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1 Engineering Management Support, Inc. Memorandum To: Jesse Aviles, EPA RPM, VB/I70 Superfund Site From: Timothy C. Shangraw Date: June 26, 2018 Re: POLREP #35 - 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 #35) 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 May 1 through 31, 2018 during which time the following activities occurred: Excavation of Regulated Asbestos-Contaminated Soils (RACS) and hauling to and disposing at the Denver Arapahoe Disposal Site (DADS); Excavation of non-racs and hauling to and disposing at DADS; Finished construction of the UV treatment box and removal of sheet piles around its excavation; Finished placement and contouring of vegetative soils over the protective soil layer in the open channel; Finished removal of sheet piles from the south side of the GLP outlet channel; Continued construction of the Arkins Court transition structure; Rough grading of the south bank of the open channel, including removing the surface extension of sheep piling to approximately 2 feet below finished grade; Pumped and treated groundwater from dewatering zone 3a; On-Site and off-site monitoring for air quality, dust, and odors; and Conducted Quality Assurance field audits. The volumes of RACS and non-racs excavated and managed, and the volumes of water pumped, treated, and returned to the South Platte River are summarized in Table 1.

2 Memorandum POLREP #35 VB/I70, OU2 Removal Action June 26, 2018 Page 2 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 sixteenth meeting on June 19 th. Meeting minutes are posted on the VB/I-70 Superfund Community Advisory Group web site. It is anticipated that the next CAG meeting will be held on July 17, The following project meetings were held in May and earlier this month: Weekly GLO Project Status Meetings (May 3, 10, 17, 24, and 31, 2018); and 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 #13 was prepared on June 5, It involved Site inspections on May 9 th and 23 rd 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 May 1, 7, 9, 16, 18, 23, and 25 for completeness and accuracy. The field inspections and CABI report reviews indicated asbestos management and environmental monitoring activities were being performed in full compliance with Section 5.5 of the CSWRs and the MMP, with one exception. During the May 23 rd field inspection, a small petroleum oil spill was observed next to the portable toilets by the job trailer/ice machine. Klienfelder personnel were notified of the spill immediately and later that day, the spill was addressed by Ames personnel to the satisfaction of the EMSI representative. No additional corrective action was required and 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.

3 Memorandum POLREP #35 VB/I70, OU2 Removal Action June 26, 2018 Page 3 Planned activities for the next reporting period consist of: Excavation of RACS and non-racs from the GLP; Continued construction of the Arkins Court transition structure in the GLP; Pumping and treatment of groundwater from beneath the Arkins Court transition structure (dewatering zone 3a); Continue on-site and off-site monitoring for air quality, dust, and odors; Continue conducting Quality Assurance field audits; Start preparing closeout documentation. 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 July 18 th at 9:00 am in the Webb building. Please call Kara Edewaard ( ) or me ( ) if you have any questions. Attachments: May 2018 Summary of GLO Construction Activities 3-Week Look-Ahead Schedule QA Audit Report # 13 Summary of Effluent and Influent Analytical Results

4 TABLE 1 - MAY 2018 Construction Summary Current Month QTY QTY to date Comments EXCAVATION/HAULING # of days Excavation occurred Globeville park # of days Excavation occurred Municipal Landfill 35 Volume of Racs Excavated (CY) 9,604 99,159 Volume of Racs hauled to DADS (CY) 9,604 99,159 Volume of Non-Racs Excavated (CY) 3,528 64,127 Volume of Non-Racs stockpiled onsite (CY) 0 13,116 Volume of Non-Racs hauled to DADS (CY) 3,528 51,011 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 198,000 29,327,772 Volume of treated water, including dilution, discharged to S. Platte 1/ 195,521 29,475,053 Analytical results 0 April net DMR submitted CONSTRUCITION DEWATERING status of permit compliance LINER INSTALLATION % complete during the month 100% QC/QA testing results N/A Test results submitted in May 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, June 18, 2018 Item Activity Description Work performed by Start Finish Shift Current Forecast Forecast Forecast Comments 06/18 06/18 06/19 06/19 06/20 06/20 06/21 06/21 06/22 06/22 06/23 06/23 06/24 06/24 06/25 06/25 06/26 06/26 06/27 06/27 06/28 06/28 06/29 06/29 06/30 06/30 07/01 07/01 07/02 07/02 07/03 07/03 07/04 07/04 07/05 07/05 07/06 07/06 07/07 07/07 07/08 07/08 07/09 07/09 07/10 07/10 07/11 07/11 07/12 07/12 07/13 07/13 07/14 07/14 07/15 07/15 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 Mike Boss Crew 4 backfill overexc/subgrade prep North plaza Ames 06/12/18 06/20/18 day 5 backfill overexc areas near trailer Ames 06/20/18 06/29/18 day 6 Type M Rip Rap in overflow wier Ames 07/02/18 07/15/18 day Pinky's Crew 11 Excavate/Prep Arkins phase 2 subgrade Ames 06/20/18 06/26/18 day 12 Place embankment in old Arkins diversion Ames 06/26/18 07/06/18 day 13 Exc subgrade prep/ bike path detour # 4 Ames 07/09/18 07/13/18 day Jaime Crew 18 Divert water into North Bay Ames 06/13/18 06/23/18 day 19 F/R/P bottom slab phase 2 Ames 06/26/18 07/03/18 day 20 F/R/P walls phase 2 Ames 07/09/18 07/13/18 day 21 F/R/P Deck Ames 07/16/18 07/25/18 day Dolores 25 F/R/P Cutoff walls regional trail seg 1 Ames 06/11/18 06/22/18 day 26 F/R/P regional trail seg 1 Ames 06/25/18 07/03/18 day 27 F/R/P Cutoff walls regional trail seg 2 Ames 07/09/18 07/15/18 day 28 F/R/P regional trail seg 2 Ames 07/17/18 07/24/18 day Seiko 31 Drive sheets River overlook wall Ames 06/25/18 06/27/18 day Subcontractors 35 Over-Exc on East side of Project (Chimney Wall) ESA 06/08/18 06/26/18 day 36 Exc/str subgrade prep cutof walls overlfow wier ESA 6/27/18q7/2/18 06/27/18 day

6 Engineering Management Support, Inc. QA Audit Report #13 To: From: cc: Marty Beck and Paul Jacobson, Kiewit Tim Shangraw, EMSI Kara Edewaard DDPHE; Steve Gonzales, DDPHE; Ryan Crum (DPW); Brian McLaren (DPW); and Patrick Riley (DPW) Date: June 5, 2018 Re: Audit of Asbestos Management and Environmental Monitoring Activities during May 2018 at Globeville Landing Outfall Project On May 9 and 23, 2018, a representative from Engineering Management Support, Inc. (EMSI) conducted Quality Assurance (QA) audits 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. David Buckley, Mr. Mitchell Reese, and Mr. John Van Wazer represented Kleinfelder. With respect to Section 5.5 of the CSWRs, the field inspections involved independent inspections 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 inspections involved observations of environmental screening activities of excavated materials, and odor and dust control monitoring. In addition, the EMSI representative reviewed Kleinfelder s Certified Asbestos Building Inspector (CABI) reports dated May 1, 7, 9, 16, 18, 23, and 25 for completeness and accuracy. Following completion of the field inspections and CABI report reviews, the EMSI representative met with Mr. Buckley to review his observations. 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 and CABI report reviews indicated asbestos management and environmental monitoring activities were being performed in full compliance with Section 5.5 of the CSWRs and the MMP, with one exception. During the May 23 rd field inspection, a small petroleum oil spill was observed next to the portable toilets by the job trailer/ice machine. Page 1

7 QA Audit Report #13, GLO Project June 5, 2018 ACTION REQUIRED The spill needed to be addressed as soon as possible. Klienfelder personnel were notified immediately upon its discovery. Later that day, the spill was addressed by Ames personnel to the satisfaction of the EMSI representative. No additional corrective action is required and this audit is closed. Attachments Page 2

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33 Historical Influent and Effluent Water Quality, GLO Water Treatment Plant Parameter Unit Sample Frequency 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 ph standard units 3 days/wk 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 Oil and Grease (visual) visual presence 3 days/wk Report 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 Total Suspended Solids mg/l Weekly N/R <5-21 N/R 1.4J N/R <5-2.5J N/R < E. Coli #/100 ml Weekly N/R 0-2 N/R 0 N/R 0 N/R BOD 5 mg/l Monthly N/R <2 N/R <1 N/R <1 N/R 1.1 Total Inorganic Nitrogen mg/l Monthly 10 N/R 8.4 N/R 8.7 N/R 8.7 N/R 8.3 Ammonia mg/l Monthly Report N/R 0.48 N/R 0.3 N/R 0.26 N/R 0.38 Arsenic, total recoverable ug/l Monthly < < Cadmium, potentially dissolved ug/l Monthly < < < <0.2 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 Lead, potentially dissolved ug/l Monthly 2, < Mercury, total ug/l Monthly 3.5 N/R <0.2 N/R <0.2 N/R <0.1 N/R <0.1 Selenium, potentially dissolved ug/l Monthly WET Testing LC 50 Quarterly 100 N/R N/R N/R Failed, then passed N/R N/R N/R N/R 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 N/R Not Required Effluent Permit Limit May-17 Jun-17 Jul-17 Aug-17 Page 1 of 4

34 Historical Influent and Effluent Water Quality, GLO Water Treatment Plant Parameter Unit Sample Frequency Effluent Permit Limit Flow Rate (monthly ave) gpm Continuous 100 ph standard units 3 days/wk Total Residual Chlorine mg/l 3 days/wk 0.5 Oil and Grease (visual) visual presence 3 days/wk Report Oil and Grease (lab) mg/l Contingent upon visual presence 10 Total Suspended Solids mg/l Weekly E. Coli #/100 ml Weekly BOD 5 mg/l Monthly Total Inorganic Nitrogen mg/l Monthly 10 Ammonia mg/l Monthly Report Arsenic, total recoverable ug/l Monthly 3.0 Cadmium, potentially dissolved ug/l Monthly 0.87 Copper, potentially dissolved ug/l Monthly 5,656-6,975 Iron, total recoverable ug/l Monthly 253,000 Lead, total recoverable ug/l Monthly 13,005 Lead, potentially dissolved ug/l Monthly 2,405 Mercury, total ug/l Monthly 3.5 Selenium, potentially dissolved ug/l Monthly 4.6 WET Testing LC 50 Quarterly 100 Sep-17 Oct-17 Nov-17 Dec-17 Influent* Effluent** Influent* Effluent** Influent* Effluent** Influent* Effluent** N/R 54.6 N/R 38.5 N/R 32.9 N/R 31.9 N/R N/R N/R N/R N/R N/R N/R N/R N/R None N/R None N/R None N/R None 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 0-54 N/R 0-1 N/R 0-1 N/R 0-11 N/R 2.6 N/R <1.0 N/R 11.4 N/R 7.4 N/R 5.9 N/R 6.8 N/R 5.9 N/R 5.9 N/R 0.38 N/R 0.04 N/R 0.38 N/R < < < < < < <1.0 < < < <1.0 <1.0 < < <1.0 <1.0 <1.0 N/R <0.1 N/R 2.0 N/R 0.6 N/R < < N/R N/R N/R Passsed N/R N/R N/R N/R 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 N/R Not Required Page 2 of 4

35 Historical Influent and Effluent Water Quality, GLO Water Treatment Plant Parameter Unit Sample Frequency Effluent Permit Limit Flow Rate (monthly ave) gpm Continuous 100 ph standard units 3 days/wk Total Residual Chlorine mg/l 3 days/wk 0.5 Oil and Grease (visual) visual presence 3 days/wk Report Oil and Grease (lab) mg/l Contingent upon visual presence 10 Total Suspended Solids mg/l Weekly E. Coli #/100 ml Weekly BOD 5 mg/l Monthly Total Inorganic Nitrogen mg/l Monthly 10 Ammonia mg/l Monthly Report Arsenic, total recoverable ug/l Monthly 3.0 Cadmium, potentially dissolved ug/l Monthly 0.87 Copper, potentially dissolved ug/l Monthly 5,656-6,975 Iron, total recoverable ug/l Monthly 253,000 Lead, total recoverable ug/l Monthly 13,005 Lead, potentially dissolved ug/l Monthly 2,405 Mercury, total ug/l Monthly 3.5 Selenium, potentially dissolved ug/l Monthly 4.6 WET Testing LC 50 Quarterly 100 Jan-18 Feb-18 Mar-18 Apr-18 Influent* Effluent** Influent* Effluent** Influent* Effluent** Influent* Effluent** N/R 32.6 N/R 33.7 N/R 14.3 N/R 3.2 N/R N/R N/R N/R N/R N/R N/R N/R N/R None N/R None N/R None N/R None 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 0-1 N/R 0 N/R 0-1,400 N/R 0-5 N/R 5.5 N/R <12 N/R <5 N/R 3.2 N/R 8.1 N/R 2.7 N/R 0.98 N/R 3.2 N/R 2.1 N/R 0.52 N/R 0.3 N/R < < < < < < < < < < < < < <1 <0.5 N/R <0.1 N/R <0.07 N/R <0.2 N/R 0.48 J < <2.0 N/R N/R N/R Passed N/R N/R N/R N/R 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 N/R Not Required Page 3 of 4

36 Historical Influent and Effluent Water Quality, GLO Water Treatment Plant Parameter Unit Sample Frequency Effluent Permit Limit Flow Rate (monthly ave) gpm Continuous 100 ph standard units 3 days/wk Total Residual Chlorine mg/l 3 days/wk 0.5 Oil and Grease (visual) visual presence 3 days/wk Report Oil and Grease (lab) mg/l Contingent upon visual presence 10 Total Suspended Solids mg/l Weekly E. Coli #/100 ml Weekly BOD 5 mg/l Monthly Total Inorganic Nitrogen mg/l Monthly 10 Ammonia mg/l Monthly Report Arsenic, total recoverable ug/l Monthly 3.0 Cadmium, potentially dissolved ug/l Monthly 0.87 Copper, potentially dissolved ug/l Monthly 5,656-6,975 Iron, total recoverable ug/l Monthly 253,000 Lead, total recoverable ug/l Monthly 13,005 Lead, potentially dissolved ug/l Monthly 2,405 Mercury, total ug/l Monthly 3.5 Selenium, potentially dissolved ug/l Monthly 4.6 Influent* May-18 Effluent** N/R 4.4 N/R N/R N/R None N/R N/R N/R N/R 0-1 N/R 2.6 N/R 2.1 N/R < <0.3 < <1.0 <0.5 <1.0 <0.5 N/R < <2.0 WET Testing LC 50 Quarterly 100 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 N/R Not Required N/R N/R Page 4 of 4

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