JOHNSON LAKE FISH TISSUE MONITORING STUDY

SAMPLING AND ANALYSIS PLAN

PREPARED FOR:

OWENS-BROCKWAY GLASS CONTAINER INC.

5850 NE 92^ND DRIVE

PORTLAND, OR, 97222

PREPARED BY:

GRETTE ASSOCIATES ^LLC

2102 NORTH 30^TH STREET, SUITE A

TACOMA, WASHINGTON 98403

(253) 573-9300

APRIL 28, 2022

TABLE OF CONTENTS

1  INTRODUCTION  1

1.1  Project Site Description and Background  1

1.2  Remediation Activities  1

1.3  Sampling and Analysis Plan (SAP)  2

1.3.1  Purpose  2

1.3.2  Scope  2

1.3.3  Organization  2

2  FISH SAMPLING  4

2.1  Fish Collection  4

2.2  Tissue Sample Collection, Decontamination, and Packaging  5

2.3  Sample Transport and Chain of Custody Procedures  6

3  LABORATORY ANALYSIS  7

3.1  Testing Facilities  7

3.2  Laboratory Chain of Custody  7

3.3  Chemicals of Concern (Chemicals of Interest) Screening  7

3.4  Testing Methods  7

4  QUALITY ASSURANCE  8

5  REFERENCES  9

LIST OF TABLES

Table 1. Sample Holding Time and Storage Criteria  7

LIST OF FIGURES

Figure 1: Site Map of Johnson Lake  10

LIST OF ATTACHMENTS

Attachment A. ODFW Scientific Taking Permit

Attachment B. ODEQ May 25, 2017 SAP approval and comments

Attachment C. ALS Standard Operating Procedure MET-TISP (5/29/16) – Fish Tissue Sample

Preparation

Attachment D. ODEQ January 29, 2018 Letter and Comments

Attachment E. Johnson Lake Quality Assurance Project Plan

1  INTRODUCTION

This Sampling and Analysis Plan (SAP) has been prepared to describe the Johnson Lake fish tissue monitoring study, consistent with the Remediation Operations & Maintenance Plan (O&M Plan), Sediment Remedial Action (DOF 2012b), hereafter “O&M Plan.” In support of this SAP, the approved Scientific Take Permit from the Oregon Department of Fish and Wildlife (ODFW) is included as Attachment A. Approval of the 2017 SAP by comment letter from Oregon Department of Environmental Quality (DEQ), comments which are incorporated herein, are included as Attachment B. The analytical laboratories (ALS Global) standard operating procedures for fish tissue sample preparation are attached as Attachment C. DEQ comments from the 2017 collection and sampling effort are included as Attachment D.

The 2022 Johnson Lake fish tissue monitoring study is a requirement of the O&M Plan in response to the results of the 2017 monitoring effort showing contaminant levels in fish samples exceeding the levels specified in the 2007 Record of Decision for the site cleanup.

1.1  PROJECT SITE DESCRIPTION AND BACKGROUND

Owens-Brockway Glass Containers Inc. (Owens) owns and operates a glass manufacturing plant located at 5850 NE 92^nd Drive, Portland, Oregon (the “Property”). Owens’ Property is approximately 43 acres in size and is located on the south shore of Johnson Lake. Johnson Lake extends over 18 acres and is directly connected to the Whitaker Slough, which in turn flows to the Columbia Slough. Johnson Lake is bounded to the south by the Owens Property and to the west and east by other industrial facilities and highways. The Owens Property and Johnson Lake are collectively referred to as the “Site.”

Sediments in Johnson Lake were found to contain polychlorinated biphenyls (PCBs), as described in the Johnson Lake Investigation Work Plan (ARCADIS 2004a), Site Investigation Report (ARCADIS 2004b), and Johnson Lake Risk Assessment (Environ and ARCADIS 2004). Based on the previous investigations and a Feasibility study prepared in 2006, DEQ selected a final remedy for the site in the Record of Decision (October 2007) and Record of Decision Amendment (July 2009). The 2007 Record of Decision and the 2009 Amendment are referred to collectively in this document as the ROD.

1.2  REMEDIATION ACTIVITIES

As described in the ROD, the final remedy for cleanup of the PCBs and other contaminants at the site consisted of the following tasks.

1.  Surface soils from the low-lying area were excavated.

2.  Excavated soils were disposed of at an off-site landfill.

3.  The excavated area was covered with clean soil and revegetated.

4.  A stormwater bio-swale (swale) was constructed.

5.  A thin layer cap was placed over Johnson Lake sediments.

All of the above-listed tasks have been completed and are addressed in detail in the two Site completion reports:

•  Project Completion Report, Soil Remediation Action, March 22, 2011 (DOF and Environ 2011) (Tasks 1 through 4)

•  Project Completion Report, Sediment Remedial Action, September 24, 2012 (DOF 2012a) (Task 5).

1.3  SAMPLING AND ANALYSIS PLAN (SAP)

1.3.1  Purpose

The purpose of this SAP is to describe the Johnson Lake fish tissue monitoring study and build upon previous study efforts. The objective of this study is to evaluate the level of PCBs in fish tissue sampled from Johnson Lake, consistent with the O&M Plan (DOF 2012b). The ROD included the following objective with respect to PCBs in fish tissue, “Prevent human consumption of fish tissue with tissue concentrations of greater than 0.003 ug/kg PCB congener 126”. Fish tissue results will be compared with this concentration.

In 2017, a collection and sampling field effort was completed, and all field and lab data were included in a monitoring report submitted to DEQ in January of 2018. As PCBs were still present in fish tissue at levels exceeding the ROD standard, further efforts to collect fish tissue in 2022 will be conducted and will include information provided in the 2018 report as well as a summary of results from the 2017 and 2004 events for comparison (DEQ 2018). This SAP addresses comments from DEQ regarding the 2017 sampling efforts.

1.3.2  Scope

The SAP describes the procedures for the following:

•  Description of the lake area as a whole;

•  Fish collection (including environmental data collection);

•  Tissue sampling (for fish categories with fillet samples), decontamination, and packaging;

•  Laboratory Analysis (EPA Method 1668C; NOAA or Bligh and Dyer (1959) for lipids), and;

•  Quality Assurance.

1.3.3  Organization

The sampling and analysis for the Johnson Lake fish tissue monitoring study is based on the monitoring report requirements as described in the O&M Plan (DOF 2012b), with additional input as provided during discussions between Rob Webb of DOF (“Project Engineer”), Susan Sholl of Owens, Scott Maharry of Grette Associates, and DEQ personnel in early 2017. Further monitoring report requirements will be incorporated based on comments from DEQ in the 2018 comment letter. The additional field sampling requirements specified by DEQ in the 2018 comment letter (Attachment D) include:

•  level of sampling effort must be sufficient to ensure the required number of fish specified in the OMP (and herein) are collected and that fish are collected throughout the lake;

•  fish in each category must adequately represent that category;

•  use of a full range of available gear types to collect the targeted fish species in each sample category.

The comments from the 2018 DEQ letter related to laboratory procedures and reporting include:

•  the evaluation of results should consider total PCB, PCB TEQ, and lipid normalized total PCB concentrations in addition to PCB congener 126 concentrations to support evaluation of data trends over time;

•  laboratory protocols for sample preparation should specify that composite homogenates of fish tissue are created using equal mass from each individually homogenized fish sample;

•  composite samples of each fish should be of the same type (species) and size (age) class, and;

•  consistent with EPA Guidelines (EPA 2000), the differences between lengths of individuals in a composite sample and the average of the lengths should not exceed 10 percent and at least one replicate should also be analyzed.

The monitoring report for the 2022 fish tissue sampling effort will include, at a minimum, the following:

•  the date of the fish tissue collection;

•  location of fish collection;

•  fish tissue PCB concentrations;

◦  reported both as total PCB and by congener;

◦  reported both on the basis of mass and lipid content;

◦  reported as total PCB, PCB TEQ and, lipid normalized total PCB concentrations in addition to PCB congener 126 concentrations

•  a summary of the results from the 2017 and 2004 sampling events;

•  descriptions of the fish collected (number, species, length, mass) and which fish constituted which composite, and;

•  results of cap inspection with photos (2017, to be provided by the Project Engineer).

2  DESCRIPTION OF JOHNSON LAKE

2.1  INSPECTION OF AREAS NEAR OUTFALLS TO JOHNSON LAKE

During the course of the fish sampling program, inspection of the areas near the outfalls to Johnson Lake will occur. Inspection of the outfalls will include recording of observations related to increased turbidity, discoloration, or algae growth. Photographs of the outfalls and immediately surrounding areas will be taken and included in the monitoring report.

2.2  INSPECTION OF WARNING SIGNS

In addition to the outfall inspections above, the condition and effectiveness of the fish warning signs installed around the perimeter of Johnson Lake will be assessed. For safety, multiple monitoring staff will participate in this assessment. In addition to recording observations of the signs and surrounding areas, photographs of the signs will be taken and included in the monitoring report.

3  FISH SAMPLING

3.1  FISH COLLECTION

The following fish collection program is consistent with the O&M Plan (DOF 2012b) as well as phone and email communication between the Project Engineer and DEQ personnel in early 2017 and the 2018 DEQ comment letter.

The fish collection will be conducted on foot or from a small vessel(s) using a waveform electro-shocker, traditional hook and line methods, and nets or seining. Fish will be collected from a variety of locations around and within the lake, as practicable, and where fish can be collected to represent general fish tissue concentrations lake-wide. Composite samples of each fish collected shall adequately represent the sampling category and be of the same type (species) and size (age) class. The collection will be consistent with EPA Guidelines (Guidance for Assessing Chemical Contaminant Data for Use in Fish Advisories, Volume 1 Fish Sampling and Analysis; EPA 2000), in a manner such that individual fish comprising a single composite sample should be of similar size (the smallest individual in a single composite should be no less than 75% of the total length of the largest individual).

The lake has been remediated with a thin-layer cap, as described in Section 1.2. Fish collection methods must not damage the cap. The Project Engineer advises that the cap is resilient enough for sampling methods which could require biologists to walk on it, including seining (R. Webb, personal communication).

Fish collection will target the following categories of fish. The goal for each category is to collect enough fish for the lab to composite five samples of the same fish type (fillets) and size range (whole fish) into a single composite sample for each category.

•  Game fish fillets: One composite sample will target fish typically consumed by humans (e.g., largemouth bass).

•  Panfish fillets: One composite sample will target panfish (e.g., bluegills); panfish tend to be smaller than game fish and may be consumed by humans.

•  Rough fish fillets: One composite sample will target rough fish that are not typically targeted by humans but may be consumed by humans (e.g., suckers, carp).

•  Large whole‐fish: One composite sample will target fish greater than 350 mm in length that may be consumed by humans and large wildlife species¹.

•  Small whole‐fish: One composite sample will target fish <125 mm in length that may be consumed by smaller wildlife species.

All game and pan fish collected that are greater than 125 mm will be retained for potential analysis. Due to the scarcity of these fish in Johnson Lake, the analysis of individual fish may be required.

During the 2017 collection effort, a single white sturgeon (Acipenser transmontanus) approximately six feet in length was observed in Johnson Lake. The sturgeon was not harmed during the field collection and may still be present in the lake. If this is the case, interactions with the sturgeon will be avoided to the extent practicable. The sturgeon will be included in the list of potential bycatch species in the application for a Scientific Taking Permit obtained from ODFW for the project. The ODFW Scientific Taking Permit is included as Attachment A.

For replicate samples (minimum one replicate sample), the relative difference between the average length of individuals within any replicate sample and the average of the average lengths of individuals in all replicate samples should not exceed 10 percent.

Where possible, fish should be of a harvestable size and weight. Samples collected will be representative of fish likely to be consumed by humans and large enough that this exposure would be reasonable.

Due to habitat limitations and low oxygen conditions previously documented in Johnson Lake, it may not be practicable to collect and analyze the numbers and types of fish samples described above as there may not be a significant fish population in the lake. A good faith effort (four days moving about the lake on foot or by boat, attempting to electroshock or otherwise collect fish that are present) will be made to characterize fish PCB concentrations that are representative of those existing in Johnson Lake. In the event that adequate fish are not collected from each category, a second 4-day collection and sampling effort will be made over the same period at a later date during 2022. In the event a second 4-day collection and sampling effort is required, DEQ will be provided advance notice. This approach is consistent with the O&M Plan (DOF 2012b).

The previous sampling indicates that small fish do not inhabit the center of the lake (ARCADIS 2004b). As such, the collection of small whole-fish composites (<125 mm) will prioritize perimeter sampling zones 6, 7, and 8 to evaluate small home range species closest to the Owens facility.

Sampling methods will include the use of a backpack electro shocker with dip nets, passive nets (e.g., gill net, Fyke net), beach seine, and hook and line angling.

Fish collected at each sample location will be enumerated by species, photographed, categorized (game fish, panfish, rough fish), and measured/weighed. A record will be kept of all fish collected, including species type, length, weight, method of capture, and whether selected for sampling or released. Fish collected during sampling from a specific location within the lake will be temporarily held in a decontaminated cooler filled with water from Johnson Lake. Once sampling activities from that area are complete, fish targeted for tissue analysis will be euthanized via CO₂ immersion (dry ice added to holding water), measured/weighed, wrapped in aluminum foil, placed in individually-labeled plastic bags, and stored on ice in collection bags for transport to ALS Global laboratories in Kelso, Washington for analysis. In the event that multiple areas of the lake are sampled concurrently (e.g., angling in one area while a gill net is deployed in another), fish from different areas of the lake will be kept in separate coolers and not mixed. Fish that are kept for analysis will be held on ice for the duration of the 4-day sampling event, and delivered to ALS Laboratories after the completion of sampling activities on the fourth day.

In an effort to implement humane practices, larger fish will be dispatched by stunning the fish with an appropriately sized blunt tool just above the eyes on the back of the skull followed by pithing using a sharp, decontaminated knife. Any fish not required for tissue analysis will be returned to the location in the lake from which they were collected prior to euthanasia.

If fish in any category continue to be collected after the goal of five individuals and replicate samples has been met, they may be used to replace previously collected fish to get a more spatially-representative sample of fish tissue in each category. This will be noted on field forms.

Five specimens of the same fish species shall be collected to form into a single whole-body composite sample. An additional five specimens of the same species should be collected to form a single fillet composite sample. This allows for more accurate whole-body estimates and allows for correct implementation of Section 11.2.4.1 Whole Fish Tissue in the attached ALS Standard Operating Procedure. If there are not enough fish collected to develop both whole body and fillet composites, whole body composites shall be the priority. This is consistent with the goals of both DEQ and the Oregon Health Authority to ensure risk is not underestimated for people that typically eat the whole fish.

While five fish per composite is the goal, if fewer than five fish of a species are collected, potential compositing with a smaller number of fish or the analysis of individual fish will be considered. In this case, decisions regarding compositing of type and sizes of fish will be made with DEQ coordination.

Fish will not be composited across species, in accordance with the EPA Guidance for Fish Sampling (EPA 2000).

Each sampling location will be recorded using a dGPS. This will include locations where any fish collection was not successful. Water temperature, turbidity, and dissolved oxygen levels will be collected in the middle water column at each sample location, along with weather conditions.

3.2  TISSUE SAMPLE COLLECTION, DECONTAMINATION, AND PACKAGING

Filleting of fish and compositing of samples will be done in the analytical laboratory, not in the field. When preparing euthanized fish for transport to the lab, care will be taken to avoid cross-contamination. Nitrile gloves and aluminum foil work surfaces will be changed regularly to avoid contamination.

Individual fish will be rinsed with analyte-free-ionized water, wrapped in aluminum foil, bagged, labeled, and placed in an ice cooler for shipment to the analytical laboratory.

The analytical laboratory will composite the fillet and whole-fish samples into the single composite samples for each category (Section 3). Fish tissue composites will be created using equal mass from each individually homogenized fish sample, in accordance with the analytical laboratory’s Tissue Sample Preparation Standard Operating Procedure (MET-TISP, dated 5/29/16; Attachment C). Filleting of fish will be done in accordance with the procedures in Attachment C as well as the procedures in Section 7.2.2.7 in EPA Guidance for Assessing Chemical Contaminant Data for Use in Fish Advisories: Volume 1 - Fish Sampling and Analysis (EPA 2000).

3.3  SAMPLE TRANSPORT AND CHAIN OF CUSTODY PROCEDURES

After collected and bagged/labeled, fish will be placed in the ice coolers and packed for shipping. The field representative will log each sample sent for analysis on a chain of custody (COC) form, noting sample identification code, date and time of collection, requested testing, and comments as appropriate.

All fish captured during the sampling effort(s) will be given a unique identifier. The sample code will allow individual fish to be correlated to the data collected, as well as determine which individual fish are included in composited samples in the lab. The sample identification scheme is described below.

•  The first two letters of the sample identification code will identify the category of fish sampled or if the fish was returned to the lake, i.e., fish returned (FR), game fish (GF), pan fish (PF), rough fish (RF), large whole fish (LF), and small whole fish (SF);

•  The first set of numbers in the sample code will be; the area of the lake from which the fish was captured;

•  The second set of numbers in the sample code will be a sequential count of the fish captured

•  If the fish is to be used as a replicate, a letter code (R) will follow the sequential number.

Two example fish sample codes are as follows:

 GF-05-09-R;

 where, “GF” = Game Fish, “05” = Area 5 within Johnson Lake, “09” = the ninth fish  captured during the sampling effort, “R” = this is a replicate sample.

 LF-02-15;

 where, “LF” = Large Whole Fish, “02” = Area 2 within Johnson Lake, “15” = the fifteenth  fish captured during the sampling effort.

Chain-of-custody procedures will commence in the field and will track the delivery of the samples to the laboratory. Upon transfer of possession to the testing laboratory, the chain-of-custody forms will be signed by the persons transferring custody of the samples.

4  LABORATORY ANALYSIS

4.1  TESTING FACILITIES

The collected fish will be delivered to and processed at ALS Global in Kelso, WA. The processed samples will then be shipped to ALS’s laboratory in Houston, Texas, for analysis.

4.2  LABORATORY CHAIN OF CUSTODY

A laboratory chain-of-custody record for each set of samples will be maintained throughout all sampling, processing, and analytical activities. Information tracked by the laboratory chain-of-custody records include a sample identification number, date and time of sample receipt, analytical parameters required, location and conditions of storage, date and time of removal from and return to storage, the signature of the person removing and returning the sample, the reason for removing from storage, and final disposition of the sample.

4.3  CHEMICALS OF CONCERN (CHEMICALS OF INTEREST) SCREENING

The evaluation of results shall consider total PCB, PCB TEQ, and lipid normalized total PCB concentrations in addition to PCB congener 126 concentrations to support evaluation of data trends over time (DEQ 2018). They will also be reported relative to tissue mass and tissue lipid content.

4.4  TESTING METHODS

PCB congeners will be analyzed using EPA method 1668C. The storage temperature for this analysis is 4°C, holding time is 14 days.

Table 1. Sample holding time and storage criteria

5  QUALITY ASSURANCE AND DATA VALIDATION

All sampling and analysis will be done in accordance with the existing DEQ-approved Quality Assurance Project Plan (QAPP) for the Johnson Lake Remediation Project (Arcadis 2004, Johnson Lake Investigation Work Plan, Appendix B, Quality Assurance Project Plan), as well as comments provided in the DEQ 2018 response letter to DOF. The Project QAPP is included as Attachment E.

All field data forms and chain-of-custody forms will be reviewed by the field lead prior to demobilization from the site to ensure completeness and correctness. The field lead will also be responsible for all fish species identification and for ensuring that each fish receives the proper sample identification code.

The field sampling team will attempt to collect replicate and duplicate samples concurrent with sampling activities for laboratory QA/QC. These attempts will be made to an extent practicable during the field efforts and through the course of sampling.

All laboratory QA/QC forms will be included as an appendix to the final report including method blanks, laboratory control samples, and calibration data.

6  REFERENCES

ARCADIS. 2004a. Johnson Lake Investigation Work Plan, Revision 2. Prepared for Owens-Brockway Glass Container, Inc. Portland Oregon, by ARCADIS G&M, Inc., Cleveland, Ohio. January 29, 2004.

ARCADIS. 2004b. Johnson Lake Site Investigation Report. Prepared for Owens-Brockway Glass Container, Inc. Portland Oregon, by ARCADIS G&M, Inc., Cleveland, Ohio. July 15, 2004.

ARCADIS. 2004c. Johnson Lake Investigation Work Plan, Revision 2, Appendix B, Quality Assurance Project Plan. Prepared for Owens-Brockway Glass Container, Inc. Portland Oregon, by ARCADIS G&M, Inc., Cleveland, Ohio. January 29, 2004.

Dalton, Olmsted & Fuglevand, Inc. (DOF) and Environ. 2011. Project Completion Report – Soil Remediation Action. Johnson Lake, Portland, Oregon. Prepared for Owens-Brockway Glass Container Inc. March 22, 2011.

Dalton, Olmsted & Fuglevand, Inc. (DOF). 2012a. Project Completion Report – Sediment Remedial Action. Johnson Lake, Portland, Oregon. Prepared for Owens-Brockway Glass Container Inc. September 24, 2012.

Dalton, Olmsted & Fuglevand, Inc. (DOF). 2012b. Remediation Operations & Maintenance Plan (O & M Plan): Sediment Remedial Action. Johnson Lake, Portland, Oregon. Prepared for Owens-Brockway Glass Container Inc. December 20, 2012.

Grette Assoc. 2018. Revised Johnson Lake Fish Tissue Monitoring Study – Monitoring Report

Oregon Department of Environmental Quality. (DEQ). 2018. Johnson Lake Fish Monitoring Study Comment Response Letter. Prepared for Dalton Olmsted Fuglevand

United States Environmental Protection Agency. (EPA). 2000. EPA Guidance for Assessing Chemical Contaminant Data for Use in Fish Advisories. Vol. 1 Fish Sampling and Analysis. Third edition. Office of Water. EPA 823-B-00-007.

Webb, R. personal communication. Phone call with M. Shelton, April 26, 2017.

Figure 1: Site Map of Johnson Lake

JOHNSON LAKE FISH TISSUE MONITORING STUDY

SAMPLING AND ANALYSIS PLAN

ATTACHMENT A: ODFW SCIENTIFIC TAKING PERMIT

JOHNSON LAKE FISH TISSUE MONITORING STUDY

SAMPLING AND ANALYSIS PLAN

ATTACHMENT B: ODEQ MAY 25, 2017, SAP APPROVAL AND COMMENTS

JOHNSON LAKE FISH TISSUE MONITORING STUDY

SAMPLING AND ANALYSIS PLAN

ATTACHMENT C: ALS STANDARD OPERATING PROCEDURE MET-TISP (5/29/16) – TISSUE SAMPLE PREPARATION

JOHNSON LAKE FISH TISSUE MONITORING STUDY

SAMPLING AND ANALYSIS PLAN

ATTACHMENT D: ODEQ JANUARY 29, 2018, LETTER AND COMMENTS

JOHNSON LAKE FISH TISSUE MONITORING STUDY

SAMPLING AND ANALYSIS PLAN

ATTACHMENT E: QUALITY ASSURANCE PROJECT PLAN