: 4-Bromofluorobenzene 47.2 % The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Daniel Chavez, Project Manager Page 4 of 7

64 25712 Commercentre Drive Lake Forest, California Phone Fax Partner Engineering & Science, Inc.--San Francisco Project: Campbells 111 Pine St. Suite 1750 Project Number: San Francisco CA, Project Manager: Terri Men Reported: 01/09/15 16:38 SV-3 T (Air) Reporting Analyte Result Limit Units Dilution Batch Prepared Analyzed Method Notes TO-15 Isopropyl alcohol ug/m³ Air /08/15 01/08/15 TO-15 cis-1,2-dichloroethene trans-1,2-dichloroethene ND 4.0 Tetrachloroethene Trichloroethene Vinyl chloride ND 2.6 Surrogate: 4-Bromofluorobenzene 48.5 % The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Daniel Chavez, Project Manager Page 5 of 7

65 25712 Commercentre Drive Lake Forest, California Phone Fax Partner Engineering & Science, Inc.--San Francisco Project: Campbells 111 Pine St. Suite 1750 Project Number: San Francisco CA, Project Manager: Terri Men Reported: 01/09/15 16:38 TO-15 - Quality Control Analyte Result Reporting Limit Units Spike Level Source Result %REC %REC Limits RPD RPD Limit Notes Batch EPA 5030 GCMS Blank ( BLK1) Prepared & Analyzed: 01/08/15 Isopropyl alcohol ND 13 ug/m³ Air cis-1,2-dichloroethene ND 4.0 trans-1,2-dichloroethene ND 4.0 Tetrachloroethene ND 6.9 Trichloroethene ND 5.5 Vinyl chloride ND 2.6 Surrogate: 4-Bromofluorobenzene Duplicate ( DUP1) Source: T Prepared: 01/08/15 Analyzed: 01/09/15 Isopropyl alcohol ug/m³ Air cis-1,2-dichloroethene trans-1,2-dichloroethene ND 4.0 ND 30 Tetrachloroethene Trichloroethene ND 5.5 ND 30 Vinyl chloride ND 2.6 ND 30 Surrogate: 4-Bromofluorobenzene The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Daniel Chavez, Project Manager Page 6 of 7

66 25712 Commercentre Drive Lake Forest, California Phone Fax Partner Engineering & Science, Inc.--San Francisco Project: Campbells 111 Pine St. Suite 1750 Project Number: San Francisco CA, Project Manager: Terri Men Reported: 01/09/15 16:38 Notes and Definitions E DET ND NR dry RPD The concentration indicated for this analyte is above the calibration range of the instrument. This value should be considered as an estimate as the actual value may be higher. Analyte DETECTED Analyte NOT DETECTED at or above the reporting limit Not Reported Sample results reported on a dry weight basis Relative Percent Difference The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Daniel Chavez, Project Manager Page 7 of 7

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