The date, site name, report author, report recipient, and report number are presented above.

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1 Engineering Management Support, Inc. Memorandum To: Jesse Aviles, EPA RPM, VB/I70 Superfund Site From: Timothy C. Shangraw Date: March 29, 2018 Re: POLREP #32 - Vasquez Boulevard/Interstate 70 (VB/I70) Superfund Site, Operable Unit 2, Removal Action ======================================================================= On behalf of the City and County of Denver (Respondent), Engineering Management Support, Inc. (EMSI) is submitting this Pollution Report (POLREP #32) in accordance with Section 4.c of Appendix C to the Administrative Settlement Agreement and Order on Consent for Removal Action, for the subject Superfund Site (the Site). This report follows the outline detailed in Section 4.c of Appendix C, and contains pertinent new information specified in the Superfund Removal Procedures, Removal Response Reporting: POLREP and On-Scene Coordinator (OSC) Reports (EPA, 1994). Section I Heading The date, site name, report author, report recipient, and report number are presented above. Section II Response Information This reporting period extended from February 1 through 28, 2018 during which time the following activities occurred: Excavation of non-regulated Asbestos-Contaminated Soil (RACS), stockpiling some of it onsite for future backfilling, and hauling the remainder to the Denver Arapahoe Disposal Site (DADS); Construction of outlet wing walls and open channel sidewalls through the Coliseum Parking Lot (CPL); Construction of inlet and outlet wing walls, open channel sidewalls, lateral drain boxes, UV treatment box, Arkins Court transition structure, and outlet rip rap through the Globeville Landing Park (GLP); Pumping and treatment of groundwater from dewatering zones 1, 2, 3a, and 3b; On-site and off-site monitoring for air quality, dust, and odors; and Conducting Quality Assurance field audits. The volumes of water pumped, treated, and returned to the South Platte River, and the volumes of non-racs excavated and managed are summarized in Table 1. No RACS were excavated

2 Memorandum POLREP #32 VB/I70, OU2 Removal Action March 29, 2018 Page 2 during the month. On-site monitoring for volatile organic compounds (including methane), odor, and visible dust emissions occurred continuously during excavation activities. In addition, monitoring for airborne asbestos fibers proceeded in accordance with Section 5.5 of the Colorado s Solid Waste Regulations (CSWRs). Due to their overall size, daily monitoring reports for volatile organic compounds, odor, dust, and asbestos are being submitted under separate cover. Off-Site monitoring by Denver for PM 10, airborne lead and arsenic at four locations within the monitoring boundary continued throughout the reporting period. Sampling from these stations occurred every sixth day throughout the month. All results were all below the Occupational Safety and Health Administration 8-hour limits and National Ambient Air Quality Standards. Monthly monitoring reports are posted on the Globeville Landing Outfall (GLO) project web site at: As part of the GLO project s Community Outreach program, a community hotline was operated. No complaints were received during the reporting period. The Community Advisory Group (CAG) held its thirteenth meeting on March 13 th. Meeting minutes are posted on the VB/I-70 Superfund Community Advisory Group web site. The next CAG meeting is scheduled for April 10, The following project meetings were held in February and earlier this month: Weekly GLO Project Status Meetings (February 1, 8, 15, and 22, 2018); and EPA monthly progress meeting (March 21, 2018). Lastly, a 3-week look-ahead Construction Schedule is attached to this POLREP. Section III Issues, Resolutions, and Planned Activities Quality Assurance (QA) Audit Report #10 was prepared on March 7, It involved a site inspection on February 15 th by a representative from Engineering Management Support, Inc. (EMSI) to assess consistency with Section 5.5 of Colorado s Solid Waste Regulations (CSWRs), and consistency with environmental monitoring activities detailed in the Final Materials Management Plan (MMP) (EMSI, 2016). In addition, the EMSI representative reviewed Kleinfelder s Certified Asbestos Building Inspector (CABI) reports dated February 1, 5, 10, and 15 for completeness and accuracy. The field inspection indicated asbestos management and environmental monitoring activities were being performed in partial compliance with Section 5.5 of the CSWRs. During excavation to expose some of the stone columns, Kleinfelder representatives appeared uncertain about their determinations of whether the material immediately overlying the columns was RACS, and if the excavated area should be determined an RWA. This appeared to be caused more by a change in Kleinfelder personnel recently assigned to the project than by a proper determination of RACS/RWA. Upon review of earlier

3 Memorandum POLREP #32 VB/I70, OU2 Removal Action March 29, 2018 Page 3 records, the material had been classified as non-racs. It also appeared that Kleinfelder was not informed by Ames that when excavating to the top of stone columns, Ames would encounter soil other than Class 1 fill material. Required corrective actions consisted of 1) better informing new Kleinfelder personnel about historical Site knowledge and prior RACS determinations, 2) updating protocol for handling suspect ACM, and 3) improving communications among Kleinfelder and Ames personnel. Only one minor typographical error was noted on one of the CABI reports. All of the required corrective actions have been implemented and the typographical error has been corrected. Therefore, the audit was closed. A copy of the Audit Report is attached to this POLREP. Monitoring of treated effluent from the GLO project continued during the reporting period in accordance with Discharge Permit Number CO All monitored parameters met discharge limits during the month, as shown in the attached summary table. Planned activities for the next reporting period consist of: Continue construction of wing walls and open channel sidewalls through the CPL and GLP; Complete construction of lateral drain boxes in the GLP; Complete construction of outlet structures, transition zones, and riprap in the GLP; Complete final grading of the drainage channel and placement of the strengthening layer; Begin placement of liner material over the strengthening layer; Continued dewatering in zones 1, 2, 3a and 3b; and Continued on-site and off-site monitoring of air quality. To maintain effective and transparent communication during GLO implementation, EPA and CDPHE personnel are invited to participate in weekly coordination meetings at Kiewit s RiNo office. The next EPA Monthly Status meeting will be held on April 18 th at 9:00 am in the Webb building. Please call Andrew Ross ( ) or me ( ) if you have any questions. Attachments: February 2018 Summary of GLO Construction Activities 3-Week Look-Ahead Schedule QA Audit Report # 10 Summary of Effluent and Influent Analytical Results

4 TABLE 1 - FEB 2018 Construction Summary Current Month QTY QTY to date Comments EXCAVATION/HAULING # of days Excavation occurred Globeville park 0 98 # of days Excavation occurred Municipal Landfill 0 35 Volume of Racs Excavated (CY) 0 89,527 From Globeville Park Volume of Racs hauled to DADS (CY) 0 89,527 From Globeville Park Volume of Non-Racs Excavated (CY) 1,518 60,487 Volume of Non-Racs stockpiled onsite (CY) ,116 Volume of Non-Racs hauled to DADS (CY) 1,008 47,371 Volume Hauled to Clean Harbors (CY) 0 GROUT AND STONE COLUMNS number of grout columns installed this month 0 1,091 All Stone and Grout columns are complete Grout column SPT testing results 0 0 All Stone and Grout columns are complete number of stone columns installed per month All Stone and Grout columns are complete stone column test results 0 0 All Stone and Grout columns are complete REMEDIATION DEWATERING AND TREATMENT LF of underdrain/wick wells installed 650 Volume of water transported and treated at MFEI 1,439,500 28,313,874 Volume of treated water, including dilution, discharged to S. Platte 1,356,933 28,499,623 Analytical results 0 Jan DMR submitted; no exceedences CONSTRUCITION DEWATERING status of permit compliance LINER INSTALLATION % complete during the month N/A QC/QA testing results N/A Issues and Resolutions N/A MODCP RESULTS Daily Methane, Odor, and Dust monitoring reports Issues and Resolutions COMMUNITY OUTREACH Summary of Calls to hotline Issues and Resolutions

5 Globeville Phase 1A Schedule Title Current Week Phase 1A 3 week schedule Monday, March 12, 2018 Item Activity Description Work performed by Start Finish Shift Current Forecast Forecast Forecast Comments 03/12 03/12 03/13 03/13 03/14 03/14 03/15 03/15 03/16 03/16 03/17 03/17 03/18 03/18 03/19 03/19 03/20 03/20 03/21 03/21 03/22 03/22 03/23 03/23 03/24 03/24 03/25 03/25 03/26 03/26 03/27 03/27 03/28 03/28 03/29 03/29 03/30 03/30 03/31 03/31 04/01 04/01 04/02 04/02 04/03 04/03 04/04 04/04 04/05 04/05 04/06 04/06 04/07 04/07 04/08 04/08 M T W T F Sa Su M T W T F Sa Su M T W T F Sa Su M T W T F Sa Su 1 2 EARTHWORK (Park Channel) 3 Backfill S. Lateral Dran box Ames 03/08/18 03/16/18 day 4 Backfill N. Lateral Dran box Ames 03/26/18 03/30/18 day 5 Finish Geogrid and Rock in Channel Ames 03/19/18 03/23/18 day 6 Install Strenghtening Layer (LINER) ECA 03/26/18 04/07/18 day OUTFALL CHANNEL 10 Upper Soil wrap Ames 03/15/18 03/30/18 day 11 Upper Soil wrap Ames 03/26/18 03/30/18 day 12 Seed / Blanket Lower outfall channel Western states 03/15/18 03/19/18 day 13 Topsoil in upper outfall channel Ames 03/12/18 03/16/18 day 14 Topsoil in upper outfall channel Ames 03/12/18 03/15/18 day 15 Remove sheets zones 1 & 2 Ames 03/12/18 04/14/18 day N. LATERAL DRAIN BOX 18 Strip shoring Ames 03/14/18 03/20/18 day EAST PARK WALL UV Vault 24 Lower Excavation Ames 03/12/18 03/13/18 day 25 F/R/D UV vault footing Ames 03/14/18 03/23/18 day 26 F/R/D UV vault wall Ames 03/26/18 03/30/18 day 27 F/R/D UV vault deck Ames 04/02/18 04/15/18 day N. Bridge Abutment 31 F/R/P N. Abutment wall Ames 03/26/18 04/06/18 day S. Bridge Abutment 35 F/R/P Abutment wing walls Ames 03/12/18 03/26/18 day Arkins outlet 39 F/R/P Apron section 1 Ames 03/09/18 03/13/18 day 40 F/R/P Apron section 2 Ames 03/14/18 03/15/18 day 41 42

6 Globeville Phase 1A Schedule Title Current Week Phase 1A 3 week schedule Monday, March 12, 2018 Item Activity Description Work performed by Start Finish Shift Current Forecast Forecast Forecast Comments 03/12 03/12 03/13 03/13 03/14 03/14 03/15 03/15 03/16 03/16 03/17 03/17 03/18 03/18 03/19 03/19 03/20 03/20 03/21 03/21 03/22 03/22 03/23 03/23 03/24 03/24 03/25 03/25 03/26 03/26 03/27 03/27 03/28 03/28 03/29 03/29 03/30 03/30 03/31 03/31 04/01 04/01 04/02 04/02 04/03 04/03 04/04 04/04 04/05 04/05 04/06 04/06 04/07 04/07 04/08 04/08 M T W T F Sa Su M T W T F Sa Su M T W T F Sa Su M T W T F Sa Su 43 N. Colisuem conduit wingwall 44 Finegrade Footings J1 - K1 Ames 03/12/18 03/13/18 day 45 F/R/P Footings J1-K1 Ames 03/14/18 03/23/18 day 46 F/R/P walls J1-K1 Ames 03/26/18 04/07/18 day S. Colisuem conduit wingwall 50 Finegrade Footings L1 - K1 Ames 03/15/18 03/19/18 day 51 F/R/P Footings J1-K1 Ames 03/20/18 03/30/18 day 52 F/R/P walls J1-K1 Ames 04/02/18 04/16/18 day

7 Engineering Management Support, Inc. QA Audit Report #10 To: From: cc: Marty Beck and Paul Jacobson, Kiewit Tim Shangraw, EMSI Andrew Ross, DEH; Steve Gonzales, DEH; Ryan Crum (DPW); Brian McLaren (DPW); and Patrick Riley (DPW) Date: March 7, 2018 Re: Audit of Asbestos Management and Environmental Monitoring Activities during February 2018 at Globeville Landing Outfall Project On February 15, 2018, a representative from Engineering Management Support, Inc. (EMSI) conducted a Quality Assurance (QA) audit of asbestos management activities at the Globeville Landing Outfall (GLO) project for consistency with Section 5.5 of Colorado s Solid Waste Regulations (CSWRs), and environmental monitoring activities for consistency with the Final Materials Management Plan (MMP) (EMSI, 2016). Mr. David Matteocci with Matteocci & Associates, LLC represented EMSI and Mr. Mitch Reese and Mr. David Buckley represented Kleinfelder. With respect to Section 5.5 of the CSWRs, the field inspections involved an independent inspection of asbestos handling activities, documentation of findings, sampling, assessment of regulated work areas (RWAs) and how they were delineated, who entered the RWAs and the level of personnel protection equipment (PPE) worn, decontamination procedures, observations of possible visible emissions from RWAs, and other possible indicators of impacted soils. With respect to the MMP, the field inspection involved observations of environmental screening activities of excavated materials, and odor and dust control monitoring. In addition, the EMSI representative reviewed Kleinfelder s CABI reports dated February 1, 5, 10, and 15 for completeness and accuracy. Following completion of the field inspections and CABI report reviews, the EMSI representative met with Ms. Lanaia Carveth to review his observations. Discrepancies or omissions were resolved and documented in both EMSI s logs and Kleinfelder s logs. Copies of EMSI s logs are attached to this Audit Report. Due to their size, copies of Kleinfelder s logs are submitted under separate cover. AUDIT FINDINGS The field inspections indicated asbestos management and environmental monitoring activities were being performed in partial compliance with Section 5.5 of the CSWRs and in full compliance the MMP. Specifically, during excavation to expose stone columns in Area J8, Page 1

8 QA Audit Report #10, GLO Project March 7, 2018 Kleinfelder representatives appeared uncertain about their determinations of whether the material being excavated was RACS, and if the area should be determined an RWA. This appeared to be caused more by a change in Kleinfelder personnel recently assigned to the project than by a proper determination of RACS/RWA. It also appeared that Kleinfelder was not informed by Ames that materials being excavated would be below the Class 1 material that had been placed in the area. Because of the uncertainty, the Kleinfelder CABI conservatively assumed that the soil below the Class 1 material was RACS. Level C PPE was worn by equipment operators when excavating the material, but PPE was not worn be Ames s workers who shoveled the assumed RACS into a poly-wrapped front-end loader bucket. As well, the area being disturbed was not delineated as an RWA. On balance, Kleinfelder s CABI was observing the material being excavated and determined there was no suspect ACM present; only minimal amounts of crushed red brick and concrete were present. He also had the assumed RACS placed in a delineated RWA in Area I6. Screening of CABI reports identified only one discrepancy: CABI Report dated February 1, 2018 by David Buckley: Section 2B does not have a yes or no marked. It should be properly marked. ACTION REQUIRED With regards to the Site Inspection findings, the following corrective actions should be taken: 1. New Kleinfelder personnel assigned to the project need to be better informed about historical Site knowledge and prior RACS determinations. 2. Protocol for handling suspect ACM should be updated and clearly communicated among Kleinfelder and Ames personnel. 3. Ames needs to better communicate the scope of excavation (areal and vertical extent) in areas containing suspect ACM with Kleinfelder before excavation begins, so proper contingent measures can be planned proactively. As documented in correspondence from Kleinfelder, these three corrective actions have been addressed to the satisfaction of EMSI. With regards to the single CABI report discrepancy, Section 2B has been properly marked in a revised report. Consequently, this audit report is closed. Attachments Page 2

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24 Historical Influent and Effluent Water Quality, GLO Water Treatment Plant Parameter Unit Sample Frequency Effluent Permit Limit May-17 Jun-17 Jul-17 Influent* Effluent** Influent* Effluent** Influent* Effluent** Influent* Effluent** Influent* Effluent** Influent* Effluent** Influent* Effluent** Influent* Effluent** Influent* Effluent** Influent* Effluent** Flow Rate (monthly ave) gpm Continuous 100 N/R 95.5 N/R 96.8 N/R 91.2 N/R 84.5 N/R 54.6 N/R 38.5 N/R 32.9 N/R 31.9 N/R 32.6 N/R 33.7 ph standard units 3 days/wk N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R Total Residual Chlorine mg/l 3 days/wk 0.5 N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R Oil and Grease (visual) visual presence 3 days/wk Report N/R None N/R None N/R None N/R None N/R None N/R None N/R None N/R None N/R None N/R None Oil and Grease (lab) mg/l Contingent upon visual presence 10 N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R N/R Total Suspended Solids mg/l Weekly N/R <5-21 N/R 1.4J N/R <5-2.5J N/R < N/R N/R N/R < N/R < N/R N/R E. Coli #/100 ml Weekly N/R 0-2 N/R 0 N/R 0 N/R N/R 0-54 N/R 0-1 N/R 0-1 N/R 0-11 N/R 0-1 N/R 0 BOD 5 mg/l Monthly N/R <2 N/R <1 N/R <1 N/R 1.1 N/R 2.6 N/R <1.0 N/R 11.4 N/R 7.4 N/R 5.5 N/R <12 Total Inorganic Nitrogen mg/l Monthly 10 N/R 8.4 N/R 8.7 N/R 8.7 N/R 8.3 N/R 5.9 N/R 6.8 N/R 5.9 N/R 5.9 N/R 8.1 N/R 2.7 Ammonia mg/l Monthly Report N/R 0.48 N/R 0.3 N/R 0.26 N/R 0.38 N/R 0.38 N/R 0.04 N/R 0.38 N/R 1.2 N/R 2.1 N/R 0.52 Arsenic, total recoverable ug/l Monthly < < <2.0 Cadmium, potentially dissolved ug/l Monthly < < < < < < < < < <0.3 Copper, potentially dissolved ug/l Monthly 5,656-6, < Iron, total recoverable ug/l Monthly 253, < < Lead, total recoverable ug/l Monthly 13, < <1.0 <1.0 < < < < < <0.5 Lead, potentially dissolved ug/l Monthly 2, < <1.0 < < <1.0 <1.0 < < <0.5 Mercury, total ug/l Monthly 3.5 N/R <0.2 N/R <0.2 N/R <0.1 N/R <0.1 N/R <0.1 N/R 2.0 N/R 0.6 N/R <0.1 N/R <0.1 N/R <0.07 Selenium, potentially dissolved ug/l Monthly < <2.0 WET Testing LC 50 Quarterly 100 N/R N/R N/R Failed, then passed N/R N/R N/R N/R N/R N/R N/R Passsed N/R N/R N/R N/R N/R N/R N/R Passed shaded cell indicates compliance with permit limit shaded cell indicates influent exceeds discharge limit; treatment required shaded cell indicates effluent exceeds permit limit * Metals Screen required per Section 1.A.3 of GLO Discharge Permit. VOC and SVOC screens confirmed only trace detections. ** Monitored parameters required per Section 1.A.2 of GLO Discharge Permit Aug-17 Sep-17 Oct-17 Nov-17 Dec-17 Jan-18 Feb-18