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Comprehensive Management Plan for Arsenic-Contaminated Soil and Sediment - Library - November 16, 2012 Comprehensive Management Plan for Arsenic-Contaminated Soil and Sediment >� Tigard Library >t 13500 SW Hall Boulevard Tigard, Oregon for City of Tigard � November 16, 2012 Earth Science+ o• Comprehensive Management Plan for Arsenic-Contaminated Soil and Sediment Tigard Library 13500 SW Hall Boulevard Tigard, Oregon for City of Tigard November 16, 2012 GWENGINEERS� 15055 SW Sequoia Parkway,Suite 140 Portland, Oregon 97224 503.624.9274 Comprehensive Management Plan for Arsenic-Contaminated Soil and Sediment Tigard Library 13500 SW Hall Boulevard Tigard, Oregon File No.4025-003-05 November 16,2012 Prepared for: City of Tigard 13125 SW Hall Boulevard Tigard,Oregon 97223 Attention: Dennis Koellermeier Prepared by: GeoEngineers, Inc. 15055 SW Sequoia Parkway,Suite 140 Portland,Oregon 97224 503.624.9274 Marsi Beeson Senior Project Manager J 4 k, Dana Carlisle, PE ° Principal MMB:DLC:cje .,." A? '`3 i Disclaimer.Any electronic form,facsimile or hard copy of the original document(email,te4 table,and/or figure),if provided,and any attachments are only a copy of the original document.The original document is stored by GeolEngineers,Inc.and will serve as the official document of record. Copydghtm 2012 by GeoEngineers,Inc.All rights nerved. GWENGINEER� Table of Contents 1.0 INTRODUCTION...................................................................................................................................1 2.0 SITE DESCRIPTION.............................................................................................................................1 2.1 Setting.............................................................................................................................................1 2.2 Geology and Hydrogeology.............................................................................................................1 2.3 Previous Investigations..................................................................................................................2 3.0 BASELINE CONTAMINANT CONDITIONS...........................................................................................2 4.0 HEALTH AND SAFETY.........................................................................................................................2 4.1 Parking Area and Pine Tree Area...................................................................................................3 4.2 Wetland Area and Wild Area..........................................................................................................3 4.3 North Field......................................................................................................................................4 5.0 INSTITUTIONAL CONTROLS................................................................................................................4 5.1 Deed Restriction..............................................................................................................................4 5.2 Maintenance and Monitoring Plan.................................................................................................4 5.2.1 Visual Inspection..................................................................................................................4 5.2.2 Reporting..............................................................................................................................5 5.3 Contaminated Media Management Plan.......................................................................................5 5.3.1 Identification of Potentially Contaminated Soil..................................................................5 5.3.2 Handling of Contaminated Soil............................................................................................5 5.3.3 Erosion Control.....................................................................................................................6 5.3.4 Soil Stockpile Testing...........................................................................................................6 5.3.5 Disposition Options for Soil .................................................................................................7 6.0 LIMITATIONS.......................................................................................................................................7 7.0 BIBLIOGRAPHY...................................................................................................................................8 LIST OF FIGURES Figure 1.Vicinity Map Figure 2.Site Plan Showing Remedial Action Areas APPENDICES Appendix A. Inspection Form Appendix B. Comprehensive Management Plan Limitations and Guidelines For Use GEOENGINEERS� November 16,2012 Page i File No.4025-003-05 TIGARD LIBRARY COMPREHENSIVE MANAGEMENT PLAN Tigard,Oregon 1.0 INTRODUCTION This document outlines the Comprehensive Management Plan (CMP) for arsenic-contaminated soil and sediment at the Tigard Library, property (hereafter referred to as "site"). The CMP is a tool intended for use by the City of Tigard staff that work at and maintain the site. The document presents a monitoring and maintenance plan for contaminated areas, guidelines for the management of contaminated soil and sediment, and recommended protection of worker and visitor health. The CMP was requested by the Oregon Department of Environmental Quality(DEQ)as a condition of regulatory closure of the site. 2.0 SITE DESCRIPTION The site location,geologic setting and background are summarized in the following sections. 2.1 Setting The approximate 14.7-acre site is located east of the intersection of SW Hall Boulevard and SW Wall Street in Tigard, Oregon, as shown in Figure 1. The site is bordered by SW Hall Boulevard and residences to the west, residences to the south, vacant land and Fanno Creek to the north and east. Fanno Creek is a perennial stream that discharges to the Tualatin River approximately 2 miles south of the site. The site is occupied by a City of Tigard library and associated parking and vegetated areas. A concrete pedestrian trail traverses the east and north sides of the site. The elevation of most of the site is approximately 150 feet above mean sea level (MSL). The site is relatively flat, with the exception of a low area, occupied by Pinebrook Stream that traverses the south side of the site in a west-east direction. A gentle swale, oriented in a southwest-northeast direction, runs through the middle of the site. Much of the southwest-northeast trending swale was filled during construction of the library, and the swale no longer channels stormwater at the site. Pinebrook Stream flows across the south side of the site, after entering the site through a culvert underneath Hall Boulevard. Pinebrook Stream discharges to Fanno Creek near the southeast corner of the site. A stormwater pond (the "pond") is located at the southeast corner of the site, adjacent to and north of Pinebrook Stream. The pond receives stormwater runoff from parking areas at the site. The stormwater enters the north side of the pond through a constructed channel. During high water events, the pond, Fanno Creek, and Pinebrook Stream are sometimes connected. Site features are shown in Figure 2. 2.2 Geology and Hydrogeology The surface of the site outside of the building footprint is generally covered with trees, shrubs, grasses, and in some areas, asphalt and concrete. Organic sandy silt with some clay is present in the upper 2 to 5 feet of soil (Shannon and Wilson, 2003). Silt with varying amounts of clay and sand, but fewer organics is present below the upper organic layer and extends to at least 10 feet below ground surface (bgs), the maximum depth explored at the site. Groundwater has been encountered at depths ranging between 2 and 9 feet bgs. Shallow groundwater presumably flows toward Fanno Creek. GEOENGINEER� November 16,2012 Page 1 File No.4025-003-05 TIGARD LIBRARY COMPREHENSIVE MANAGEMENT PLAN Tigard,Oregon 2.3 Previous Investigations Several phases of soil assessment and remediation were completed at the site between 2002 and 2009. Past investigation activities are described in GeoEngineers' Human Health Risk Assessment and Level I and Level 11 Ecological Risk Assessment, dated July 11, 2008 (hereafter referred to as the "Risk Assessment Report")and GeoEngineers' Revised Focused Feasibility Study, dated June 15, 2009. The Focused Feasibility Study (FFS) was conducted to evaluate remedial alternatives for addressing potential risks to human health posed by arsenic in soil at the site. The selected remedial alternative was a combination of excavation, access restriction and capping of residual arsenic-contaminated soil and sediment at the site. Soil and sediment excavation activities were performed concurrently with library construction activities and are described in previous reports (GeoEngineers, 2008). Residual contaminant locations and conditions are described in the following sections. 3.0 BASELINE CONTAMINANT CONDITIONS The only contaminant of concern at the site is arsenic. Areas of the site where arsenic has been detected at concentrations exceeding applicable DEQ risk-based concentrations(RBCs) include the following: ■ Pine Tree Area - Soil ■ Parking Lot Area - Soil ■ Wetland Area - Soil and Sediment ■ Wild Area - Soil ■ North Field-Soil The maximum detected concentration of arsenic in soil and sediment in these areas exceed relevant risk screening criteria for human health, indicating that the arsenic concentrations in these areas could pose an unacceptable risk to human health. The concentrations of arsenic in soil and sediment do not appear to pose an unacceptable risk to terrestrial or ecological receptors. Contaminant risk-management actions implemented by the City are outlined in Section 4.0. 4.0 HUMAN HEALTH EXPOSURE PATHWAYS Arsenic is considered a potential carcinogen. Health effects from unacceptable levels of arsenic exposure include ulcerated nasal septum, dermatitis, gastrointestinal disturbances, peripheral neuropathy, respiratory irritation, and hyper pigmentation of skin. Potential exposure pathways for arsenic in soil and/or sediment include human exposure via direct contact, ingestion,and/or inhalation to exposed soil. The maximum detected concentration of arsenic (264 milligrams per kilogram [mg/kg]) at the site does not exceed the DEQ generic RBC for the excavation worker exposure scenario. However, arsenic concentrations at many site areas do exceed DEQ's generic RBCs for construction and occupational worker scenarios. RBCs are conservative screening levels. Under some circumstances, exposure to chemical concentrations that exceed RBCs can lead to unacceptable human health risks; however, contaminant risk-management measures can significantly reduce human health risks. Page 2 November 16,2012 GeoEngineers,Inc. File No.4025-003-05 TIGARD LIBRARY COMPREHENSIVE MANAGEMENT PLAN Tigard,Oregon Under current site conditions the following contaminant exposure pathways and potential receptors at the site include: ■ City workers: librarian, maintenance, and excavation worker exposure through soil ingestion, dermal contact with soil and inhalation of soil particles. ■ Public: adult and children library/park user exposure through soil ingestion, dermal contact with soil and inhalation of soil particulates. Covers or caps that can prevent or reduce exposure include vegetation, geotextile, plastic, bark dust, imported soil, asphalt, and concrete. The following sections describe actions that have been implemented at the site to prevent human exposure to arsenic-contaminated soil and sediments. 4.1 Parking Area and Pine Tree Area Human exposure to arsenic-contaminated soil at the Parking and Pine Tree Areas was eliminated by capping arsenic-contaminated soil. A 6-inch thick layer of bark dust or equivalent, underlain by a demarcation layer (geotextile or equivalent), was applied to the ground surface at these locations. The cap thickness may be less immediately adjacent to large trees, due to the potential harm caused by overly-thick bark dust adjacent to the trees. Figure 2 shows the location of capped arsenic-containing soil in the Parking and Pine Tree Areas. The City is required to conduct routine (annual) inspections and maintain the cap and demarcation layer (see Section 5.2). No operations should be conducted that will penetrate the cap or jeopardize the cap's functional integrity including, but not limited to,excavation, drilling,scraping and erosion. 4.2 Wetland Area and Wild Area Human access to a portion of the Wetland Area is controlled by fencing. The City has installed a 4-foot- high chain link fence around the southern Wetland Area and along a portion of the pedestrian trail on the east side of the parking lot(Figure 2). Human access is further restricted to the Wetland and Wild Areas by maintaining the wild character (dense brush, blackberry bushes and thicket) of this and surrounding areas to discourage regular usage of the area by people. The City is required to maintain the wild character of the Wetland and Wild Areas. DEQ has indicated that additional fencing is not necessary with the vegetation maintained in a wild state. Annual inspections that identify unintended trails (created by users that do not stay on designated walkways) shall be noted and repaired and returned to a natural state,such that they will no longer be readily usable. Arsenic in sediment in Pinebrook Stream, the pond, and the Wetland Area has been shown to pose no unacceptable risk to ecological receptors. Nonetheless, the City installed riprap for erosion protection at the pond outfall to minimize the potential for erosion from Pinebrook Stream, the pond, and the Wetland Areas to Fanno Creek. Other erosion prevention steps, if needed in the future, may include planting and encouraging growth of beneficial vegetation and/or installation of additional engineered structures, such as riprap or woody debris. GEOENGINEERS� November 16,2012 Page 3 File No.4025-003-05 TIGARD LIBRARY COMPREHENSIVE MANAGEMENT PLAN Tigard,Oregon 4.3 North Field Human access to the North Field is partially restricted by wooden split-rail fencing. Access to the North Field is further restricted by allowing area vegetation to grow (no cutting of vegetation beyond rough seasonal mowing for fire prevention). When funding by the City is secured,the top 6 inches of soil will be removed, replaced with clean fill, and the area re-planted with grass. If funding for the excavation work cannot be secured within 2 years from the date of this CMP, access to the North Field will be further limited through the installation of additional fencing, approximately as shown in Figure 2. The City is required to maintain the fence and discourage human use of the North Field. 5.0 INSTITUTIONAL CONTROLS Access restrictions and capping minimize or eliminate human exposure to contaminated soil; however, because contamination remains at the site, institutional controls are necessary to ensure the long-term success of contaminant risk-management actions. The institutional controls for the Tigard Library site include a deed restriction, maintenance and monitoring of fencing and caps, and a contaminated media management plan(CMMP). 5.1 Deed Restriction A deed restriction will be recorded to notify potential future owners of the property of the presence of elevated concentrations of arsenic in soil at the site and to record requirements and limitations associated with use of the property (i.e. requirements to maintain fencing and caps and restrictions on residential use of the property). 5.2 Maintenance and Monitoring Plan A maintenance and monitoring plan is necessary to ensure the continued protectiveness of institutional controls. The maintenance and monitoring plan consists of regular (i.e. annual) inspections of fencing and caps and reporting the results of the inspections to DEQ. If the fencing and/or cap are determined to be ineffective,the City is obligated to improve, repair or replace the damaged fence or cap. After 5 years DEQ will complete a 5-year review of the implemented remedy to ensure fencing and other measures are in place and being maintained. DEQ will then determine whether continued annual inspection and reporting are necessary,or less-frequent inspection is acceptable to DEQ. The CMP will be updated accordingly, if necessary. 5.2.1 Visual Inspection The property owner, or its agent, shall visually inspect the remedial action areas identified on the attached map (Figure 2) on or before November 1 of each year. The inspection will assess the general condition of the area, looking for signs of deterioration, erosion, damage or unauthorized uses. The inspection will consist of walking the entire area so that the entire surface can be observed and taking no fewer than two photographs of each area to document the current condition. The inspection will specifically identify areas with visible physical damage, erosion or settlement. Areas determined to require maintenance will be delineated with flagging or wooden stakes and photographed. Page 4 November 16,2012 GeoEngineers,Inc. File No.4025-003-05 TIGARD LIBRARY COMPREHENSIVE MANAGEMENT PLAN Tigard,Oregon An inspection form was prepared for City personnel to use and is presented in Appendix A. Observations and maintenance issues identified during the inspection will be recorded on this inspection form. Additional information will be attached if necessary. Maintenance issues identified during the inspection will be documented on this form and addressed in a timely manner. The property owner will initiate and oversee any repairs or maintenance of the caps and fencing. The owner will monitor maintenance activities and re-inspect repairs when completed. Maintenance and/or repair activities will be documented on the inspection form with accompanying photographs. The City representative performing the inspection shall sign and date the form confirming resolution of the issue. 5.2.2 Reporting The completed inspection form, including maintenance actions performed, shall be submitted to DEQ by December 31 of each year and will be maintained in the City's permanent records for the site. Copies of this plan and completed inspection forms should be provided to subsequent site owners. 5.3 Contaminated Media Management Plan This section is intended to provide guidance to the City and their contractors regarding: 1) identification; 2) characterization; 3) handling; and 4) disposal of contaminated soil that may be encountered during construction, maintenance,and landscaping activities performed at the site. 5.3.1 Identification of Potentially Contaminated Soil 1. Personnel that may contact contaminated soil shall review this plan to familiarize themselves with the locations of soil contamination prior to beginning the construction, maintenance, or landscaping activities. 2. All soil in the areas shown in Figure 2 shall be treated as contaminated and shall be handled and characterized as described below. 5.3.2 Handling of Contaminated Soil 1. Any soil that is contaminated shall require special handling and disposal. Workers that conduct routine maintenance and landscaping activities that are limited in duration (i.e. the workers will be exposed to contaminated soil for less than 7 days per year), should be provided with contaminant awareness training. Contaminant awareness training should include discussion of the nature and extent of contamination, the hazards posed by contamination, and risk mitigation measures. Hazardous Waste Site Operations and Emergency Response (HAZWOPER) certified personnel are not required for routine maintenance and landscaping activities. 2. To mitigate potential risks to workers during all soil disturbing activities in contaminated areas (as shown in Figure 2), care should be taken to minimize worker exposure to soil. During all soil disturbing activities, personnel shall: a) Wear coveralls and boot protectors during plantings and landscape maintenance; b) Remove soil and dust from clothing and shoes to the extent practicable following soil disturbance; c) Wash hands prior to the consumption of any food or beverage;and d) Refrain from eating,smoking, or drinking while in contaminated portions of the site. GEOENGINEERS� November 16,2012 Page 5 File No.4025-003-05 TIGARD LIBRARY COMPREHENSIVE MANAGEMENT PLAN Tigard,Oregon Techniques that may be useful for mitigating exposure include wetting soil to minimize airborne dust, providing washing stations for removing soil from skin, and removing dust from clothes and shoes to the extent possible at the end of work shifts. 3. If extended or large-scale (i.e. utility excavations or road and parking area construction) soil disturbance is planned and/or personnel will be exposed to contaminated soil for more than 7 days per year), upon initiation of those activities, an air sample should be collected from breathing space that is representative of a worst-case worker exposure scenario. The air sample should be analyzed for arsenic. If arsenic is detected in the air sample at a concentration that exceeds the Occupational Safety and Health Administration (OSHA) Permissible Exposure Level (PEL), further soil-disturbing activities shall be completed by HAZWOPER-certified personnel. If arsenic is detected in the air sample at a concentration that is less than the OSHA PEL, excavation can be completed by personnel that have received contaminant awareness training. 4. A Health and Safety Plan (HASP) will be required to perform excavation within contaminated areas. The HASP shall be prepared in accordance with the requirements identified above. OSHA regulation 29 CFR Part 1910.120 includes the provision for HAZWOPER training, including a health and safety program for employees working in hazardous waste cleanup areas. The City and contractors shall develop and be responsible for implementation of their own site-specific health and safety plan for site workers in accordance with these and any other applicable requirements. 5. A condition of no visible airborne dust shall be maintained at all times during construction, maintenance,and landscaping activities in contaminated areas. 6. Contaminated soil that is excavated can be loaded directly into trucks for transport to a subtitle D landfill under permit. Alternatively, soil can be stockpiled onsite in accordance with the instructions in item 7 below. 7. Contaminated soil shall be segregated from non-contaminated soil and can be secured onsite by placing it either in: 1) a designated stockpile area that is either lined or asphalt/concrete paved, covered by durable plastic sheeting and bermed to control runoff, or 2) in labeled roll-off containers, or other covered containers. Access to the secured soil will be restricted by fencing or other physical barriers to prevent unauthorized personnel from contacting the soil. On-site storage of soils shall be managed to comply with Best Management Practices for erosion and sediment control. 8. DEQ will be informed in writing of any significant release of contaminated material. 5.3.3 Erosion Control Personnel shall take appropriate steps to prevent the erosion of soil in and from contaminated areas. Erosion control methods my include one or more of the following: 1) installation of silt fence; 2) use of filter bags and/or fabric; 3) scheduling of activities to avoid rainy periods; 4) avoidance of construction activities in high risk areas such as the banks of Fanno Creek; and 5) other methods that are necessary and appropriate. 5.3.4 Soil Stockpile Testing 1. Soil that is excavated from contaminated areas of the site shall either: 1) be treated as contaminated and disposed of as described in Section 5.3.5, or 2) be tested as described below to assess soil quality. Page 6 November 16,2012 GeoEngineers,Inc. File No.4025-003-05 TIGARD LIBRARY COMPREHENSIVE MANAGEMENT PLAN Tigard,Oregon 2. Stockpiled soil shall be tested at the frequency described below: 0- 100 cubic yards of soil Minimum of 3 samples 101-500 cubic yards of soil Minimum of 5 samples 501- 1,000 cubic yards of soil Minimum of 7 samples 1,001- 2,000 cubic yards of soil 10 samples+for each additional 500 cubic yards of soil 3. Samples shall be collected from stockpiled soil in general accordance with the most recently promulgated version of the U.S. Environmental Protection Agency's (EPA) "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods,SW-846." 4. Samples shall be submitted to an Oregon-accredited analytical laboratory for analysis of arsenic by EPA Method 6010. 5.3.5 Disposition Options for Soil 1. Soil that contains concentrations of arsenic less than 7 mg/kg shall be considered non-contaminated and can be re-used at the site or disposed of at a non-regulated facility. Soil that contains concentrations of arsenic exceeding 7 mg/kg shall be considered contaminated and must be disposed of at a Subtitle D facility. 2. Contaminated soil that is transported offsite shall be disposed of at a Resource Conservation and Recovery Act (RCRA) Subtitle D municipal and/or non-hazardous waste landfill facility. Waste Management's Hillsboro Landfill is a local Subtitle D facility. 3. Transport and disposal of soil shall be in accordance with local,state and federal regulations. 4. Soil profiling will be required prior to disposal. The City, as owner of the property, will be considered the hazardous material generator for arsenic-contaminated soil at the site. The City will not be considered the generator for hazardous substances that are a result of others' operations or negligence. 5. The City will be presented with waste authorization forms and bills of lading for City signature prior to the removal of any contaminated soil from the site. 6.0 LIMITATIONS This CMP has been prepared for the exclusive use of the City of Tigard and DEQ for the Tigard Library in Tigard, Oregon. This CMP is not intended for use by others, and the information contained herein is not applicable to other sites. No other party may rely on the product of our services unless we agree in advance and in writing to such reliance. Within the limitations of scope, schedule and budget, our services have been executed in accordance with generally accepted environmental science practices in this area at the time this Plan was prepared. No warranty or other conditions,express or implied, should be understood. Please refer to the appendix titled "Comprehensive Management Plan Limitations and Guidelines for Use" for additional information pertaining to use of this report. GWENGINEERS� November 16,2012 Page 7 File Na.4025-003-05 TIGARD LIBRARY COMPREHENSIVE MANAGEMENT PLAN Tigard,Oregon Any electronic form, facsimile or hard copy of the original document (email, text, table, and/or figure), if provided, and any attachments are only a copy of the original document. The original document is stored by GeoEngineers, Inc. and will serve as the official document of record. 7.0 BIBLIOGRAPHY GeoEngineers, Inc.,Soil Assessment,Tigard Library,Tigard, Oregon,April 2007a. GeoEngineers, Inc., Contaminated Soil Management Plan,Tigard Library,Tigard, Oregon,April 11, 2007b. GeoEngineers, Inc., Human Health Risk Assessment and Level I and Level II Ecological Risk Assessments, Tigard Library, 13500 SW Hall Boulevard,Tigard, Oregon,July 11, 2008. GeoEngineers, Inc., Letter to Oregon Department of Environmental Quality regarding Supplemental Sediment Sampling, Tigard Library, 13500 SW Hall Boulevard, Tigard, Oregon, January 12, 2009a. GeoEngineers, Inc., Revised Focused Feasibility Study, Tigard Library, 13500 SW Hall Boulevard, Tigard, Oregon,June 15, 2009b. Hahn Associates, Inc., Phase II Environmental Site Assessment Report, 14.7 Acre Property, 13360 and 13560 SW Hall Boulevard,Tigard, Oregon, December 2, 2002. Hahn Associates, Inc., Draft Supplemental Site Investigation Report,October 6, 2006. McDonald, D.D, Ingersoll, C.G, and Berger, T.A., Development of Consensus-Based Sediment Quality Guidelines for Freshwater Sediment. Archives of Environmental Contamination and Toxicology, 39: 20-31, 2000, Oregon Department of Environmental Quality, Guidance for Identification of Hot Spots, 1998. Oregon Department of Environmental Quality, Default Background Concentrations for Metals, Memo from Toxicology Workshop to DEQ Cleanup Project Managers, 2002. Oregon Department of Environmental Quality, Risk-Based Decision Making for the Remediation of Petroleum-Contaminated Sites, Including Table of Generic Risk-Based Concentrations for Petroleum Constituents and Total Petroleum Hydrocarbons and Generic Remedy for Simple Risk- Based Sites, November, 2008. Oregon Department of Environmental Quality, Record of Decision, Remedial Action Alternative, Tigard Library Property,Tigard,Oregon, 2011. Shannon and Wilson,Geotechnical Investigation,Wall Street LID,Tigard, Oregon, 2003. Page 8 November 16,2012 GeoEngineers,Inc. File No.4025-003-05 „Y r r 'i .• y,4.. Y .�: o , • .F wle eft d Q♦p 1. �,, ,eni. �y,«• �! t r• . ' / t • Y Site ►t�r' t, _ ir :i • I 10 `� -• •• 1 � - •�' F� � '- � raj •� 1 ` Baa � ///'a'• � ' •'�• rt.:', �. QRDmpg ' {.- j/1 `400 �1 •• app , , , ',�� , ,.• ' L __ .� •. °o C; 12 (stlef Pei "13� o f s � cuJkt�A3t '• u _- i • ROAD .•. .�.� • J• Qi Map created wth. ©2oocs•National Geographic' . Uw r93 o .5 TNMN U NATIONAL 1000 0 � 3000 ,� '�`Es000 /17. G EOG k RAPH IC .5 9 KI OWTERS FEET ' iaaoMETERS ,oao 05/17/07 Vicinity Map Tigard Library N o Tigard, Oregon N GEDENGINEERS Figure 1 regon11 Department of Environmental Quality 1 Northwest Region Portland Oftl e i 2020 SW 4h Avenue,Suite 400 Theodore Kubngoski,Governor Portland,'OR 97201 4987 (503)'229-5263 FAX(503)229-6945 TTY(503)229-5471 September 3,2004 Mr. Agustin P. Duenas, City'Engineer City of Tigard 13125 S.W. Hall Blvd. Tigard,OR 97223 Re: Voluntary Letter Agreement Tigard Library Tigard,Oregon ECSI No.4063 Dear Mr. Duenas: This letter serves as a Voluntary Letter Agreement(Agreement)between the City of Tigard(the City)and the Oregon Department of Environmental Quality(DEQ),regarding DEQ review and oversight of the investigation and/or cleanup of hazardous substances at the property being developed for the Tigard Library. DEQ understands that the Tigard Library project involves three.tax lots(i.e.,tax Iots 100,200, and 600)located,at 13360& 13560 S.W. Hall Blvd. in Tigard,Oregon(the Property). Work to be performed under this Agreement will include completion of a Site Investigation. The objective of the Site Investigation is to determine whether hazardous substances are present in soil,groundwater,surface water,and sediment in concentrations that pose an unacceptable risk to human health and/or the environment. Under this Agreement, DEQ will perform the following review and oversight activities: • Conduct a site visit; • Review files and documents pertaining to environmental conditions at the Property; • Meet with the City and/or City's consultants to discuss the scope of work, methods,and schedule for the Site Investigation; • Review and provide comments on the draft Site Investigation Work Plan; • Review and approve the final Site Investigation Work.Plan; • Oversee the Site Investigation; • Review and provide comments on the draft Site.Investigation Report; and • Review and approve the final Site Investigation Report. City of-Tigard Voluntary Letter Agreement September 3,2004 Page 2 of 4 Under this Agreement, the City agrees to perform the following work: • Submit a Site Investigation Work Plan to DEQ within 45 days of the City's execution of thi's Agreement. The Site Investigation Work Plan should include,but not be limited to, the following: - A detailed history of the Property (e.g.,chronology of ownership,use and development history,results of previous engineering and environmental work). - A technical approach for identifying potential sources of contamination,the nature of contamination,the extent of contamination,contaminant migration pathways, exposure pathways, likely receptors,and potential hot spots of contamination; • Finalize documents submitted to DEQ under this Agreement within.30 days of receipt of DEQ's review comments on drafts. • Implement the Site Investigation in accordance with the scope of work and schedule specified in the DEQ-approved Work Plan(including submission of a Site Investigation Report). Based on the findings of the items listed above,further action may be warranted at the Property. This work may include additional site investigations,risk assessment;remedial action evaluation and selection,and/or a"no further action" (NFA)determination consistent with Oregon's Environmental Cleanup Law. DEQ will provide public notice and opportunity for comment on any remedial action proposal or NFA determination in accordance with ORS 465.320. DEQ will also determine,in consultation with the City,the form of any further agreement needed to manage the project in the most effective manner. DEQ requires that persons,seeking DEQ review and oversight of investigation and cleanup activities provide a minimum deposit of$5,000 to pay for DEQ's costs associated,with preparation of this Agreement,and as an.advance against costs that DEQ will incur. The deposit must be in the form of a check payable to the"Department of Environmental Quality".,When the City,has signed this.letter and their deposit has been received byDEQ,a sub,'account of the Hazardous Substances Remedial Action Fund will be established to be drawn upon.by DEQ as project costs are incurred. DEQ project costs will include direct costs.and indirect costs. Direct costs include site-specific , expenses and,legal costs. Indirect costs are those general management and support costs of the State of Oregon and.DEQ allocable to DEQ oversight of this Agreement and not charged as direct site-specific costs. Indirect charges are based on:actual-costs and are applied.as a percentage of directpersonal services costs.. Review and oversight costs will not include any unreasonable costs or not otherwise recoverable by.DEQ under'ORS 465:255. DEQ will provide the City with a monthly invoice,a sample of which'is attached. In the event project costs exceed the sub4ccount balance,DEQ will submit to"the City an invoice for any costs in excess of the advance. In the event project costs do not exceed the sub-account balance, DEQ will refund within 60 days of the close of the project any amount of-the deposit remaining City of Tigard Voluntary Letter Agreement September 3,2004 Page 3 of 4 in excess of the costs, or will apply the remaining amount toward oversight of work under any further agreement necessary for the project. Either the City or DEQ may terminate this:Agreement by giving 15 days advance written notice to the other. Be advised that because DEQ considers this site a High Priority.for further. investigation, if the City terminates this Agreement without completing the Site Investigation, DEQ may take action to complete the work and recover costs incurred as permitted by law. Such action could include issuing a unilateral order or using state contractors t6complete the work. Only those costs incurred or obligated by DEQ prior to the effective date of any termination of this Agreement shall be recoverable under this Agreement. Termination of this Agreement will not affect any other right DEQ may have for recovery of costs under applicable law. The City shall hold DEQ harmless for any claims(including but not limited to claims of property damage or personal injury)-arising from activities performed by the City and reviewed or overseen by DEQ under this Agreement. This Agreement is not and shall not be construed as an admission by the City of any liability under ORS 465.255 or any other law or as a waiver of any defense to such liability. This Agreement is not and shall not be"construed as a waiver,release,or settlement-of claims DEQ may have against the City or any other person or as a waiver of any enforcement authority DEQ may have with respect to the City or the Property. Upon DEQ's request and as necessary to oversight of the City's work under this Agreement,the City shall provide DEQ with data and records related to investigation and cleanup activities at the property,excluding any privileged documents identified as such by the City. DEQ appreciates the City's interest in the Voluntary Cleanup Program and looks forward to working with the City on the Tigard Library project. Sincerely, Keith Johnson Manager Cleanup and Lower Willamette Section NN irUix: City of Tigard Voluntary Letter Agreement September 3,2004 Page 4 of 4 If the terms of this Agreement are acceptable to the City of Tigard,please sign in the space provided below and return to us. Accepted and agreed to this day of(Oei*L" ,200-4—. By: �- �.1�...•-.. Title: T Attachments: Example Invoice Example Labor Summary Cc: Mr.Dominic Colletta,Ramis Crew Corrigan&Bachrach ECSI File 3892 �. . State of Oregon Department of Environmental Quality INVOICE Site Name: ABC,Inc Invoice Number: HSRAF01-)O= Project No: 10000000 Invoice Date: 8130/2001 Authorization: John Q. Public Corporation Payment Due: 9/29/2001 Attn: John 123 S.W. Bedrock Avenue Portland, OR 97200 Billing Period Project Expenditures: 7/01 Personal Services $ 0,00 Attorney General 0.00 Travel ' 0.00 Services and Supplies 0.00 Contract Payments 0.00 Total Current Charges: . $ 0.00 Previous Billing Period Total Balance Ex enditures Interest Balance Due 0.00 0.00 0.00 0.00 ------------------------------- Cut here and return this portion with payment ------------------------------- Remit and make checks payable to: Check box If your address has changed and complete back of invoice: L� Dept.of Environmental Quality Attn.: Business Office 811 SW Sixth Avenue Portland,OR 972041390 Site Name: ABC,Inc Invoice Number: HSRAF01 X7000_ Project No: 10000000 Amount Enclosed: Current 31-60 Days 61-90 Days 90+Days Total Due 0.00 0.00 0.00 0.00 0.00 DIRECT LABOR SUMMARY BUSINESS#100000 ABC,INC. FOR THE MONTH OF JULY 2001 DATE STAFF NAME ACTIVITY NAME ACTIVITY HOURS 3/7/01 TOBY SCOTT Document Review:rev constr.,remed.evil. a DAILY TOTAL 2.0 3/12/01 TOBY SCOTT Document Review:review sampling data 1.0 DAILY TOTAL 1.0 3/14/01 TOBY SCOTT Coordination:prep for field sampling lA TOBY SCOTT Site Visit:Sample ldllian well 20 DAILY TOTAL 3.0 3/15/01 TOBY SCOTT Document Review:air emission response 1'.0 TOBY SCOTT Records Management:sample prep and ship 1.0 DAILY TOTAL 2.0 3/16/01 TOBY SCOTT Meetings:mtg.@ ch2mhiB 4.0 TOBY SCOTT Travel:rdm>pdx . 2.0 MIKE POULSON Document Review:Air Modeling LQ DAILY TOTAL 7.0 3/19/01 TOBY SCOTT Document Review:system startup rpt.,constr.rpt. 2.0 MIKE POULSON Air modeling AQ DAILY TOTAL 6.0 3/22/01 TOBY SCOTT Communication:M Germon,M Poulson 1.0 TOBY SCOTT Document Prep.Air Emissions 1.0 TOBY SCOTT Document Review:well data,pilot testing,air p,,Q emission data 4.0 DAILY TOTAL 3/26/01 TOBY SCOTT Document Review.rev.reined.-pilot study 2.0 workplan DAILY TOTAL 2.0 3/27/01 TOBY SCOTT Document Prep:Killian.data 2.0 TOBY SCOTT Document Review:Killian:rpt. U DAILY TOTAL 4.0 LAB DEANNA EVANS DAILY TOTAL .5 PAULSCHOENLAUB DAILY TOTAL 2.0 TOTAL HOURS 33.5 r' regon Department of Environmental Quality Northwest Region Portland Office 2020 SW 40 Avenue,Suite 400 % �' TheadorcKubngoski.Governor Portland.OR 972014987 (503)229-5263 FAX(503)229-6945 TTY(503)229-5471 September 3, 2004. Mr. Agustin P. Duenas,City Engineer City of Tigard 13125 S.W. Hall'Blvd. . Tigard,OR 97223 Re: Transmittal of Voluntary Letter Agreement Tigard Library Tigard,Oregon ECSI No.4063 Dear Mr. Duenas: The Department of Environmental Quality(DEQ)received the verbal commitment of the City of Tigard(the City)to participate in the Voluntary Cleanup Program(VCP)for the Tigard Library (the Library)property during a meeting on August 5, 2004. The Tigard Libraryconstruction project involves three tax lots(i.e.,tax lots 100, 200,and 600)located at 13360& 13560 S.W. Hall Blvd. in Tigard,Oregon (the Property). Based on available file information and .our meeting discussions, DEQ understands that construction of the Library building has.been completed. The opening ceremony occurred on August 21". Additional site improvement work is planned for the Property including, a walking path, general landscaping, expanded parking facilities, and access road construction. Prior to initiating Property development, the City completed investigations to assess the status of environmental conditions at the Property. Site investigatory work.identified contamination of soil at the Property by arsenic. Arsenic impacts are thought to be associated:with an orchard that occupied portions of the Property from 1940 to 1953. The potential for arsenic contamination to be encountered during construction was recognized by the City and incorporated into project planning. According to documents provided by the City, precautions were taken to handle and manage soil excavated during the course of the construction work. During construction, nearly 3,700 tons of potentially impacted soil were removed from the site for off-site disposal. The City has elected to enter the VCP for DEQ's technical and regulatory input and oversight during the remainder of the Library project. Enclosed are two copies of DEQ's Letter Agreement for Voluntary Cleanup (the Agreement) for the Library property. The Agreement provides for technical and regulatory oversight, review of environmental documents prepared by or on behalf of the City,and preparation of a No Further Action determination, if appropriate. Mr. Agustin P. Duenas , January 28,2004 Page 2 of 2 Please sign both copies of the enclosed Agreement and return one signed copy to me. As was discussed during the August 5'h meeting, DEQ is willing to waive the$5,000 deposit for public agencies and local governments. If you wish DEQ to waive the$5,000 deposit,then please attach a brief note requesting the waiver and attach it to the executed Agreement. As you may know,DEQ Northwest Region's Cleanup Program currently has limited resources. The Cleanup Program maintains a waiting list of projects waiting to be assigned a DEQ project manager. Typically, new projects are picked-up from the waiting list and initiated as current projects are completed and resources become available. Right now,the Northwest Region Cleanup Program is managing more than 250 projects. Due to our limited staff resources and the popularity of the Voluntary Cleanup Pathway,a project may remain on the waiting list for two to three months until staff resources become available and we are able to assign a project manager to the site. That said,DEQ is supportive of projects undertaken by municipal governments that have community benefits and result in the investigation,cleanup,and re-use of potentially contaminated properties. These types of projects are priorities for us and we do our best to accommodate them within the Cleanup Program. Given the importance of this project to the City, DEQ will assign a project manager to the Library project as expeditiously as workloads allow. I will contact you as soon as a project manager is assigned. DEQ appreciates your time in meeting with us to discuss the Library project,and the efforts made by the City to identify and mitigate potential soil impacts prior to and during construction work. Please feel free to call me at(503)229-5543 or e-mail me at bayuk.danaC deq.or.state.us if you have any questions regarding the VCP or if 1 can provide additional information and/or assistance. Sincerely, "gz Mr. Dana Bayuk Cleanup Program Representative Northwest Region Cc: Mr.Dominic Colletta,Ramis Crew Corrigan&Bachrach ECSI File 3892 Encl: Voluntary Letter Agreement October 19, 2004 : -. . . CITY OF TIGARD OREGON Mr. Dana Bayuk Cleanup Program Representative Northwest Region Portland Office Department of Environmental Quality 2020 SW 4th Avenue, Suite 400 Portland, OR 97201-4987 Dear Mr. Bayuk: Enclosed is one(1)signed copy of the Letter Agreement for Voluntary Cleanup for the Tigard New Library property. Please waive the $5,000.00 deposit, which we understand DEQ is willing to do for local governments. We look forward to working with a DEQ project manager once the assignment is made for this project. If you should need anything further from us prior to the assignment of a project manager, please call me at 503-718-2470,or send me an email message at gus@ci.tigard.or.us. Sincerely, STIN P. DUENAS, P.E. Ci Engineer Enclosure: Signed Letter Agreement for Voluntary Cleanup c: William A. Monahan, City Manager Dominic Colletta, Ramis Crew Corrigan & Bachrach i.WVVu*Y"4raWdn to ON transmdli.q voiwaa,letw aWftMe a.Ooc 13125 SW Hall Blvd., Tigard, OR 97223(503).639-4171 TDD(503)684-2772 l� ::- _�--�,- • - ��__� APPENDIX A Inspection Form J i , J,. Appendix A Inspection Form Site Name Tigard Library, Tigard,Oregon Date of Inspection Inspection Conducted by Weather Conditions Instructions: The property owner or its agent shall visually inspect the remedial action areas identified on attached map on or before November 1 of each year. The inspection will assess the general condition of the area, looking for signs of deterioration, erosion or damage. The inspection will consist of walking the entire area so that the entire surface can be observed and taking no fewer than two photographs of each area to document the current condition. The inspection will specifically identify areas with visible physical damage, erosion, settlement and/or unauthorized use. Areas determined to require maintenance will be delineated with flagging or wooden stakes and photographed. Observations and maintenance issues identified during the inspection will be recorded on this inspection form. Additional information will be attached if necessary. Maintenance issues identified during the inspection will be documented on this form and addressed in a timely manner. The property owner will initiate and oversee any repairs or maintenance of the caps and fencing. The owner will monitor maintenance activities and re-inspect repairs when completed. Maintenance and/or repair activities will be documented on the inspection form with accompanying photographs. The City representative performing the inspection shall sign and date the form confirming resolution of the issue. The completed inspection form, including maintenance actions performed, shall be submitted to DEQ by December 31" of each year and will be maintained in the City's permanent records for the site. Copies of this plan and completed inspection forms should be provided to subsequent site owners. NORTH FIELD Condition: Issues identified and resolved: City of Tigard Library Inspection Form Page l of 3 Appendix A Inspection Form WILD AREA Condition: Issues identified and resolved: PINE TREE AREA Condition: Issues identified and resolved: PARKING LOT AREA Condition: Issues identified and resolved: City of Tigard Library Inspection Form Page 2 of 3 Appendix A Inspection Form EAST WETLAND/POND AREA Condition: Issues identified and resolved: SOUTH WETLAND AREA Condition: Issues identified and resolved: By signing,I verify that the information on this form and any attachments is accurate and complete: Signature: Print Name: Date: City of Tigard Library Inspection Form Page 3 of 3 lI �. APPENDIX B ;Comprehensive Management Plan Limitations and Guidelines for Use t _ .. % __- f s TIGARD LIBRARY COMPREHENSIVE MANAGEMENT PLAN Tigard,Oregon APPENDIX B COMPREHENSIVE MANAGEMENT PLAN LIMITATIONS AND GUIDELINES FOR USE This Appendix provides information to help you manage your risks with respect to the use of this plan. Environmental Services Are Performed For Specific Purposes, Persons and Projects This CMP has been prepared for the exclusive use of the City of Tigard and the DEQ. This CMP is not intended for use by others, and the information contained herein is not applicable to other sites. This Comprehensive Management Plan is Based on a Unique Set of Project-Specific Factors This CMP has been prepared for the property occupied by the Tigard Library in Tigard, Oregon. GeoEngineers considered a number of unique, project-specific factors when establishing the scope of services for this project and CMP. Unless GeoEngineers specifically indicates otherwise, do not rely on this CMP if it was: ■ Not prepared for you. ■ Not prepared for your project. ■ Not prepared for the specific site. ■ Completed before important project changes were made. If important changes are made after the date of this CMP, GeoEngineers should be given the opportunity to review our interpretations and recommendations and provide written modifications or confirmation, as appropriate. Reliance Conditions for Third Parties Our CMP was prepared for the exclusive use of the City of Tigard. No other party may rely on the product of our services unless we agree in advance to such reliance in writing. This is to provide our firm with reasonable protection against open-ended liability claims by third parties with whom there would otherwise be no contractual limits to their actions. Within the limitations of scope, schedule and budget, our services have been executed in accordance with our Agreement with the City of Tigard and generally accepted environmental practices in this area at the time this CMP was prepared. Environmental Regulations Are Always Evolving Some substances may be present in the site vicinity in quantities or under conditions that may have led, or may lead, to contamination of the subject site, but are not included in current local, state or federal regulatory definitions of hazardous substances or do not otherwise present current potential liability. GeoEngineers cannot be responsible if the standards for appropriate inquiry, or regulatory definitions of hazardous substance, change or if more stringent environmental standards are developed in the future. GWENGINEER� November 16,2012 Page B-1 File No.4025-003-05 TIGARD LIBRARY COMPREHENSIVE MANAGEMENT PLAN Tigard,Oregon Subsurface Conditions Can Change This CMP is based on conditions that existed at the time it was prepared. The findings and conclusions of this CMP may be affected by the passage of time, by manmade events such as construction on or adjacent to the site, by new releases of hazardous substances, or by natural events such as floods, earthquakes, slope instability or groundwater fluctuations. Always contact GeoEngineers before applying this CMP to determine if it is still applicable. Soil and Groundwater End Use The cleanup levels referenced in this report are site-and situation-specific. The cleanup levels may not be applicable for other sites or for other on-site uses of the affected media (soil and/or groundwater). Note that hazardous substances may be present in some of the site soil and/or groundwater at detectable concentrations that are less than the referenced cleanup levels. GeoEngineers should be contacted prior to the export of soil or groundwater from the subject site or reuse of the affected media on site to evaluate the potential for associated environmental liabilities. We cannot be responsible for potential environmental liability arising out of the transfer of soil and/or groundwater from the subject site to another location or its reuse on-site in instances that we were not aware of or could not control. Most Environmental Findings Are Professional Opinions Our interpretations of subsurface conditions are based on field observations and chemical analytical data from widely spaced sampling locations at the site. Site exploration identifies subsurface conditions only at those points where subsurface tests are conducted or samples are taken. GeoEngineers reviewed field and laboratory data and then applied our professional judgment to render an opinion about subsurface conditions throughout the site. Actual subsurface conditions may differ - sometimes significantly - from those indicated in this CMP. Our report, conclusions and interpretations should not be construed as a warranty of the subsurface conditions. Read These Provisions Closely Some clients, design professionals and contractors may not recognize that the geoscience practices (geotechnical engineering, geology and environmental science) are far less exact than other engineering and natural science disciplines. This lack of understanding can create unrealistic expectations that could lead to disappointments, claims and disputes. GeoEngineers includes these explanatory "limitations" provisions in this CMP to help reduce such risks. Please confer with GeoEngineers if you are unclear how these "CMP Limitations and Guidelines for Use" apply to your project or site. Page B-2 November 16,2012 GeoEngineers,Inc. File No.4025-003-05 TIGARD LIBRARY COMPREHENSIVE MANAGEMENT PLAN Tigard,Oregon Biological Pollutants GeoEngineers' Scope of Work specifically excludes the investigation, detection, prevention or assessment of the presence of Biological Pollutants. Accordingly, this report does not include any interpretations, recommendations, findings, or conclusions regarding the detecting, assessing, preventing or abating of Biological Pollutants and no conclusions or inferences should be drawn regarding Biological Pollutants, as they may relate to this project. The term "Biological Pollutants" includes, but is not limited to, molds, fungi, spores, bacteria, and viruses, and/or any of their byproducts. If the City of Tigard desires these specialized services, they should be obtained from a consultant who offers services in this specialized field. GEOENGINEER November 16,2012 Page B-3 File No.4025-003-05 P 1441025003WZCAD1Fin*IR 1F'gure7.dwg MSY.MWJ 07/08!06 N WE S10 S ,32 N, 70 0 70 S4 Feet ®r ` %sip, 008--; ® ( •>. W2 it o IIs3` s0 S c SS-33 • r I I SS-37 O �' � I 0 i \. I 1 -24 733 / SS-27 SS-28 S O 9 1 ( S 0 '2t SS:U°S 25 \ O O � 006 OC7 008 i I t S O C •�°° SS-15 0 TIC, li SS-18 SO 19 SS-20 IBJ I I SV ' 10 I1 I I e sic 2 oo _ i i l � 0 a 275 o Y 00 2 Q o SS-59S•' SS-61 $'�'�' *g O 195 �� 1IIIII �IIIII-_ ti S 2 �I css SS sa 56 OSSSr O58 a HA is(0-1) t 1 OS ssQ-a9 sIs•50 SS-t- SS-48 � SS-5b / SS-5: •+ IIP `' I� l �111J1'� i iel.h1 0.,, 1 + HA.,e,e 0.5> A\' HA-16 j ' •�.��� / Ii l * a �<' S 0 � .�. -� -,20(0.0.6) , c ; o s.. HA-17(0-1) Pond v t y ( I HA-2C 1S HA-9A 00 --------- 1 N -22(0-0.S) -- -- 6s o�i♦A-11(0-1) rs 536- A?VWa11 SFSS-Wjtte t 1v s 29(0-0.5) HA-9B ° A-�S dB M` -23 — -off'* — - rases` &� 0 t Ag aoa•j HA-10(0-1) - w► _ s'•=' 3$ 4.HA-27(0-0.5) A HA-28(0-0.5) a-9'HA-6 HA-24(0-0.5) c910-2(0.0.5) s� ,•�, P-3 . +HA-7 OW j COMP4( 5) ( �* y:. X i I - j i Legend: HA-1-HA-30 + Hond-auger sompte locations I I / Outfall (April 2007 and May 2008) I I I SP-1 (a Soil sompte locations (June 2007) 7__•_ TF� 090 Pre-2006 Sal samples Locality of Facility I F+ �— Approximate Area of Soil Exceeding 17-71 Adult and Child Pork User RBC (2.6 mg/kg) A and Background (7 mg/kg) Areas Exceeding Screening Criteria OPaved Cop Approximate Area of Soil Exceeding Tigard Library O Freshwater Sediment (6 mg/kg) and Tigard,Oregon `v ,"�n�..a...rrw....w...nn.ww.. Sediment Bioaccumulation (7 mg/kg) SLVs L TIY.�/�4 bMlnwlM.Wi�a MY�r b Mrrw�rrwe�e�r M wrraraawr.0°sEry�.�,K M°a1pCMM wsaep.ly N i.-.Yr.M1RrC b1. GEOENGINEERS Figure .ay.e....ey...rr! ♦.N°..r°solwrvr-. D:\PROJECT\PORTLAND\4025003\05\CAD\402500305 F2.dwg\TAB:F2 modified on Nov 15,2012-11:14am PORT:MMB:SCY AA I1 , x r } / a 14 l North Field +ill "e� x Wild Area : °f x x k' A x Pine Tree a Area . . i f� v Parking Lot . Area —.5' i + 71 Wetland Vill _ Area r 40 Stream bvoo lob , lift r• r ` Wetland Area AL Legend: N Approximate Areas of Soil Exceeding Adult and Child Park W E User RBC (2.6 mg/kg) and Background (7 m9/kg) S 70 0 70 ® Cap WE Feet 4' Chain—link Fence Site Plan Showing —X—X— Split—rail Fence Remedial Action Areas ———— Proposed Fence Tigard Library Notes: Tigard, Oregon 1.The locations of all features shown are approximate. 2.This drawing Is for Information purposes.It Is Intended to assist In showing features discussed in an attached document.GeoEngineers,Inc.can not guarantee the accuracy and content of electronic files. G M E N G I N E E R S Figure 2 The master file is stored by GeoEngineers,Inc.and will serve as the official record of this communication. Reference:Base drawing provided by Portland Maps.