SOIL MANAGEMENT PLAN

Transcription

1 Washington Issaquah Bellingham Seattle Oregon Portland Bend Baker City California Oakland Sacramento Irvine SOIL MANAGEMENT PLAN NORTHEAST KILLINGSWORTH PROPERTY 3009 NORTHEAST KILLINGSWORTH STREET PORTLAND, OREGON Submitted by: Farallon Consulting, L.L.C Southwest Macadam Avenue Portland, Oregon Farallon PN: For: Mr. Brian Spencer Ascend Holdings, Inc. PO Box Vancouver, Washington March 14, 2016 Prepared by: Paul Garvin, R.G. Project Hydrogeologist Reviewed by: Mark Havighorst, P.E. Senior Engineer Q u a l i t y S e r vi ce f o r E n v i r o n m e n t a l So l u t i o n s f a r a l l o nc o n s u l t i n g. c o m

2 TABLE OF CONTENTS 1.0 INTRODUCTION OBJECTIVE PLAN ORGANIZATION PLANNED REDEVELOPMENT BACKGROUND SITE CONDITIONS GEOLOGY AND HYDROGEOLOGY NATURE AND EXTENT OF IMPACTED SOIL Soil with ORO Concentrations Exceeding DEQ RBCs Soil with ORO Concentrations Less than DEQ RBCs NATURE AND EXTENT OF SOIL GAS IMPACTS NATURE AND EXTENT OF GROUNDWATER IMPACTS WORKER SAFETY PROTOCOLS SOIL MANAGEMENT PETROLEUM IMPACTED SOIL IDENTIFICATION PETROLEUM IMPACTED SOIL HANDLING Erosion and Dust Control Excavation Stockpiling Characterization TRANSPORTATION AND DISPOSAL GENERAL LIMITATIONS REFERENCES i G:\Projects\1380 Ascend Holdings\ Northeast Killingsworth Property\Reports\Soil Management Plan\ Soil Management Plan.docx Q u a l i t y S e r vi ce f o r E n v i r o n m e n t a l So l u t i o n s f a r a l l o nc o n s u l t i n g. c o m

3 Figure 1 Figure 2 Table 1 Table 2 Table 3 Table 4 Table 5 Appendix A Appendix B FIGURES Site Vicinity Map Site Plan with Sampling Locations TABLE Soil Analytical Results Petroleum Hydrocarbons Soil Analytical Results VOCs Soil Analytical Results Metals Soil Analytical Results PCBs Soil Gas Analytical Results VOCs APPENDICES Laboratory Analytical Reports Farallon Field Standard Operating Procedures ii G:\Projects\1380 Ascend Holdings\ Northeast Killingsworth Property\Reports\Soil Management Plan\ Soil Management Plan.docx Q u a l i t y S e r vi ce f o r E n v i r o n m e n t a l So l u t i o n s f a r a l l o nc o n s u l t i n g. c o m

4 1.0 INTRODUCTION Farallon Consulting, L.L.C. (Farallon) has prepared this Soil Management Plan (SMP) on behalf of Ascend Holdings, Inc. (Ascend) for the Northeast Killingsworth Property at 3009 Northeast Killingsworth Street in Portland, Oregon (herein referred to as the Site). The Site includes Multnomah County Tax Lot No. 1N1E13CD-15000, which comprises approximately 0.23 acre of land developed with a combined automobile service station and office building that totals approximately 1,300 square feet. The Site location is shown on Figure 1, and Site features are shown on Figure OBJECTIVE The objective of the SMP is to provide a framework for contractors in management of impacted soil that was identified at the Site and that will be encountered during future earthwork activities related to redevelopment of the Site for residential and commercial use. The SMP summarizes planned redevelopment activities and pertinent background information, describes current Site conditions based on the results of sampling activities performed to characterize soil at the Site, and presents worker safety and management protocols for the handling and disposal of impacted soil. The Site owner, operator, contractors, workers, and others involved with earthwork activities should be familiar with the SMP prior to beginning work. 1.2 PLAN ORGANIZATION The SMP is organized into the following sections: Section 2: Describes the planned redevelopment of the Site; Section 3: Provides background information pertinent to development of the SMP, including the results of previous environmental investigations performed at the Site; Section 4: Discusses Site conditions and the nature and extent of impacted soil, based on investigation results; Section 5: Describes worker safety protocols to limit the risk to Site workers handling impacted soil at the Site; Section 6: Describes soil management during redevelopment activities, including methods for the handling and disposal of impacted soil; Section 7: Describes the limitations of the SMP; and Section 8: Provides a list of the documents used in preparing the SMP. 1-1 G:\Projects\1380 Ascend Holdings\ Northeast Killingsworth Property\Reports\Soil Management Plan\ Soil Management Plan.docx Q u a l i t y S e r vi ce f o r E n v i r o n m e n t a l So l u t i o n s f a r a l l o nc o n s u l t i n g. c o m

5 2.0 PLANNED REDEVELOPMENT Farallon understands that the Site is being considered for mixed-use redevelopment, with commercial spaces on the ground floor and residences on the upper floors. Based on proposed redevelopment plans supplied to Farallon, redevelopment activities will include demolition of the existing structures, excavation to construct subsurface structures and utilities, and construction of a four-story building and other surface features. 2-1 G:\Projects\1380 Ascend Holdings\ Northeast Killingsworth Property\Reports\Soil Management Plan\ Soil Management Plan.docx Q u a l i t y S e r vi ce f o r E n v i r o n m e n t a l So l u t i o n s f a r a l l o nc o n s u l t i n g. c o m

6 3.0 BACKGROUND Farallon conducted a Phase I Environmental Site Assessment (Phase I ESA) and a Phase II Environmental Assessment of the Site (Phase II ESA) in 2015 (Farallon 2015a and 2015b, respectively). The Phase I ESA identified the Site as a historical automobile service station, and the potential for releases of hazardous substances to the subsurface from historical underground storage tanks (USTs) and the associated service island, interior sump, and hydraulic vehicle hoists in service bays on the Site as a recognized environmental condition in connection with the Site. The Phase II ESA was conducted to evaluate potential contamination to subsurface soil in connection with the USTs and the associated service island, interior sump, and hydraulic vehicle hoists in service bays; and to develop an initial framework to address potential impacted soil during the course of Site redevelopment. The field work for the Phase II ESA was performed by Farallon on April 13 and 14, Fifteen direct-push soil borings were advanced at the Site to depths ranging from 17 to 25 feet below ground surface (bgs) by Cascade Drilling LP using a Geoprobe 7720DT direct-push drill rig. Representative soil and soil samples were collected from each boring for laboratory analysis to evaluate potential impacts to on-site soil and the associated risk to potential receptors. Four soil gas borings were advanced at the Site to a depth of 10 feet bgs by Cascade Drilling LP using a Geoprobe 7720DT direct-push drill rig outfitted with a Post Run Tubing system. Representative subsurface soil gas samples were collected from each soil gas boring for laboratory analysis to evaluate vapor intrusion risk to potential current and future Site occupants and adjacent residential receptors. The soil and soil gas boring locations are shown on Figure 2. During drilling, soil classification and field screening were conducted in accordance with the methodologies described above. Groundwater was not encountered in the borings. Selected soil samples were submitted under standard chain-of-custody protocols to Apex Laboratories of Tigard, Oregon for laboratory analysis for the potential constituents of interest (COIs) associated with the petroleum products, as defined in Table 2.1 of the DEQ guidance document Risk-Based Decision Making for the Remediation of Petroleum-Contaminated Sites, that historically may have been stored at the Site. The selected soil samples were analyzed for petroleum hydrocarbons using Northwest Method TPH-HCID. Based on the results of the TPH- HCID analysis, 10 soil samples were further analyzed for total petroleum hydrocarbons (TPH) as gasoline-range organics (GRO) using Northwest Method NWTPH-Gx and TPH as diesel- and as oil-range organics (DRO and ORO, respectively) using Northwest Method NWTPH-Dx. In addition, the selected soil samples collected from soil borings B01, B02, and B11 were analyzed for volatile organic compounds (VOCs) using EPA Method 8260B, U.S. Environmental Protection Agency (EPA) Resource Conservation Recovery Act (RCRA) 8 metals using EPA Methods 200/6000/7000 Series, and polychlorinated biphenyls using EPA Method The four soil gas samples were collected using evacuated 1-liter Summa canisters that were individually certified clean. The Summa canisters were labeled, sealed, packed into the original shipping containers, and submitted to Eurofins Air Toxics, Inc. in Folsom, California under chainof-custody protocols for analysis for VOCs using EPA Method TO G:\Projects\1380 Ascend Holdings\ Northeast Killingsworth Property\Reports\Soil Management Plan\ Soil Management Plan.docx Q u a l i t y S e r vi ce f o r E n v i r o n m e n t a l So l u t i o n s f a r a l l o nc o n s u l t i n g. c o m

7 The following is a summary of the analytical results for the soil and soil gas samples; a comparison of the analytical results to the related DEQ Risk-Based Concentrations (RBCs) for potential residential, occupational, construction worker, and excavation worker receptors; and the DEQ Clean Fill Criteria screening levels. Soil GRO and DRO were not detected at concentrations at or exceeding laboratory method reporting limits (MRLs) in the soil samples analyzed. ORO was detected in soil samples collected from borings B07, B08, B09, and B10 at depths ranging from 5.5 to 16.5 feet bgs. The detected concentrations ranged from 65.1 to 4,310 mg/kg. ORO concentrations exceeding DEQ Risk-Based Concentrations (RBCs) were detected in only the soil sample collected at a depth of 5.5 feet bgs at boring B07 (B07_5-5.5). The concentration of ORO detected in sample B07_5-5.5 exceeded the DEQ RBC for the Soil Ingestion, Dermal Contact, and Inhalation Pathway for residential receptors. DEQ has not established a Clean Fill Criteria screening level for ORO. Soil analytical results for petroleum hydrocarbons are summarized in Table 1. VOCs were not detected at concentrations at or exceeding laboratory MRLs in the soil samples analyzed. Soil analytical results for VOCs are summarized in Table 2. Metals were not detected at concentrations exceeding DEQ RBCs for construction workers and excavation workers, or the Clean Fill Criteria screening levels. Arsenic was detected at a concentration exceeding the DEQ RBC for the Soil Ingestion, Dermal Contact, and Inhalation Pathway for potential residential receptors in the soil sample collected at a depth of 7 feet bgs at boring B02. However, the detected concentration of arsenic was less than the background concentration for arsenic established for the Portland Basin. Soil analytical results for metals are summarized in Table 3. Polychlorinated biphenyls (PCBs) were not detected at concentrations at or exceeding laboratory MRLs, and MRLs were less than DEQ RBCs and Clean Fill Criteria screening levels. Soil analytical results for PCBs are summarized in Table 4. Soil Gas VOCs were not detected in the soil gas samples at concentrations exceeding DEQ RBCs for residential and occupational receptors, and MRLs are less than DEQ RBCs. Soil gas analytical results for VOCs are summarized in Table 5. The laboratory analytical reports are provided in Appendix A. Based on the results from investigations conducted at the Site, Ascend submitted a Notice of Intent to Participate application to DEQ on November 2, 2015, and the Site was entered into the DEQ Environmental Cleanup Site Information (ECSI) Database (ECSI Site No. 6502). The Site was enrolled in the DEQ Voluntary Cleanup Program under the Independent Cleanup Pathway on November 6, 2015, to properly manage impacted subsurface materials during the course of the Site redevelopment activities and ultimately to obtain a No Further Action determination for the Site. The Site conditions, including 3-2 G:\Projects\1380 Ascend Holdings\ Northeast Killingsworth Property\Reports\Soil Management Plan\ Soil Management Plan.docx Q u a l i t y S e r vi ce f o r E n v i r o n m e n t a l So l u t i o n s f a r a l l o nc o n s u l t i n g. c o m

8 the nature and extent of impacted subsurface materials that will require special management during redevelopment, are described in Section G:\Projects\1380 Ascend Holdings\ Northeast Killingsworth Property\Reports\Soil Management Plan\ Soil Management Plan.docx Q u a l i t y S e r vi ce f o r E n v i r o n m e n t a l So l u t i o n s f a r a l l o nc o n s u l t i n g. c o m

9 4.0 SITE CONDITIONS The following Site conditions are based on the findings from the Phase I ESA and Phase II Environmental Assessment (Farallon 2015a, 2015b). 4.1 GEOLOGY AND HYDROGEOLOGY The Site lies within the Portland Basin, which is a structural basin formed by Eocene to Miocene volcanic and marine sedimentary rocks. Immediately overlying the bedrock units throughout the basin are various mudstones, sandstones, and conglomerates. Overlying these older, more consolidated sediments are late Pleistocene sediments that were deposited by alluvial and catastrophic flood events in the basin. The groundwater system in the Portland Basin is recharged principally from precipitation and stream flow. Water also enters the groundwater system in the vicinity of the Site at significant rates from urban runoff into dry wells. Based on Farallon s experience at properties in the vicinity of the Site, groundwater is expected to occur at a depth greater than 60 feet below ground surface. Shallow groundwater flow direction typically can be estimated by examination of surface topography. Based on information obtained from topographic maps and Farallon s understanding of hydrogeologic conditions in the vicinity of the Site, shallow groundwater typically flows to the north toward the Columbia River. 4.2 NATURE AND EXTENT OF IMPACTED SOIL ORO was the only COI detected at concentrations requiring special handling in Site soil. ORO was detected at concentrations both exceeding and less than the DEQ RBC for the Soil Ingestion, Dermal Contact, and Inhalation Pathway for residential receptors Soil with ORO Concentrations Exceeding DEQ RBCs The estimated areal extent of soil with concentrations of ORO exceeding the DEQ RBC for the Soil Ingestion, Dermal Contact, and Inhalation Pathway for residential receptors (Area 1) is shown on Figure 2. The depth at which ORO was detected at concentrations exceeding the DEQ RBC is greater than 3 feet bgs and Area 1 is covered with asphalt. Therefore, based on available data, the exposure pathway for residential receptor populations currently is incomplete and remediation or removal of soil from this area is not warranted under current Site conditions. However, future redevelopment activities may include excavation in Area 1. Soil excavated in Area 1 must be managed to prevent an unacceptable risk to future residents of the Site and comply with DEQ solid waste rules and regulations Soil with ORO Concentrations Less than DEQ RBCs The estimated areal extent of soil with concentrations of ORO less than the DEQ RBCs (Area 2) is shown on Figure 2. Although the concentrations of ORO detected in Area 2 do not present a risk to receptors, if soil in Area 2 is excavated as part of future redevelopment, specialized handling and disposal will be required. 4-1 G:\Projects\1380 Ascend Holdings\ Northeast Killingsworth Property\Reports\Soil Management Plan\ Soil Management Plan.docx Q u a l i t y S e r vi ce f o r E n v i r o n m e n t a l So l u t i o n s f a r a l l o nc o n s u l t i n g. c o m

10 4.3 NATURE AND EXTENT OF SOIL GAS IMPACTS COIs were not detected at concentrations exceeding DEQ RBCs; therefore, the soil gas impacts at the Site do not pose an unacceptable risk to potential receptors during redevelopment activities or to future occupants of the Site. 4.4 NATURE AND EXTENT OF GROUNDWATER IMPACTS Groundwater was not encountered during the Phase II ESA, and is expected to occur at a depth greater than 60 feet bgs at the Site. Anticipated redevelopment activities will not include excavation to a depth near 60 feet bgs; therefore, groundwater is not expected to be encountered during redevelopment activities. 4-2 G:\Projects\1380 Ascend Holdings\ Northeast Killingsworth Property\Reports\Soil Management Plan\ Soil Management Plan.docx Q u a l i t y S e r vi ce f o r E n v i r o n m e n t a l So l u t i o n s f a r a l l o nc o n s u l t i n g. c o m

11 5.0 WORKER SAFETY PROTOCOLS DRO, GRO, VOCs, and PCBs were not detected at concentrations at or exceeding laboratory MRLs in the soil samples analyzed, and ORO and metals were detected at concentrations less than DEQ RBCs for Soil Ingestion, Dermal Contact, and Inhalation for construction and excavation workers in the soil samples analyzed. Therefore, there is no evidence indicating that the presence of COIs in soil at the Site may pose an unacceptable risk to construction and excavation workers. However, ORO and metals are hazardous chemicals as defined by the Occupational Safety and Health Administration (OSHA). The Site owner, operator, or contractor must prepare and implement a Site-specific Hazard Communication Plan (HCP) prior to beginning earthwork activities at the Site, as required by OSHA Hazard Communication Standard, as established in Part of Title 29 of the Code of Federal Regulations (29 CFR ). The HCP fulfills worker right to know requirements (29 CFR ). If the HCP is completed by the contractor, a copy must be submitted to the Site owner prior to the start of work on the project. The HCP must be posted at the Site during earthwork activities. The contractor is responsible for notifying subcontractors of pertinent environmental conditions. Subcontractors may either adopt the HCP completed by the contractor or prepare their own HCPs. The SMP must be used in conjunction with and not in place of the HCP and the project plans and specifications. Each contractor and subcontractor is responsible for the safety of its employees, including compliance with applicable Oregon OSHA regulations and plans and project specifications. In addition to implementation of an HCP, the contractor must prepare and implement a Site-specific Health and Safety Plan (HASP) in accordance with OSHA requirements to ensure adequate protection for workers on the Site. 5-1 G:\Projects\1380 Ascend Holdings\ Northeast Killingsworth Property\Reports\Soil Management Plan\ Soil Management Plan.docx Q u a l i t y S e r vi ce f o r E n v i r o n m e n t a l So l u t i o n s f a r a l l o nc o n s u l t i n g. c o m

12 6.0 SOIL MANAGEMENT This section summarizes the methods to be used to identify, handle, and dispose of ORO impacted soil in Areas 1 and 2. Given the historical use of the Site, other localized areas of impacted soil also may be encountered in other areas of the Site. Therefore, the methods described in this section potentially will apply to all Site soil that is disturbed during redevelopment activities. Prior to beginning work, the contractor should verify that work will be completed in accordance with a Site-specific HASP and the SMP. 6.1 PETROLEUM IMPACTED SOIL IDENTIFICATION Areas 1 and 2 are shown on Figure 2. In the event that suspected petroleum impacted soil outside these areas is encountered by an earthwork contractor or Site workers, excavation activities must stop and the Site owner and/or operator notified. The work area will be secured using barricades or otherwise isolated until it can be verified that additional work can be completed in accordance with the Site-specific HASP and this SMP. After the work area has been secured, the suspected petroleum impacted soil will be field screened in accordance with the field screening procedures provided in Appendix B. The known petroleum impacted soil in Areas 1 and 2 and additional petroleum impacted soil detected based on field screening results will be handled and disposed of as described in Section PETROLEUM IMPACTED SOIL HANDLING At a minimum, the procedures described in this section will be followed when handling and disposing of petroleum impacted soil excavated in Areas 1 and 2 and additional petroleum impacted Site soil identified outside these areas based on field screening results. Additional or more-stringent soil-handling procedures may be established as part of the project plans and specifications Erosion and Dust Control Because exposed soil is susceptible to erosion by wind and water, erosion-control measures should be planned carefully and should be in place before earthwork activities begin. At a minimum, erosion and dust control measures will be implemented in accordance with permits issued pursuant to applicable National Pollutant Discharge Elimination System (NPDES), OAR , OAR , City of Portland, and Multnomah County regulations and other requirements Excavation Area 1 will be excavated to a depth of 6 feet bgs to remove soil with concentrations of ORO exceeding the DEQ RBC for the Soil Ingestion, Dermal Contact, and Inhalation Pathway for residential receptors. Confirmation soil samples will be collected from the excavation sidewalls and field screened in accordance with the field screening procedures provided in Appendix B. The known petroleum impacted soil in Areas 1 and 2 and additional petroleum impacted soil detected based on field screening results will be handled and disposed of as described in Section 6.2. Soil samples will be collected from the excavation sidewalls and bottom and submitted under standard 6-1 G:\Projects\1380 Ascend Holdings\ Northeast Killingsworth Property\Reports\Soil Management Plan\ Soil Management Plan.docx Q u a l i t y S e r vi ce f o r E n v i r o n m e n t a l So l u t i o n s f a r a l l o nc o n s u l t i n g. c o m

13 chain-of-custody protocols to Apex Laboratories of Tigard, Oregon for laboratory analysis for ORO using Northwest Method NWTPH-Dx. Analytical results will be compared with DEQ RBCs. Additional excavation and soil sampling will be performed as necessary to remove soil with concentrations of ORO exceeding DEQ RBCs for residential receptors. Area 2 and the remainder of the Site will be excavated only as necessary for redevelopment (e.g., to install utilities or construct basements). Soil excavated from Areas 1 and 2 will be loaded into separate roll-off boxes or staged in separate temporary stockpiles in accordance with Section Additional petroleum impacted soil identified based on field screening will be transferred to the Area 1 or 2 roll-off boxes or stockpiles based on the severity of impacts detected by field screening methods Stockpiling Petroleum impacted soil that is placed in temporary stockpiles will be well maintained at all times. Stockpiled soil must be placed on impermeable plastic sheeting a minimum of 6 mils thick, with a berm at the perimeter of the stockpile to prevent runoff of stockpiled soil contaminants to surrounding areas. The berm may be constructed with hay bales or an equivalent method, as established in the plans and specifications for the project. The plastic sheeting beneath the stockpile should be lapped over the berm materials, and the soil stockpile within the berm should be covered with plastic sheeting to prevent erosion or leaching of soil stockpile contaminants, impacting underlying soil. The upper plastic sheeting covering the soil stockpile should be secured using sand bags or equivalent. The upper plastic sheeting should prevent the stockpiled soil from being exposed to precipitation and wind Characterization Soil from the Area 1 roll-off box or stockpile will be disposed of at a solid waste landfill as described in Section 6.3. Soil from the Area 2 roll-off box or stockpile will be sampled to determine if the soil can be re-used on or off the Site as fill. A minimum of three soil samples will be collected from the Area 2 roll-off box or stockpile for the first 100 cubic yards of soil. Two additional soil samples will be collected from the Area 2 roll-off box or stockpile if the excavated soil volume is between 101 and 500 cubic yards. It is anticipated that the Area 2 excavated soil volume will not exceed 500 cubic yards. Soil samples collected from the Area 2 roll-off box or stockpile will be analyzed for ORO using Northwest Method NWTPH-Dx. Sampling results will be screened against the DEQ RBCs for residential receptors. If the concentrations of ORO are less than the DEQ RBCs for residential receptors, then the soil in the Area 2 roll-off box or stockpile may be re-used on the Site as backfill. If the concentrations of ORO are equal to or greater than the DEQ RBCs for residential receptors, then the soil in the Area 2 roll-off box or stockpile may be disposed of at a solid waste landfill as described in Section TRANSPORTATION AND DISPOSAL As soon as practicable, the petroleum impacted soil must be transported to and disposed of at an approved landfill in accordance with applicable requirements of OAR Chapter 340, Division 093, Section 6.3.3, Transportation. The contractor must exercise care during the loading of petroleum impacted soil to minimize spillage of soil onto the ground surface. Trucks leaving the Site must be examined to ensure that truck exteriors carry no loose soil. Soil loaded into trucks must be 6-2 G:\Projects\1380 Ascend Holdings\ Northeast Killingsworth Property\Reports\Soil Management Plan\ Soil Management Plan.docx Q u a l i t y S e r vi ce f o r E n v i r o n m e n t a l So l u t i o n s f a r a l l o nc o n s u l t i n g. c o m

14 covered if dry, warm, or windy weather conditions could cause soil to blow out during transport to the disposal facility. The contractor should avoid handling, loading, or transporting contaminated soil during periods of wet weather, if possible. The contractor must use care to not track soil onto roads. Trucks should not be allowed to leave the Site if liquids are draining from loads. Transport-tracking tickets should be required to document each truck leaving the Site and its trip to the approved disposal facility. Petroleum impacted soil will be disposed of only at a solid waste landfill authorized by OAR Chapter 340, Division 093, Section 6.3.4, Landfill Disposal and DEQ to receive this type of material, unless DEQ approves an alternate disposal location. The contractor will coordinate characterization, transportation, and disposal requirements with the appropriate landfill identified. The Site contractor, owner, or operator will maintain all records and/or receipts associated with the final disposition of petroleum impacted soil that is encountered during future earthwork activities. These records and receipts should be kept on file with facility records. 6-3 G:\Projects\1380 Ascend Holdings\ Northeast Killingsworth Property\Reports\Soil Management Plan\ Soil Management Plan.docx Q u a l i t y S e r vi ce f o r E n v i r o n m e n t a l So l u t i o n s f a r a l l o nc o n s u l t i n g. c o m

15 7.0 GENERAL LIMITATIONS The conclusions contained in this report/assessment are based on professional opinions with regard to the subject matter. These opinions have been arrived at in accordance with currently accepted hydrogeologic and engineering standards and practices applicable to this location. The conclusions contained herein are subject to the following inherent limitations: Accuracy of Information. Farallon obtained, reviewed, and evaluated certain information used in this report/assessment from sources that were believed to be reliable. Farallon s conclusions, opinions, and recommendations are based in part on such information. Farallon s services did not include verification of its accuracy or authenticity. Should the information upon which Farallon relied prove to be inaccurate or unreliable, Farallon reserves the right to amend or revise its conclusions, opinions, and/or recommendations. Reconnaissance and/or Characterization. Farallon performed a reconnaissance and/or characterization of the Site that is the subject of this report/assessment to document current conditions. Farallon focused on areas deemed more likely to exhibit hazardous materials conditions. Contamination may exist in other areas of the Site that were not investigated or were inaccessible. Site activities beyond Farallon s control could change at any time after the completion of this report/assessment. For the foregoing reasons, Farallon cannot and does not warrant or guarantee that the Site is free of hazardous or potentially hazardous substances or conditions, or that latent or undiscovered conditions will not become evident in the future. Farallon s observations, findings, and opinions can be considered valid only as of the date of the report hereof. This plan has been prepared in accordance with the contract for services between Farallon and Ascend Holdings, Inc. No other warranties, representations, or certifications are made. Reliance by third parties is prohibited. Any use, interpretation, or reliance upon this report/assessment by anyone other than Ascend Holdings, Inc. is at the sole risk of that party, and Farallon will have no liability for such unauthorized use, interpretation, or reliance. 7-1 G:\Projects\1380 Ascend Holdings\ Northeast Killingsworth Property\Reports\Soil Management Plan\ Soil Management Plan.docx Q u a l i t y S e r vi ce f o r E n v i r o n m e n t a l So l u t i o n s f a r a l l o nc o n s u l t i n g. c o m

16 8.0 REFERENCES Farallon Consulting, L.L.C. 2015a. Phase I Environmental Site Assessment Report, Northeast Killingsworth Property, 3009 Northeast Killingsworth Street, Portland, Oregon. Prepared for Ascend Holdings Inc., Vancouver, Washington. May b. Phase II Environmental Site Assessment, Northeast Killingsworth Property, 3009 Northeast Killingsworth Street, Portland, Oregon. Prepared for Ascend Holdings Inc., Vancouver, Washington. June 9. Oregon Department of Environmental Quality (DEQ) Background Levels of Metals in Soil for Cleanups. Fact Sheet. March G:\Projects\1380 Ascend Holdings\ Northeast Killingsworth Property\Reports\Soil Management Plan\ Soil Management Plan.docx Q u a l i t y S e r vi ce f o r E n v i r o n m e n t a l So l u t i o n s f a r a l l o nc o n s u l t i n g. c o m

17 FIGURES SOIL MANAGEMENT PLAN Northeast Killingsworth Property 3009 Northeast Killingsworth Street Portland, Oregon Farallon PN: G:\Projects\1380 Ascend Holdings\ Northeast Killingsworth Property\Reports\Soil Management Plan\ Soil Management Plan.docx

18 SITE LOCATION ³ Source: USGS 100k series, Vancouver, OR Date: 1975 Washington Issaquah Bellingham Seattle Oregon Portland Bend Baker City Farallon CONSULTING California Oakland Sacramento Irvine Quality Service for Environmental Solutions farallonconsulting.com Drawn By: pgarvin Checked By: CWW FIGURE 1 SITE VICINITY MAP NORTHEAST KILLINGSWORTH PROPERTY 3009 NORTHEAST KILLINGSWORTH STREET PORTLAND, OREGON FARALLON PN: Date: 10/25/2015 Disc Reference: Document Path: G:\Projects\1380 Ascend Holdings\ Northeast Killingsworth Property\GIS\1380_002_Figure_1B.mxd

19 RESIDENTIAL!A SG2 CANOPY POSSIBLE FORMER LOCATION OF WHITE GAS UST NORTHEAST 30TH AVENUE B14!! B15! B12 B13 J!!!A SERVICE BAYS B02 SG1 B11!! B01 REPORTED FORMER LOCATION OF WASTE OIL UST REPORTED FORMER LOCATION OF GASOLINE AND DIESEL USTs OFFICE B09!!A! SG3 B08 SG4!A RESIDENTIAL B07!! B10 OVERHANG PUMP ISLAND! B04! B03! B05! B06 NORTHEAST KILLINGSWORTH STREET Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community LEGEND APPROXIMATE SITE BOUNDARY ESTIMATED EXTENT OF PETROLEUM-IMPACTED SOIL EXCEEDING RBCs (AREA 1) ESTIMATED EXTENT OF PETROLEUM-IMPACTED SOIL LESS THAN RBCs (AREA 2)! SOIL SAMPLING LOCATION!A SOIL GAS SAMPLING LOCATION J CATCH BASIN INFERRED SANITARY SEWER LOCATION ³ 0 25 Scale in feet Farallon CONSULTING Washington Issaquah Bellingham Seattle Oregon Portland Bend Baker City California Oakland Sacramento Irvine Quality Service for Environmental Solutions farallonconsulting.com Drawn By: pgarvin FIGURE 2 SITE PLAN WITH SAMPLING LOCATIONS NORTHEAST KILLINGSWORTH PROPERTY 3009 NORTHEAST KILLINGSWORTH STREET PORTLAND, OREGON FARALLON PN: Checked By: MH Date: 3/7/2016 Disc Reference: MXD Document Path: G:\Projects\1380 Ascend Holdings\ Northeast Killingsworth Property\GIS\1380_002_Figure_3_smp2.mxd

20 TABLES SOIL MANAGEMENT PLAN Northeast Killingsworth Property 3009 Northeast Killingsworth Street Portland, Oregon Farallon PN: G:\Projects\1380 Ascend Holdings\ Northeast Killingsworth Property\Reports\Soil Management Plan\ Soil Management Plan.docx

21 Table 1 Soil Analytical Results Petroleum Hydrocarbons Northeast Killingsworth Property Portland, Oregon Farallon PN: Analytical Results (milligrams per kilogram) 2 Sample Sample Sample Sample Identification Location Date Depth 1 DRO ORO GRO B01_7-7.5 B01 04/13/ <53.4 <107 <4.99 B02_7-7.5 B02 04/13/ <49.8 <99.7 <4.85 B03_6-6.5 B03 04/13/ <53.6 <107 <21.5 B04_6-6.5 B04 04/13/ <52.7 <105 <21.1 B05_ B05 04/13/ <51.7 <103 <20.7 B06_6-6.5 B06 04/13/ < <20.7 B06_ B06 04/13/ <25.0 <50 NA B07_5-5.5 B07 04/13/ <925 4,310 <985 B07_ B07 04/13/ < NA B08_5-5.5 B08 04/14/ < <21.5 B08_ B08 04/14/ <25.0 <50 NA B09_5-5.5 B09 04/14/ < <22.2 B09_ B09 04/14/ < NA B10_5-5.5 B10 04/14/ < <106 B10_ B10 04/14/15 24 <25.0 <50 NA B11_6-6.5 B11 04/14/ <52.8 <106 <4.94 B12_6-6.5 B12 04/14/ <52.6 <105 <21.0 B14_6-6.5 B14 04/14/ <54.1 <102 <21.6 B15_6-6.5 B15 04/14/ <50.9 <102 <20.3 3,4 DEQ RBC ss Residential DEQ RBC 3,4 ss Occupational 3,4 DEQ RBC ss Construction Worker 3,4 DEQ RBC ss Excavation Worker DEQ Clean Fill Value 5 NOTES: 1,100 2,800 1,200 14,000 36,000 20,000 4,600 11,000 9,700 >Max >Max >Max NE NE NE > Max = The constituent risk-based concentration for this pathway DRO = total petroleum hydrocarbons as diesel-range organics is calculated as greater than 1,000,000 milligrams per kilogram or 1,000,000 milligrams per liter; therefore, this substance is deemed not to pose a risk in this scenario. GRO= total petroleum hydrocarbons as gasoline-range organics NA = Not analyzed NE = Not established < denotes analyte not detected at or exceeding the reporting limit listed. ORO = total petroleum hydrocarbons as oil-range organics 1 Depth in feet below ground surface. RBC = risk-based concentration 2 Analyzed by Northwest Methods NWTPH-HCID, NWTPH-Dx, and NWTPH-Gx. 3 RBCs are from RBC ss = RBC for the Soil Ingestion, Dermal Contact, and Inhalation Pathway 4 RBC is the lowest RBC for this exposure pathway. 5 DEQ Clean Fill Screening Table for Upland Use, State of Oregon, Portland Basin, dated July 23, of 1 G:\Projects\1380 Ascend Holdings\ Northeast Killingsworth Property\Reports\Soil Management Plan\Tables\SMP Tables

22 Table 2 Soil Analytical Results VOCs Northeast Killingsworth Property Portland, Oregon Farallon PN: Analytical Results (micrograms per kilogram) 2 Sample Sample Sample Sample Identification Location Date Depth 1 PCE TCE 1,1-DCE cis-1,2-dce trans-1,2-dce Vinyl Chloride B01_7-7.5 B01 4/14/ <24.9 <24.9 <24.9 <24.9 <24.9 <24.9 B02_7-7.5 B02 4/14/ <24.2 <24.2 <24.2 <24.2 <24.2 <24.2 B11_6-6.5 B11 4/14/ <24.7 <24.7 <24.7 <24.7 <24.7 <24.7 3,4 DEQ RBC si Residential 2, ,000 > Max 16, DEQ RBC ss 3,4 Occupational 3,4 DEQ RBC ss Construction Worker 3,4 DEQ RBC ss Excavation Worker DEQ Clean Fill Value 5 1,000,000 51,000 29,000,000 2,300,000 23,000,000 44,000 1,600,000 6,400 1,800, , ,000 34,000 44,000,000 14, , ,000 2, ,000 1,200 2, NOTES: < denotes analyte not detected at or exceeding the reporting limit listed. DCE = dichloroethene - denotes RBC not developed by DEQ. DEQ = Oregon Department of Environmental Quality 1 Depth in feet below ground surface. PCE = tetrachloroethene 2 Analyzed by U.S. Environmental Protection Agency Method 8260B. RBC = risk-based concentration 3 RBCs are from RBC si = RBC for the Vapor Intrusion into Buildings pathway. 4 RBC is the lowest RBC for this exposure pathway. RBC ss = RBC for the Soil Ingestion, Dermal Contact, and Inhalation pathway. > Max = The constituent RBC for this pathway TCE = trichloroethene is calculated as greater than 1,000,000 milligrams per kilogram or 1,000,000 milligrams per liter; therefore, this substance is deemed not to pose a risk in this scenario. 5 DEQ Clean Fill Screening Table for Upland Use, State of Oregon, Portland Basin, dated July 23, VOCs = volatile organic compounds G:\Projects\1380 Ascend Holdings\ Northeast Killingsworth Property\Reports\Soil Management Plan\Tables\SMP Tables 1 of 1

23 Table 3 Soil Analytical Results Metals Northeast Killingsworth Property Portland, Oregon Farallon PN: Analytical Results (milligrams per kilogram) 2 Sample Sample Sample Sample Identification Location Date Depth 1 Arsenic Barium Cadmium Chromium (III) Lead Mercury Selenium Silver B01_7-7.5 B01 4/14/ < < <2.34 <.0234 B01_ B01 4/14/ < < <2.15 <.0215 B02_7-7.5 B02 4/14/ < <2.17 <.0217 B02_ B02 4/14/ < < <2.11 <.0211 Background Concentrations DEQ Clean Fill Value 4 NE NE NE NE NE NE NE 4.2 DEQ RBC 5 ss Residential , NE 390 DEQ RBC 3,4 ss Occupational ,000 1,100 > Max NE 5,800 5 DEQ RBC ss Construction Worker 15 69, , NE 1,800 5 DEQ RBC ss Excavation Worker 420 > Max 9,700 > Max 800 2,900 NE 49,000 NOTES: < denotes analyte not detected at or exceeding the reporting limit listed. DEQ = Oregon Department of Environmental Quality > Max = The constituent risk-based concentration for this pathway is calculated as greater than 1,000,000 milligrams per kilogram RBC = risk-based concentration or 1,000,000 milligrams per liter; therefore, this substance is deemed not to pose a risk in this scenario. RBC ss = RBC for the Soil Ingestion, Dermal Contact, and Inhalation pathway 1 Depth in feet below ground surface. NE = not established 2 Analyzed by U.S. Environmental Protection Agency Method 8260B. 3 Background concentrations for the Portland Basin physiographic province from the DEQ guidance document Development of Oregon Background Metals Concentrations in Soil. 4 DEQ Clean Fill Screening Table for Upland Use, State of Oregon, Portland Basin, dated July 23, RBCs are from G:\Projects\1380 Ascend Holdings\ Northeast Killingsworth Property\Reports\Soil Management Plan\Tables\SMP Tables 1 of 1

24 Table 4 Soil Analytical Results PCBs Northeast Killingsworth Property Portland, Oregon Farallon PN: Analytical Results (micrograms per kilogram) 2 Sample Sample Sample Aroclor Aroclor Aroclor Aroclor Aroclor Aroclor Aroclor Sample Identification Location Date Depth B01_7-7.5 B01 4/14/ <10.4 <10.4 <10.4 <10.4 <10.4 <10.4 <10.4 B01_ B01 4/14/ <10.2 <10.2 <10.2 <10.2 <10.2 <10.2 <10.2 B02_7-7.5 B02 4/14/ <9.90 <9.90 <9.90 <9.90 <9.90 <9.90 <9.90 B02_ B02 4/14/ <10.4 <10.4 <10.4 <10.4 <10.4 <10.4 <10.4 DEQ Clean Fill Value 4 DEQ RBC 5 ss Residential DEQ RBC ss 5 Occupational 5 DEQ RBC ss Construction Worker 5 DEQ RBC ss Excavation Worker ,900 4,900 4,900 4,900 4,900 4,900 4, , , , , , , ,000 NOTES: < denotes analyte not detected at or exceeding the reporting limit listed. DEQ = Oregon Department of Environmental Quality 1 Depth in feet below ground surface. PCBs = polychlorinated biphenyls 2 Analyzed by U.S. Environmental Protection Agency Method 8082A. RBC = risk-based concentration 3 RBCs are from RBC ss = RBC for the Soil Ingestion, Dermal Contact, and Inhalation pathway 4 DEQ Clean Fill Screening value fot total PCBs. From: Table for Upland Use, State of Oregon, Portland Basin, dated July 23, RBCs are from RBCs are for total PCBs. G:\Projects\1380 Ascend Holdings\ Northeast Killingsworth Property\Reports\Soil Management Plan\Tables\SMP Tables 1 of 1

25 Table 5 Soil Gas Analytical Results VOCs Northeast Killingsworth Property Portland, Oregon Farallon PN: Analytical Results (micrograms per kilogram) 2 Sample Sample Sample Sample 2-Butanone Identification Location Date Depth 1 Benzene 1,3-Butadiene Toluene (Methyl Ethyl Ketone) Ethanol Acetone 2-Propanol o-xylene m,p-xylene Other VOCs SG1_ SG1 4/14/ <3.9 <2.7 <4.6 <14 <9.2 <29 <12 <5.3 <5.3 <MRLs SG2_ SG2 4/14/ <12 <5.1 <5.1 <MRLs SG3_ SG3 4/14/ < <5.6 <5.6 <MRLs SG4_ SG4 4/14/ < <MRLs DEQ RBC si Residential 3 DEQ RBC si Occupational 3 62 NA 1,000,000 NA NA NA NA 21,000 21,000 Varies 1,600 NA 21,900,000 NA NA NA NA 440, ,000 Varies NOTES: < denotes analyte not detected at or exceeding the reporting limit listed. DEQ = Oregon Department of Environmental Quality 1 Depth in feet below ground surface. MRLs = method reporting limits 2 Analyzed by U.S. Environmental Protection Agency Method TO-15. NA = not applicable 3 RBCs are from RBC = risk-based concentration RBC si = RBC for the Vapor Intrusion into Buildings pathway VOCs = volatile organic compounds 432 G:\Projects\1380 Ascend Holdings\ Northeast Killingsworth Property\Reports\Soil Management Plan\Tables\SMP Tables 1 of 1

26 APPENDIX A LABORATORY ANALYTICAL REPORTS SOIL MANAGEMENT PLAN Northeast Killingsworth Property 3009 Northeast Killingsworth Street Portland, Oregon Farallon PN: G:\Projects\1380 Ascend Holdings\ Northeast Killingsworth Property\Reports\Soil Management Plan\ Soil Management Plan.docx

27 4/28/2015 Mr. Paul Garvin Farallon Consulting, LLC 4380 Macadam Suite 500 Portland CA Project Name: Phase II ESA Project #: Workorder #: Dear Mr. Paul Garvin The following report includes the data for the above referenced project for sample(s) received on 4/16/2015 at Air Toxics Ltd. The data and associated QC analyzed by TO-15 are compliant with the project requirements or laboratory criteria with the exception of the deviations noted in the attached case narrative. Thank you for choosing Air Toxics Ltd. for your air analysis needs. Air Toxics Ltd. is committed to providing accurate data of the highest quality. Please feel free to contact the Project Manager: Kelly Buettner at if you have any questions regarding the data in this report. Regards, Kelly Buettner Project Manager Page 1 of 21

28 WORK ORDER #: Work Order Summary CLIENT: PHONE: FAX: Mr. Paul Garvin Farallon Consulting, LLC 4380 Macadam Suite 500 Portland, CA DATE RECEIVED: 04/16/2015 DATE COMPLETED: 04/28/2015 BILL TO: PROJECT # CONTACT: Accounts Payable Farallon Consulting, LLC 975 Fifth Avenue NW Issaquah, WA P.O. # Phase II ESA Kelly Buettner RECEIPT FRACTION # NAME TEST VAC./PRES. FINAL PRESSURE 01A SG1_ TO Hg 15.3 psi 02A SG2_ TO Hg 15.2 psi 03A SG3_ TO Hg 15.2 psi 04A SG4_ TO Hg 14.6 psi 05A Lab Blank TO-15 NA NA 06A CCV TO-15 NA NA 07A LCS TO-15 NA NA 07AA LCSD TO-15 NA NA CERTIFIED BY: DATE: 04/28/15 Technical Director Certification numbers: AZ Licensure AZ0775, NJ NELAP - CA016, NY NELAP , TX NELAP - T , UT NELAP CA , VA NELAP , WA NELAP - C935 Name of Accreditation Body: NELAP/ORELAP (Oregon Environmental Laboratory Accreditation Program) Accreditation number: CA300005, Effective date: 10/18/2014, Expiration date: 10/17/2015. Eurofins Air Toxics Inc.. certifies that the test results contained in this report meet all requirements of the NELAC standards This report shall not be reproduced, except in full, without the written approval of Eurofins Air Toxics, Inc. 180 BLUE RAVINE ROAD, SUITE B FOLSOM, CA (916) (800) FAX (916) Page 2 of 21

29 LABORATORY NARRATIVE EPA Method TO-15 Farallon Consulting, LLC Workorder# Four 1 Liter Summa Canister samples were received on April 16, The laboratory performed analysis via EPA Method TO-15 using GC/MS in the full scan mode. This workorder was independently validated prior to submittal using 'USEPA National Functional Guidelines' as generally applied to the analysis of volatile organic compounds in air. A rules-based, logic driven, independent validation engine was employed to assess completeness, evaluate pass/fail of relevant project quality control requirements and verification of all quantified amounts. Receiving Notes There were no receiving discrepancies. Analytical Notes There were no analytical discrepancies. Definition of Data Qualifying Flags Eight qualifiers may have been used on the data analysis sheets and indicates as follows: B - Compound present in laboratory blank greater than reporting limit (background subtraction not performed). J - Estimated value. E - Exceeds instrument calibration range. S - Saturated peak. Q - Exceeds quality control limits. U - Compound analyzed for but not detected above the reporting limit, LOD, or MDL value. See data page for project specific U-flag definition. UJ- Non-detected compound associated with low bias in the CCV N - The identification is based on presumptive evidence. File extensions may have been used on the data analysis sheets and indicates as follows: a-file was requantified b-file was quantified by a second column and detector r1-file was requantified for the purpose of reissue Page 3 of 21

30 Summary of Detected Compounds EPA METHOD TO-15 GC/MS FULL SCAN Client Sample ID: SG1_ Lab ID#: A No Detections Were Found. Client Sample ID: SG2_ Lab ID#: A Compound 1,3-Butadiene Ethanol Acetone 2-Butanone (Methyl Ethyl Ketone) Benzene Toluene Rpt. Limit Amount Rpt. Limit Amount (ppbv) (ppbv) (ug/m3) (ug/m3) Client Sample ID: SG3_ Lab ID#: A Compound 1,3-Butadiene Ethanol Acetone 2-Propanol 2-Butanone (Methyl Ethyl Ketone) Toluene Rpt. Limit Amount Rpt. Limit Amount (ppbv) (ppbv) (ug/m3) (ug/m3) Client Sample ID: SG4_ Lab ID#: A Compound 1,3-Butadiene Ethanol Acetone 2-Propanol Benzene Toluene Rpt. Limit Amount Rpt. Limit Amount (ppbv) (ppbv) (ug/m3) (ug/m3) Page 4 of 21

31 Summary of Detected Compounds EPA METHOD TO-15 GC/MS FULL SCAN Client Sample ID: SG4_ Lab ID#: A m,p-xylene o-xylene Page 5 of 21

32 File Name: v Dil. Factor: 2.44 Compound Freon 12 Freon 114 Chloromethane Vinyl Chloride 1,3-Butadiene Bromomethane Chloroethane Freon 11 Ethanol Freon 113 1,1-Dichloroethene Acetone 2-Propanol Carbon Disulfide 3-Chloropropene Methylene Chloride Methyl tert-butyl ether trans-1,2-dichloroethene Hexane 1,1-Dichloroethane 2-Butanone (Methyl Ethyl Ketone) cis-1,2-dichloroethene Tetrahydrofuran Chloroform 1,1,1-Trichloroethane Cyclohexane Carbon Tetrachloride 2,2,4-Trimethylpentane Benzene 1,2-Dichloroethane Heptane Trichloroethene 1,2-Dichloropropane 1,4-Dioxane Bromodichloromethane cis-1,3-dichloropropene 4-Methyl-2-pentanone Toluene trans-1,3-dichloropropene 1,1,2-Trichloroethane Tetrachloroethene 2-Hexanone Client Sample ID: SG1_ Lab ID#: A EPA METHOD TO-15 GC/MS FULL SCAN Rpt. Limit (ppbv) Amount (ppbv) Date of Collection: 4/14/15 4:02:00 PM Date of Analysis: 4/21/15 02:14 PM Rpt. Limit (ug/m3) Amount (ug/m3) 1.2 Not Detected 6.0 Not Detected 1.2 Not Detected 8.5 Not Detected 12 Not Detected 25 Not Detected 1.2 Not Detected 3.1 Not Detected 1.2 Not Detected 2.7 Not Detected 12 Not Detected 47 Not Detected 4.9 Not Detected 13 Not Detected 1.2 Not Detected 6.8 Not Detected 4.9 Not Detected 9.2 Not Detected 1.2 Not Detected 9.4 Not Detected 1.2 Not Detected 4.8 Not Detected 12 Not Detected 29 Not Detected 4.9 Not Detected 12 Not Detected 4.9 Not Detected 15 Not Detected 4.9 Not Detected 15 Not Detected 12 Not Detected 42 Not Detected 1.2 Not Detected 4.4 Not Detected 1.2 Not Detected 4.8 Not Detected 1.2 Not Detected 4.3 Not Detected 1.2 Not Detected 4.9 Not Detected 4.9 Not Detected 14 Not Detected 1.2 Not Detected 4.8 Not Detected 1.2 Not Detected 3.6 Not Detected 1.2 Not Detected 6.0 Not Detected 1.2 Not Detected 6.6 Not Detected 1.2 Not Detected 4.2 Not Detected 1.2 Not Detected 7.7 Not Detected 1.2 Not Detected 5.7 Not Detected 1.2 Not Detected 3.9 Not Detected 1.2 Not Detected 4.9 Not Detected 1.2 Not Detected 5.0 Not Detected 1.2 Not Detected 6.6 Not Detected 1.2 Not Detected 5.6 Not Detected 4.9 Not Detected 18 Not Detected 1.2 Not Detected 8.2 Not Detected 1.2 Not Detected 5.5 Not Detected 1.2 Not Detected 5.0 Not Detected 1.2 Not Detected 4.6 Not Detected 1.2 Not Detected 5.5 Not Detected 1.2 Not Detected 6.6 Not Detected 1.2 Not Detected 8.3 Not Detected 4.9 Not Detected 20 Not Detected Page 6 of 21