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1 Engineering Management Support, Inc. Memorandum To: Dania Zinner, EPA RPM, VB/I70 Superfund Site From: Timothy C. Shangraw Date: August 16, 2017 Re: POLREP #25 - 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 #25) 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 July 1 through 31, 2017 during which time, the following activities occurred: Excavation of Regulated Asbestos-Contaminated Soils (RACS) and hauling to the Denver Arapahoe Disposal Site (DADS) for disposal; Excavation of non-regulated Asbestos-Contaminated Soils (non-racs) and stockpiling it for future use onsite; Construction of concrete box conduits in the Coliseum Parking Lot (CPL); Pumping and treatment of water from dewatering zones 2, 3a, and 3b; Construction of the drop inlet structure and reinforced box conduits (RBCs) in dewatering zone 2 (beneath Delgany sanitary sewer); Construction of the lateral drain box in dewatering zone 3a; and On-site and off-site monitoring for air quality and odors. The volumes of RACS and non-racs soil excavated and managed, and the volumes of water pumped, treated, and returned to the South Platte River, are summarized in Table 1. On-site monitoring for volatile organic compounds (including methane), odor, and visible dust emissions occurred continuously during excavation and drilling activities. In addition, monitoring for airborne asbestos fibers proceeded in accordance with Section 5.5 of the Colorado

2 Memorandum POLREP #25 VB/I70, OU2 removal Action August 16, 2017 Page 2 Department of Public Health and Environment (CDPHE) Solid Waste Regulations. 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. Results were all below Occupational Safety and Health Administration 8-hour limits and National Ambient Air Quality Standards. Monthly monitoring report 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), which is comprised of representatives from EPA, CDPHE, City and County of Denver, and community members, held its fifth meeting on July 18 th. Meeting minutes are posted on the VB/I-70 Superfund Community Advisory Group web site. The next CAG meeting is scheduled for August 8 th. The following project meetings were held in July: Weekly GLO Project Status Meetings (July 6, 13, 20, and 27, 2017); and EPA monthly status meeting (July 12, 2017). Lastly, a 3-week look-ahead Construction Schedule is attached to this POLREP. Section III Issues, Resolutions, and Planned Activities A Quality Assurance Audit was performed on Asbestos-Containing Soils Daily Reports (ACSRs) prepared by Kleinfelder during the month of June for consistency with Section 5.5 of Colorado s Solid Waste Regulations (CSWRs) and the Final Materials Management Plan (MMP) (EMSI, 2016). No deficiencies were noted. A copy of this 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 except for the Whole Effluent Toxicity (WET) test. WET testing is required on a quarterly basis, so the WET test for second quarter 2017 was performed in June. This test is designed to provide dose-response information, expressed as the percent effluent concentration that is lethal to 50% of the test organisms (LC50) within the prescribed period of time (48 hr and 96 hr for two different aquatic species), or the highest effluent concentration in which survival is not statistically significantly different from the control. Notification of the initial WET test failures, as well as implementation of the Automatic Compliance Response Accelerated Testing, were performed in accordance with Sections 2.b and 2.c.i, respectively, of the Discharge Permit, and are

3 Memorandum POLREP #25 VB/I70, OU2 removal Action August 16, 2017 Page 3 attached to this POLREP. Details of the Initial and Accelerated WET testing efforts are described below. The Initial test, performed on a sample collected on June 15th, failed the LC50 48 Hr Acute test for Ceriodaphnia dubia and LC50 96 Hr Acute test for Fathead Minnow (see SeaCrestGroup June 27, 2017 Report for Acute Biomonitoring Tests, Sample Description B). As soon as the plant operator learned of the failure on June 19 th, he implemented the Automatic Compliance Response Accelerated Testing pursuant to Section 2.c.i of the Discharge Permit. On June 21 st, three more WET test samples were collected to determine where the toxicity was coming from. They were analyzed for the 48 Hr Acute test for Ceriodaphnia dubia, which is the more sensitive of the two aquatic species. The three samples tested consisted of: 1. Treated GLO dewatering water prior to blending with potable water (see SeaCrestGroup June 29, 2017 Report for B-UB Outfall Screen, Sample Description B); 2. Potable water from the Denver Water Department (DWD) used for blending treated GLO dewatering water (see SeaCrestGroup June 29, 2017 Report for Denver Water Screen, Sample Description B); and 3. Treated GLO dewatering water after blending with DWD potable water (see SeaCrestGroup June 29, 2017 Report for Accelerated #1 Acute Biomonitoring Test, Sample Description B); The first sample passed, while the second and third did not, indicating the source of the failures was related to the DWD potable water. McDonald Farms Enterprises, Inc. (MFEI) in the meantime purchased a Reverse Osmosis (RO) system for use in place of DWD potable water. A process control sample of RO permeate was collected on June 26 th and tested for the 48 Hr Acute test for Ceriodaphnia dubia (see SeaCrestGroup July 11, 2017 Report for Process Control Water Screen, Sample Description B). It passed. MFEI then switched over to blend treated GLO water with RO permeate. Samples of RO-blended effluent were collected on July 6 th and 11 th and tested for the 48 Hr Acute test for Ceriodaphnia dubia (see SeaCrestGroup July 14, 2017 Report for Accelerated Test #2, Sample Description B and SeaCrestGroup July 18, 2017 Report for Accelerated Test #3, Sample Description B). Both samples passed. MFEI has been blending treated GLO dewatering water with RO permeate ever since. Planned activities for the next reporting period consist of: Continued installation of sheet piling/wick wells for construction dewatering; Continued installation of concrete box conduits in the CPL; Continued installation of the inlet drop structure and RBC conduits in the GLP; Continued dewatering in zones 2 and 3a; and

4 Memorandum POLREP #25 VB/I70, OU2 removal Action August 16, 2017 Page 4 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 August 16 th at 9:00 in the Webb building. Please call Jennifer Luthi ( ) or me ( ) if you have any questions. Attachments: July 2017 Summary of GLO Construction Activities 3-Week Look-Ahead Schedule QA Audit Report #3 WET Testing Analytical Results

5 Table 1: Summary Construction Report for July 2017 Current Month QTY QTY to date Comments EXCAVATION/HAULING # of days Excavation occurred Globeville park 8 70 # of days Excavation occurred Municipal Landfill 31 Volume of Racs Excavated (CY) 6,314 69,409 From Globeville Park and Coliseum Parking lot Volume of Racs hauled to DADS (CY) 6,314 69,409 From Globeville Park and Coliseum Parking lot Volume of Non-Racs Excavated (CY) ,049 Volume of Non-Racs stockpiled onsite (CY) 500 9,400 Claystone from drop inlet stockpiled for reuse Volume of Non-Racs hauled to DADS (CY) 45,649 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 Volume of water transported to and treated at MFEI 4,412,700 13,347,300 Volume of treated water, including dilution, discharged to S. Platte 4,464,000 14,699,400 Analytical results 0 JuneDMR submitted 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

6 Globeville Phase 1A Schedule Title Current Week Phase 1A 3 week schedule Monday, July 31, 2017 Item Activity Description Work performed by Start Finish Shift Current Forecast Forecast Forecast Comments 07/31 07/31 08/01 08/01 08/02 08/02 08/03 08/03 08/04 08/04 08/05 08/05 08/06 08/06 08/07 08/07 08/08 08/08 08/09 08/09 08/10 08/10 08/11 08/11 08/12 08/12 08/13 08/13 08/14 08/14 08/15 08/15 08/16 08/16 08/17 08/17 08/18 08/18 08/19 08/19 08/20 08/20 08/21 08/21 08/22 08/22 08/23 08/23 08/24 08/24 08/25 08/25 08/26 08/26 08/27 08/27 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 PROJECT MANAGEMENT 2 Pre-Activity Park and Coliseum walls Ames 08/07/17 08/07/17 day brighton office 1:00pm GLOBEVILLE LANDING PARK 6 EARTHWORK Install Sheet Pile for Dewatering Ames day Pending 7 7 DROP INLET 8 F/R/P Drop inlet deck Ames Pending orific plate approval 9 Backfill drop inlet to bottom of Lateral drain box Ames 08/02/17 08/04/17 day pending strength S. LATERAL DRAIN BOX 12 F/S S. Lateral drain box footing sections 3 & 4 Ames Pending sheet pile installation 13 PRECAST RCB 14 Backfill/ shoring baggy wall Ames 07/28/17 08/03/17 day 15 Remove Plug Ames 08/04/17 08/04/17 day 16 Switch bypass pumping Ames/Rain for rent 08/07/17 08/11/17 day 17 Excavate/remove Brick Pipe Ames 08/12/17 08/17/17 day 18 Excavate West Precast RCB sections 1-13 Ames 08/17/17 08/31/17 day 19 EAST PARK WALL 20 Finegrade East park wall (sta xx to xx) Ames Pending sheet pile installation 21 F/R/P Footings Ames COLISEUM PARKING LOT 24 COLISEUM CONDUIT 25 Form/Rebar/stripping CIP Deck Ames 06/12/17 08/26/17 day 26 Deck pour # 14 Ames 07/31/17 07/31/17 day 27 F/R/P Conduit footing sections Ames 07/28/17 08/09/17 day 28 Footing Pour # 16,18 Ames 08/04/17 08/04/17 day 29 Footing Pour # 17,19,21 Ames 08/07/17 08/07/17 day 30 Footing Pour # 20,22 Ames 08/09/17 08/09/17 day 31 F/R/P Conduit walls sections Ames 08/05/17 08/23/17 day 32 Backfill Coliseum conduit sections 1-12 Ames 07/20/17 08/01/17 day 33 COLISEUM CONDUIT OUTLET 34 F/R/P Conduit Transition bottom slab Ames 07/27/17 08/11/17 day 35 Pour Slabs # 1,3 Ames 08/09/17 08/09/17 day 36 Pour Slabs # 2 Ames 08/11/17 08/11/17 day 37 F/R/P Conduit Transition walls Ames 08/09/17 08/25/17 day 38

7 Engineering Management Support, Inc. QA Audit Report #3 To: From: cc: Matt Ceresa, Kiewit, Tim Shangraw, EMSI Jennifer Luthi, DEH; Steve Gonzales, DEH; Bret Banwart (DPW); Brian McLaren (DPW):, and Patrick riley (DPW) Date: August 10, 2017 Re: Audit of Kleinfelder CABI Notes, June 2017, Globeville Landing Outfall Project Representatives from Engineering Management Support, Inc. (EMSI) reviewed Asbestos- Containing Soils Daily Reports (ACSRs) prepared by Kleinfelder during the month of June 2017 for consistency with Section 5.5 of Colorado s Solid Waste Regulations (CSWRs) and the Final Materials Management Plan (MMP) (EMSI, 2016). Documentation of the review is presented in Table 1. AUDIT FINDINGS Quality Control has greatly improved since the last QA Audit. As shown in Table 1, all audited parameters complied with Section 5.5 of the CSWRs and the MMP. ACTION REQUIRED No corrective action is required. Denver and EMSI will continue to monitor Ames/Kleinfelder s implementation of agreed-to reporting procedures and identify any area(s) in need of improvement during weekly progress meetings and if necessary, in subsequent QA Audit Reports. Page 1

8 Table 1: June 2017 QA of CABI daily logs per Colorado Regulation L (Documentation) and Final Materials Management Plan Page 1 1C 1A 1B 1D Personnel Date Grid Grid Site Description Description Description of Description Description Friability per CABI diagram description of site of equipment hand removals of types of suspect of ACMs Notes agree w including activities use including of debris materials discussed CABI location locations Lanaia Carveth 6/5/17 yes yes yes yes yes yes yes yes yes Lanaia Carveth 6/6/17 yes yes yes yes yes yes yes yes yes Greg St Louis 6/7/17 yes yes yes yes yes yes yes yes yes Philip Jaramillo 6/7/17 yes yes yes yes yes yes yes yes yes Greg St Louis 6/8/17 yes yes yes yes yes yes yes yes yes Greg St Louis 6/9/17 yes yes yes yes yes yes yes yes yes Matt Snyder 6/9/17 yes yes yes yes yes yes yes yes yes Greg St Louis 6/12/17 yes yes yes yes yes yes yes yes yes Lanaia Carveth 6/12/17 yes yes yes yes yes yes yes yes yes Greg St Louis 6/13/17 yes yes yes yes yes yes yes yes yes Lanaia Carveth 6/13/17 yes yes yes yes yes yes yes yes yes Greg St Louis 6/14/17 yes yes yes yes yes yes yes yes yes Lanaia Carveth 6/15/17 yes yes yes yes yes yes yes yes yes Lanaia Carveth 6/16/17 yes yes yes yes yes yes yes yes yes Lanaia Carveth 6/19/17 yes yes yes yes yes yes yes yes yes Greg St Louis 6/20/17 yes yes yes yes yes yes yes yes yes Greg St Louis 6/21/17 yes yes yes yes yes yes yes yes yes Lanaia Carveth 6/22/17 yes yes yes yes yes yes yes yes yes Lanaia Carveth 6/23/17 yes yes yes yes yes yes yes yes yes Greg St Louis 6/24/17 yes yes yes yes yes yes yes yes yes Lanaia Carveth 6/26/17 yes yes yes yes yes yes yes yes yes Lanaia Carveth 6/27/17 yes yes yes yes yes yes yes yes yes Tyler Godby 6/27/17 yes yes yes yes yes yes yes yes yes Greg St Louis 6/28/17 yes yes yes yes yes yes yes yes yes Tyer Godby 6/28/17 yes yes yes yes yes yes yes yes yes Tyler Godby 6/29/17 yes yes yes yes yes yes yes yes yes Greg St Louis 6/30/17 yes yes yes yes yes yes yes yes yes Lanaia Carveth 6/30/17 yes yes yes yes yes yes yes yes yes Notes: 1) NVE = no visible emissions observed 2) in the table "yes" designates that documentation was completed

9 Table 1: June 2017 QA of CABI daily logs per Colorado Regulation L (Documentation) and Final Materials Management Plan Page 2 2A and 2B 4 5B 1E 1F Personnel Date Bulk sampling Decontamination Spill Observations Observations Observations Photo-log / documentation visual inspection response of visible of non-earthen of other description and clearance activities emissions / material / indicators of Reponses commented soil impact Lania Carveth 6/5/17 Not conducted yes No spills NVE yes yes yes Lania Carveth 6/6/17 yes yes No spills NVE yes yes yes Greg St Louis 6/7/17 Not conducted yes No spills NVE yes yes yes Philip Jaramillo 6/7/17 Not conducted yes No spills NVE yes yes yes Greg St Louis 6/8/17 Not conducted yes No spills NVE yes yes yes Greg St Louis 6/9/17 Not conducted yes No spills NVE yes yes yes Matt Synder 6/9/17 yes yes No spills NVE yes yes yes Greg St Louis 6/12/17 Not conducted yes No spills NVE yes yes yes Lania Carveth 6/12/17 Not conducted yes No spills NVE yes yes yes Greg St Louis 6/13/17 Not conducted yes No spills NVE yes yes yes Lania Carveth 6/13/17 Not conducted yes No spills NVE yes yes yes Greg St Louis 6/14/17 Not conducted yes No spills NVE yes yes yes Lania Carveth 6/15/17 Not conducted yes No spills NVE yes yes yes Lania Carveth 6/16/17 Not conducted yes No spills NVE yes yes yes Lania Carveth 6/19/17 Not conducted yes No spills NVE yes yes yes Greg St Louis 6/20/17 Not conducted yes No spills NVE yes yes yes Greg St Louis 6/21/17 Not conducted yes No spills NVE yes yes yes Lania Carveth 6/22/17 Not conducted yes No spills NVE yes yes yes Lania Carveth 6/23/17 yes yes No spills NVE yes yes yes Greg St Louis 6/24/17 Not conducted yes No spills NVE yes yes yes Lania Carveth 6/26/17 Not conducted yes No spills NVE yes yes yes Lania Carveth 6/27/17 Not conducted yes No spills yes yes yes yes Tyler Godby 6/27/17 Not conducted yes No spills NVE yes yes yes Greg St Louis 6/28/17 yes yes No spills NVE yes yes yes Tyler Godby 6/28/17 Not conducted yes No spills NVE yes yes yes Tyler Godby 6/29/17 Not conducted yes No spills NVE yes yes yes Greg St Louis 6/30/17 Not conducted yes No spills NVE yes yes yes Lania Carveth 6/30/17 Not conducted yes No spills NVE yes yes yes

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

The date, site name, report author, report recipient, and report number are presented above. Engineering Management Support, Inc. Memorandum To: Jesse Aviles, EPA RPM, VB/I70 Superfund Site From: Timothy C. Shangraw Date: October 17, 2017 Re: POLREP #27 - Vasquez Boulevard/Interstate 70 (VB/I70)