Attachment E Minimal Assessment Memorandum.pdf

To:

Paul Howland Assistant District 12 Manager Oregon Department of Transportation 1327 SE 3rd Street Pendleton, OR 97801

Date: July 2, 2025

From:

Michelle Peterson, R.G.

Region 5 HazMat Geologist

Subject:

Minimal Assessment Memorandum OR11: M.P. 4 to Weston Interchange Chip Seal Project Maintenance Project No. 25003, Oregon-Washington Highway MP 4 to MP 20.38 Umatilla County, Oregon

As required by ODOT’s Highway Directive ENV 16-02, the ODOT Region 5 HazMat Unit performed a limited evaluation to identify potential sources of contamination that could impact the OR11: M.P. 4 to Weston Interchange Chip Seal Project (M25003) located along OR Highway 11 between approximately MP 4 and MP 20.38 Umatilla County, Oregon (Project Corridor).

This assessment is for internal ODOT use only and may not be relied upon by any other entity without the written permission of an authorized ODOT representative. No environmental assessment can wholly eliminate uncertainty regarding the potential for environmental conditions in connection with a site. Performance of a site assessment is intended to reduce, but not eliminate, uncertainty regarding the existence of environmental conditions in connection with the site. Finally, this report does not warranty against changes in land use or environmental conditions at the site or adjoining properties subsequent to publishing this report.

Background

The Project consists of edge of pavement to edge of pavement chip sealing and placement of permanent striping along OR11 between approximately MP 4.0 and MP 20.38. Temporary traffic control will include flagging operations that require some post-mounted signs to be installed. Sign installation will occur within ODOT right-of-way (ROW), and typically within the roadway shoulder embankment wherever possible. Traffic control will extend from approximately MP 3.3 to MP 21.2 on OR11, and at the Weston Interchange, where needed. A project location map is provided in Attachment A.

Department of Transportation Region 5 Geo/Hydro Unit

3012 Island Avenue La Grande, Oregon 97850

Phone (541) 786-3106 Email: michelle.l.peterson@odot.oregon.gov

OR11: M.P. 4 to Weston Interchange Chip Seal Project (Maintenance Project No. 25003)

Oregon-Washington Highway MP 4 to MP 20.38

No new right-of-way is required for this Project. The only ground disturbing activities for this Project include installing temporary traffic control signs within existing highway shoulders as needed along the Project Corridor. No excess soil materials are anticipated to be generated from installation of temporary signs.

Shoulder soils frequently contain non-point-source contaminants from vehicle emissions and highway runoff at concentrations that exceed Oregon Department of Environmental Quality (DEQ) clean fill criteria. The Project Corridor is located in the Deschutes-Columbia Plateau Physiographic Province and shoulder soils in this part of Oregon cannot be considered clean fill without testing.

Site Condition Assessment

ODOT Region 5 HazMat Geologist, Michelle Peterson, R.G., used the ODOT Digital Video Log (DVL) to visually assess site conditions, except for the Weston interchange on OR11 where Google Maps was used to visually assess site conditions. Google Maps was also used to visually assess site conditions at a facility called McGregor at the Mann road intersection where multiple aboveground storage tanks re visible from OR11. DVL on-line images are from July 2024. Google Maps images are from July and October 2019 and June and September 2023. No evidence of spills was observed along OR11.

Environmental Records Review

The potential for releases within the Project Corridor was assessed by reviewing information available from the DEQ through its Facility Profiler Lite and Your DEQ Online (YDO) platform.

Additionally, spill records maintained by ODOT Region 5 and the Oregon State Fire Marshal (OSFM) were reviewed.

Three Environmental Cleanup Site Information (ECSI) System sites, one Leaking Underground Storage Tank (LUST) facility, and one Solid Waste Information Facility Tracking (SWIFT) were identified adjacent to the Project Corridor, as listed in the table below.

Site Identification DEQ ID Direction Listing Status The McGregor Company Hwy 11 & Mann Road

ECSI

3936 South Suspect site requiring further investigation

(agricultural chemicals) Chevron Terminal & Pipeline State Hwy 11 & Country Road

ECSI

North & South Risk-Based No Further Action

Adams Shooting Range NW Corner of Hwy 11 &

Rothrock Road

ECSI

6193 North Suspect site requiring further investigation

(shooting range)

Chevron Terminal & Pipeline State Hwy 11 & Country Road

LUST

30-76-0001

North & South Risk-Based No Further Action

ODOT Adams Scale Site Westside Hwy 11 MP 12.84 to

MP 13.34

SWIFT

112135 West Solid Waste Letter of Authorization

7/20/2009 to 7/20/2010

No registered UST facilities or DEQ-listed landfills are located on or adjoining the Project Corridor.

Two of the three ECSI sites are suspect sites only and no releases have been documented.

The third ECSI site and the one LUST site are the same facility (Chevron Terminal & Pipeline) which has documented historical releases of various petroleum hydrocarbon products. Investigation and cleanup was conducted and the remaining contamination from the Chevron Terminal & Pipeline site is not known to have impacted ODOT ROW where temporary signs will be installed. Additional details about the releases from the Chevron Terminal & Pipeline site are provided below in the spill table.

The SWIFT site is the ODOT Adams Scale Site where DEQ issued a Solid Waste Letter of Authorization (SWLA) between July 2009 and July 2010. SWLAs are typically issued when there is a beneficial re-use for a material that would otherwise be considered solid waste (e.g. lightly contaminated soil, street sweepings, etc.) and require landfill disposal. The type and location of material that was placed under the SWLA is not known. However, the chip seal work is limited to the OR11 highway surface and is not planned to go into the Adams Scale Site, which is set apart from the highway. Therefore, the ODOT Adams Scale Site is not a concern for this Project.

The ODOT Region 5 Spill database indicates there were five spills reported within the Project Corridor. Two additional incidents were reported in the Oregon State Fire Marshal (OSFM) database. The table below summarizes the seven spills by MP, and provides the Oregon Emergency Response System (OERS) ID number, if available. Bold text identifies spill locations where cleanup is not complete, or where spill information is incomplete.

Incident Location OERS ID# Chemical

Spilled Release Description

OR11 MP 8 2017-1026 Diesel

Spill occurred 3/28/2017; approximately 20 gallons of diesel based on recovery of 130 gallons from the compromised saddle tank. A multiple vehicle crash involving two semi trucks and one passenger vehicle resulted in damage to one saddle tank on one semi-truck. The release impacted the pavement and the north shoulder. Eastern Oregon Environmental Recovery (EOER) conducted a cleanup. Ten tons of contaminated soil was disposed at Finley Buttes Landfill (Boardman, OR). Two closure samples were collected. Diesel was not detected. Low levels of residual-range organics (RRO) were detected at concentrations ranging from 211 milligrams per kilogram (mg/kg) and 215 mg/kg. The RRO concentrations were believed to be from the use of asphalt grindings in the shoulder. Cleanup complete.

Spilled Release Description

OR11 MP 9.1 None Various petroleum products

A former Chevron Bulk Plant operated at this location between the 1950s and 1990 when it was decommissioned. The petroleum pipeline remains in place and is still operational. A release from this facility was discovered in 1976 when petroleum began weeping out of a hillside on Wildhorse Creek approximately 1,100 feet north of the facility. The release was reported to DEQ and this facility was assigned ECSI No. 675 and LUST ID 30-76-0001.

Multiple releases have been documented, but the most substantive release occurred from an unwelded manifold that leaked each time product delivery occurred. The quantity of petroleum released from the unwelded manifold is not known. The releases primarily impacted groundwater that occurs at depths of approximately 50 to 60 feet below ground surface (bgs), within the basalt that underlies up to 25 feet of clay, silt and fine sand. Multiple investigations to identify the nature and extent of the releases were conducted and confirmed that the majority of the contamination is to groundwater.

Soil contamination was identified in only two of more than 50 borings completed at the facility and between the facility and the creek. Interim remedial actions included collection of light non-aqueous phase liquid (LNAPL) from the seeps on the creek bank using dikes and dams. LNAPL stopped seeping at the creek bank in 1983. A Record of Decision (ROD) in 2004 required ongoing groundwater monitoring and passive recovery of light non-aqueous phase liquid (LNAPL) from monitoring wells. Groundwater monitoring occurred between 1992 and 2008. A total of 17 gallons of LNAPL were recovered during this period. DEQ issued a Conditional No Further Action (NFA) determination on March 24, 2009. The Conditional NFA required land use restrictions be placed on two tax lots affected by the release. The restrictions limit land use, groundwater use, and require DEQ notification of a property sale or changes to the zoning. Cleanup complete.

OR11 MP 16 None Diesel

Spill occurred 5/18/2005; approximately 20 to 40 gallons. A semi-truck crashed resulting in a release of diesel fuel. ODOT incident records indicate ODOT maintenance forces placed boom around the release which was primarily contained to the pavement.

Cleanup considered complete.

OR11 MP 18.8 2015-2790 Diesel

Spill occurred 12/10/15; unknown quantity released. A semi-truck was blown over by high winds and then dragged off the highway to the shoulder where the diesel drained to the shoulder soils.

Eastern Oregon Environmental Recovery (EOER) conducted a cleanup and disposed approximately 250 tons of contaminated soil at Finley Buttes Landfill (Boardman, OR). Diesel was not detected in seven closure samples. Cleanup complete.

OR11 MP 20.5 2011-2227 Diesel

Spill occurred 9/9/2011; approximately 50 gallons. DEQ and ODOT Region 5 spill records indicate most of the release was on pavement, and that a cleanup was conducted by EOER. Cleanup complete.

76931 Oregon Highway 11

(MP 11.64)

None Anhydrous ammonia

Release occurred 11/8/2003; approximately 30 gallons. According to the OSFM incident report, the release occurred from a leaking valve at the McGregor facility. The release was stopped by turning off the valve. The anhydrous ammonia dispersed into the air and was not observed to impact the ground. No cleanup required.

Spilled Release Description

OR11

unknown location in zip code 97801

None Diesel

Spill occurred 12/22/1992; approximately 25 gallons.

According to the OSFM incident report, the Pendleton Fire Department responded to an abandoned semi-truck and found a diesel leak. The Pendleton Fire Department contained the release, but the incident report does not describe how this was done. No other information about incident cleanup is provided in the OSFM incident report and no cleanup report is available.

Six of the seven incidents had cleanups completed, or the release only impacted the air. These incidents are not a concern for this Project. The remaining incident is a relatively small diesel release that occurred more than 30 years ago somewhere along OR 11, but the exact location is not known and may not be within the Project Corridor. Given the age of the release, its relatively small size, and the uncertainty in its location, the installation of temporary signs for traffic control are not likely to encounter any remaining contamination. No further investigation is warranted.

Conclusions and Recommendations

The findings of this report are summarized below:

• No cleanup sites were identified that are a concern for this Project because they are not known to have impacted ODOT ROW where temporary construction signs will be installed.

• Seven spills identified within or along the Project Corridor are a not concern for this Project for one of the following reasons:

o A cleanup was conducted and no contamination remains.

o A cleanup was conducted and remaining contamination is much deeper than the depth of temporary traffic control signs.

o The release only impacted pavement.

o The release only impacted the air.

• Ground disturbance of shoulder soils will occur for installation of temporary traffic control signs. Shoulder soil adjacent to state highways has been found to contain contaminants (e.g., lead) at concentrations that do not meet DEQ clean fill criteria in the top 1.5 feet. Therefore, shoulder soils cannot be considered clean fill without testing. Testing of shoulder soil is not proposed because of the minimal disturbance that is anticipated for installation of temporary signs.

• Shoulder soil that does not meet DEQ clean fill criteria must be managed appropriately.

Although no excess soils are anticipated to be generated, small quantities of soil removed for temporary sign installation can be re-used within the operational ROW as allowed under the DEQ approved Beneficial Use Determination (BUD) BUD-20181204 for Highway Shoulder Soil Throughout Oregon (dated July 2, 2019). ODOT Region 5 HazMat will prepare Special Provision 00294 for this Project to require the contractor conducting the work to provide workers with lead awareness training and prepare a lead compliance plan for the Project, as required by the Occupational Health and Safety Lead in Construction standard (29 CFR 1926.62). SP00294 will also require the contractor to reuse any excavated shoulder soil within operational ROW.

Based on these findings, no further work is warranted to evaluate ground disturbing activities for installation of temporary signs for traffic control, unless the scope of the Project changes.

In accordance with the 2024 Oregon Standard Specifications for Construction, if unanticipated hazardous substances are discovered that threaten the health and safety of workers, the public, or the environment, the contractor must follow the specification section 00290.20(f).

If construction plans or disposal plans change, or new information indicates the potential presence of hazardous materials, please contact me with questions at 541-786-3106 or michelle.l.peterson@odot.oregon.gov.

Sincerely, Michelle Peterson, R.G.

Region 5 HazMat Geologist

Technical review by: Ryan Franklin, C.E.G.

Corporate review by: Russell G. Frost, C.E.G.

Attachments Attachment A – Project Location Map

ATTACHMENT A

Project Location Map

PROJECT LOCATION MAP

PROJECT

CORRIDOR

I-84 EB MP 352