From: Scheffler, Linda

Sent: Tue Aug 13 09:32:08 2013

To: LIVERMAN Alex

Subject: RE: Request for revision to DEQ's July 8, 2013 memo regarding the PGE Forest Park property (ECSI # 2406).

Importance: Normal

Alex,

Thanks for sending this my way. I too have spent some time deciphering the data collected by PGE during characterization and remediation of the PGE - Yeon Property. I wanted to point out an observation I made after comparing the original report to the recent summary figure prepared by URS. Neither the URS figure nor the PGE Independent Cleanup Pathway Report depict the results of additional data collected during remediation. The importance of this is that during soil removal, PGE identified an area of the site where the concentration of total PCBs was higher than all other samples collected at the site. Specifically, at confirmation sample point #45 (between characterization points #16 and #17), total PCBs were detected at 1,400 mg/Kg at an approximate depth of 2.5' bgs (see pages 17-18 of the PGE report).

I believe your July 8, 2013 memo had indicated that the highest concentration on the site had been 930 mg/Kg, so I wanted to point out that the confirmation data yielded some additional data to incorporate into your conceptual model for the PGE site. The same holds true for data recently collected on the adjacent Tax Lot 200. The URS summary figure does not include additional data collected during soil removal at that site and does not depict the subsequent actual excavation boundary shown on Figure 3 of the Site Remediation Report (December 31, 2011) . During removal activities at Tax Lot 200, a PCB hot spot of 1,750 mg/Kg (location APP-25) was identified between characterization locations #SS21 and SS22. This concentration was detected at depth (~5' bgs) and represents the highest detected concentration at that site (your memo indicated a maximum concentration of 308 mg/Kg).

Just wanted to clarify those points for your file. Thanks.

Linda

From: LIVERMAN Alex [mailto:liverman.alex@deq.state.or.us]

Sent: Monday, August 12, 2013 11:04 AM

To: Scheffler, Linda

Subject: FW: Request for revision to DEQ's July 8, 2013 memo regarding the PGE Forest Park property (ECSI # 2406).

From: Weatherby, David [mailto:david.weatherby@urs.com]

Sent: Friday, July 26, 2013 4:17 PM

To: ANDERSON Jim M; LIVERMAN Alex

Cc: Loren Dunn; Rich George; Jayne Allen; Arya Behbehani

Subject: Request for revision to DEQ's July 8, 2013 memo regarding the PGE Forest Park property (ECSI # 2406).

Jim and Alex,

URS and PGE have received and reviewed DEQ’s July 8, 2013 memo regarding the PGE Forest Park property (ECSI # 2406). We previously met with you on May 22 to discuss DEQ’s draft version of this memo. At that meeting we stated that because sample point IDs associated with the analytical data discussed on page 2 of the draft memo were not provided, it was impossible to see any connection between the data and the conclusions that were supposedly supported by the data. As you will recall, we also expressed concern that the draft memo did not include a map showing the analytical data and sample points plotted in such a way that made clear the foundation for DEQ’s conclusions regarding concentration trends on the property.

The more recent July 8, 2013 version of this memo did not provide any further clarification or address the many questions and substantive concerns raised by PGE. Specifically, the same “analysis” of the data is provided in the 2^nd and 3^rd paragraphs of Page 3 of the memo as was provided in the draft memo. Despite our request for clarification on this crucial issue, the memo makes absolutely no reference to sample IDs and no map is provided showing the sample point IDs with associated analytical data.

For this reason, again, we request that DEQ revise the current memo as follows:

1. Please revise the memo to include the sample point IDs associated with each stated PCB concentration. For example, where the memo states “PCB concentrations of 230 mg/kg, 190 mg/kg and 130 mg/kg occurred above the 930 mg/kg point to the northwest and up onto the middle terrace, and with decreasing concentrations (54 mg/kg & 19 mg/kg) down slope to the fence line of the Brazil property”, please include the sample point ID in parentheses after each concentration. Please do so for all PCBs concentrations stated in the memo.

2. Please note the attached site map which we have provided for your use. It presents the complete pre-remediation dataset for PCBs in soil on Tax Lots 100 and 200 as well as the more recent data for the Brazil site. On this map, please draw lines connecting the groups of samples that delineate the concentrations trends described in your memo.

For example, where the memo states “PCB concentrations of 230 mg/kg, 190 mg/kg and 130 mg/kg occurred above the 930 mg/kg point to the northwest and up onto the middle terrace, and with decreasing concentrations (54 mg/kg & 19 mg/kg) down slope to the fence line of the Brazil property”, we expect to see each of these sample points clearly identified on the map. Lines should be drawn connecting each of the sample points corresponding to the DEQ’s claimed trends in concentrations. On this map please clearly identify all samples and sample groups referenced in the memo.

The concentration trends analysis that we are requesting is, as you know, a standard analytical technique in the profession, and one which DEQ typically requires for site investigations. We do not believe that PGE is requesting anything extraordinary here, especially since we have prepared the attached map for your use. As such, we expect that revising the memo and marking up the map as requested should take no more than an hour or two of Alex’s time, and we therefore request that you provide these revisions by Friday, August 2^nd.

By providing these important clarifications we will be better able to evaluate the conclusions presented in your memo. After we have received the revised memo and map, we will prepare a formal response to the memo that captures all of our comments and concerns about this memo.

If for any reason you feel that DEQ will be challenged to respond to this request expeditiously, please contact me right away.

Thank you.

D.

David Weatherby, RG

Senior Project Manager / Geologist

URS Corporation

111 SW Columbia, Suite 1500

Portland, OR 97201

(w) 503-948-7219

(c) 503-969-9742