due care plan - michigan · due care plan page 2 fleis & vandenbrink engineering, inc. 825390...

February 2016 Project No. 825390

DUE CARE PLAN

SATISFYING THE REQUIREMENTS OF RULE 299.51003 OF THE MICHIGAN ADMINISTRATIVE CODE

DOCUMENTING COMPLIANCE WITH SECTION 20107A(1) OF

P.A. 451, PART 201, AS AMENDED

505 EAST ALCOTT STREET KALAMAZOO

KALAMAZOO COUNTY, MICHIGAN

PREPARED FOR:

KALAMAZOO COUNTY

DUE CARE PLAN Page i

FLEIS & VANDENBRINK ENGINEERING, INC. 825390 Due Care Plan - Alcott Property

TABLE OF CONTENTS SECTION PAGE

EXECUTIVE SUMMARY ................................................................................................................. 1 Preventing Exacerbation ........................................................................................................ 3 Mitigating Unacceptable Exposures ....................................................................................... 3 Reasonable Precaution .......................................................................................................... 4

1.0 INTRODUCTION .................................................................................................................... 5

2.0 HAZARDOUS SUBSTANCE INFORMATION ...................................................................... 6 2.1 Known Contamination .................................................................................................. 6 2.2 Exposure Pathway Evaluation ...................................................................................... 7

2.2.1 Drinking Water (DW) ....................................................................................... 7 2.2.2 Groundwater Direct Contact (GDC) ................................................................ 7 2.2.3 Groundwater Surface Water Interface (GSI) ................................................... 7 2.2.4 Groundwater Volatilization to Indoor Air - Inhalation (GVIAI) .......................... 7 2.2.5 Non-Aqueous Phase Liquids (NAPLs) ............................................................ 8 2.2.6 Soil Direct Contact (SDC) ................................................................................ 8 2.2.7 Soil Leaching to Drinking Water (SDW) .......................................................... 8 2.2.8 Soil Leaching to Groundwater Direct Contact (SGDC) ................................... 8 2.2.9 Soil Leaching to Groundwater Surface Water Interface (SGSI) ...................... 8 2.2.10 Soil Volatilization - Inhalation (SVI) ................................................................. 8 2.2.11 Soil Transport to Surface Water ...................................................................... 8 2.2.12 Soil Volatilization to Indoor Air - Inhalation (SVIAI) ......................................... 8 2.2.13 Surface Water Sediments................................................................................ 8 2.2.14 Exposure Pathway Summary .......................................................................... 9

2.3 Exposure Controls ........................................................................................................ 9 2.3.1 Ingestion of Drinking Water ............................................................................. 9 2.3.2 Soil Leaching to Drinking Water ...................................................................... 9

3.0 NOTIFICATIONS AND CONTAMINANT MITIGATION ...................................................... 10 3.1 Offsite Migration Notification ....................................................................................... 10 3.2 Abandoned Container Notification .............................................................................. 10 3.3 Easement Holder Notification ..................................................................................... 10 3.4 Mitigation of Fire and Explosion Hazards ................................................................... 10

4.0 DUE CARE SUMMARY ....................................................................................................... 11 4.1 Preventing Exacerbation ............................................................................................ 11 4.2 Mitigating Unacceptable Exposures ........................................................................... 11 4.3 Reasonable Precaution .............................................................................................. 12

FIGURES Figure 1 Site Location Map Figure 2 Site Plan showing Analytical Data TABLES Table 1 Soil Analytical Data Summary Table 2 Groundwater Analytical Data Summary Table 3 Hazardous Substance Concentrations and GNRCC Comparison for Soil Table 4 Hazardous Substance Concentrations and GNRCC Comparison for Groundwater ATTACHMENTS Attachment 1 Notice to Contractors

DUE CARE PLAN Page ii


LIST OF ABBREVIATIONS/ACRONYMS ags Above Ground Surface bgs Below Ground Surface BEA Baseline Environmental Assessment CA Compliance Analysis DCP Due Care Plan DW Drinking Water ESA Environmental Site Assessment F&V Fleis & VandenBrink Engineering, Inc. GDC Groundwater Direct Contact GNRCC Generic Non-Residential Cleanup Criteria GRCC Generic Residential Cleanup Criteria GSIPC Groundwater Surface Interface Protection Criteria GVIAI Groundwater Volatilization to Indoor Air - Inhalation LUST Leaking Underground Storage Tank MDEQ Michigan Department of Environmental Quality MS/MSD Matrix Spike/Matrix Spike Duplicate NAPL Non-Aqueous Phase Liquid NREPA Natural Resources and Environmental Protection Act PID Photoionization Detector PNA Polynuclear Aromatics PPE Personal Protective Equipment PVC Polyvinyl Chloride QC Quality Control REC Recognized Environmental Condition SB Soil Boring SDC Soil Direct Contact SDW Soil Leaching to Drinking Water SGDC Soil Leaching to Groundwater Direct Contact SGSI Soil Leaching to Groundwater Surface Water Interface SHWS State Hazardous Waste Sites SOP Standard Operating Procedure SS Soil Sample SVI Soil Volatilization – Inhalation SVIAI Soil Volatilization to Indoor Air – Inhalation TB Test Boring TMW Temporary Monitoring Well USCS United Soil Classification System UST Underground Storage Tank VOC Volatile Organic Compound

DUE CARE PLAN Page 1


EXECUTIVE SUMMARY Section 20107a(1) (commonly referred to as Section 7a) of Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended, provides that a person who owns or operates property and also has knowledge that the property is a facility (i.e., a site of contamination) must do all of the following with respect to hazardous substances at the facility:

a. Undertake measures as necessary to prevent exacerbation of existing contamination. b. Exercise due care by undertaking response activity necessary to mitigate unacceptable

exposure to hazardous substances, mitigate fire and explosion hazards due to hazardous substances, and allow for the intended use of the facility in a manner that protects public health and safety.

c. Take reasonable precautions against the reasonably foreseeable acts or omissions of a third party and the consequences that foreseeably could result from those acts or omissions.

d. Provide reasonable cooperation, assistance, and access to persons authorized to conduct response activities.

e. Comply with land use or resource use restrictions. f. Not impede the effectiveness or integrity of any land use or resource use restrictions and

response activities. The process of reviewing what specific obligations need to be addressed during ownership and/or operations of the property is referred to as a Section 7a Compliance Analysis (CA). R 299.51003, Rule 1003(5) requires that a person subject to the provisions of Section 7a maintain documentation of compliance with Section 7a and provide such documentation to the MDEQ upon request. Such documentation is commonly referred to as a Due care Plan (DCP). If the property use changes in the future, the potential exposure pathways must be reassessed at that time and documentation of compliance with Section 7a must be maintained. Following is the CA and DCP for the property located at 505 East Alcott Street, City of Kalamazoo, Kalamazoo County, Michigan (Property). A Site Location Map (Figure 1) and a Site Plan (Figure 2) are attached. The Property is owned by Kalamazoo County (Owner), who will use the Property for Non-Residential purposes. This document has been prepared by F&V for the Property. This document does not constitute legal advice, nor does F&V purport to give legal advice. Certain information in this document may have been provided by agencies and/or persons other than F&V personnel. F&V makes no representation or warranties that such information is accurate or that any independent investigation, beyond the agreed Scope of Services, has been or will be made to verify the accuracy of such information. F&V has no obligation to any party other than the Owner, and F&V specifically disclaims any responsibility to any other party. F&V assumes no obligation for reporting any facts contained in this report to anyone other than the Owner. This document was prepared to both provide direction to the Owner/Operator of the Property and to comply with Section 7a. The Property was determined to be a facility, as defined in Section 20101(1)(r) of Part 201. F&V conducted a Phase II ESA to evaluate the RECs identified in the December 2015 Phase I ESA. The results of the Phase II ESA sampling and analysis are provided in the 2016 BEA. SB/TMW-1 was installed near the north Property boundary in an area that was formerly occupied by rail spurs and located hydraulically downgradient of the paper mill buildings. Soil sample SB-1 (2-3’) was collected from this test boring and contained arsenic at a concentration exceeding Part 201 GRCC. Numerous PNA compounds and metals were detected at concentrations below their respective Part 201 GRCC. Groundwater sample TMW-1 was collected at this location and contained tetrachloroethylene at a concentration equal to its Part 201 GRCC Drinking Water Criterion.



SB/TMW-2 was installed near the north Property boundary in an area that was formerly occupied by rail spurs and located hydraulically downgradient of the paper mill buildings. Soil sample SB-2 (3-4’) was collected from this test boring and contained the following compounds at concentrations exceeding their respective Part 201 GRCC: carbon tetrachloride, naphthalene, tetrachloroethylene, trichloroethylene, xylenes and arsenic. Numerous VOCs, PNAs and metals were detected at concentrations below their respective Part 201 GRCC. Groundwater sample TMW-2 was collected at this location and contained tetrachloroethylene at a concentration exceeding its Part 201 GRCC Drinking Water Criterion. SB/TMW-3 was installed near the north Property boundary in an area that was formerly occupied by rail spurs and located hydraulically downgradient of the paper mill buildings. Soil sample SB-3 (3-4’) was collected from this test boring and contained arsenic at a concentration exceeding Part 201 GRCC. Numerous PNA compounds and metals were detected at concentrations below their respective Part 201 GRCC. Groundwater sample TMW-1 was collected at this location and contained tetrachloroethylene at a concentration below its Part 201 GRCC Drinking Water Criterion. SB/TMW-4 was installed near the north Property boundary in an area that was formerly occupied by rail spurs and located hydraulically downgradient of the paper mill buildings. A soil sample was not collected at this location. TMW-4 was collected at this location, and it did not contain tested compounds at concentrations exceeding Part 201 GRCC. A surficial soil sample (SS-2, 0-1’) was collected from undisturbed fill material near the north Property boundary. The sample contained arsenic and mercury at concentrations exceeding their respective Part 201 GRCC. Numerous PNA compounds and metals were detected at concentrations below their respective Part 201 GRCC. The hazardous substances carbon tetrachloride, naphthalene, tetrachloroethylene, trichloroethylene, xylenes, arsenic and mercury have been identified in the Property’s soil and the hazardous substance tetrachloroethylene has been identified in the Property’s groundwater at concentrations exceeding their respective GRCC, as defined in R299.5744 and R299.5746 of the NREPA. Detailed information associated with the known contamination (i.e., sample concentrations of hazardous substances that exceed GRCC) at the Property is provided in the 2016 BEA document prepared by F&V. Based on the results of the sampling and analysis, the Property was determined to be a facility, as defined in Section 20101(1)(r) of Part 201 of the NREPA, P.A. 451 of 1994, as amended, due to the presence of carbon tetrachloride, naphthalene, tetrachloroethylene, trichloroethylene, xylenes, arsenic and mercury in soils, and tetrachloroethylene in groundwater at concentrations, exceeding Part 201 GRCC. The Property will be used for Non-Residential uses in the future, therefore the soil and groundwater data were compared to Part 201 Generic Non-Residential Cleanup Criteria (GNRCC). The detected concentrations of arsenic, carbon tetrachloride, tetrachloroethylene, and trichloroethylene in soil exceed their respective Part 201 GNRCC Drinking Water Protection Criteria (DWPC). None of the detected concentrations in soil exceed their respective Part 201 GNRCC DCC. Concentrations of detected hazardous substances in soil exceed Part 201 GNRCC GSIPC, however, there is no potential exposure pathway, therefore, this data is not relevant to the Property. The detected concentration of tetrachloroethylene in groundwater exceeds its Part 201 GNRCC Drinking Water Criterion (DWC). The soil and groundwater analytical data are summarized and compared to Part 201 GRCC and Part 201 GNRCC on Tables 3 and 4, respectively. A Site Plan that depicts the sampling locations and analytical data that exceeds Part 201 GNRCC is provided as Figure 2.



Preventing Exacerbation Soils with concentrations of hazardous substances that exceed Part 201 GNRCC Drinking Water Criteria have been identified on the north side of the Property at depths ranging from the ground surface to 4 feet below the ground surface (refer to Figure 2). Activities that are anticipated to be conducted during daily operations on the Property will not disturb the contaminated soils. Contaminated groundwater has been identified on the Property at depths ranging between 10 and 20 feet below the ground surface. Activities that are anticipated to be conducted during daily operations on the Property will not disturb the contaminated groundwater. Potable water is provided to the Property by the City of Kalamazoo municipal water supply. Site groundwater will not be utilized for any purposes. Any future activities on the Property that may result in the disruption of contaminated soils or contaminated groundwater will be performed in accordance with all applicable state and federal regulations, and a record describing the handling of the contaminated materials and their final disposition will be maintained. Subsurface work being conducted in the area of known contamination on the Property will be overseen by a qualified person. Certain earth-moving and construction activities (Activities) on the Property may result in the disruption of contaminated soils and/or contaminated groundwater. The Owner will confirm that site workers conducting Activities will be:

• provided the information of the known site contamination.

• required to conduct the Activities in accordance with all applicable local, state and federal regulations including Soil and Sedimentation Erosion Control measures.

• required to manage excess soils by properly characterizing, handling and disposing offsite.

• required to record a description of the handling of the contaminated soils and their final disposition.

• required to manage excess groundwater by properly characterizing, handling and disposing offsite.

• required to record a description of the handling of the contaminated groundwater and its final disposition.

• required to have subsurface work conducted in the area of known contamination on the Property overseen by a qualified person.

The performance of these actions will prevent the exacerbation of the identified environmental conditions. Mitigating Unacceptable Exposures Soils with concentrations of hazardous substances that exceed Part 201 NRGCC – DWPC have been identified on the north side of the Property. Groundwater with concentrations of hazardous substances that exceed Part 201 NRGCC – DWC have been identified on the north side of the Property (Figure 2). Potable water is provided to the Property by the City of Kalamazoo municipal water supply. The use of the municipal water supply will mitigate unacceptable exposure to contaminated groundwater. Certain earth-moving and construction activities (Activities) on the Property may result in exposure to soil contaminants. The Owner will confirm that site workers conducting Activities will be:

• made aware of proper management of excess soils.


• operating in accordance with a Health & Safety Plan.

• provided appropriate PPE.





These actions will protect against unacceptable exposure to contaminated soil and groundwater. All future site operations are anticipated to be conducted above the ground surface and/or within buildings. Site personnel are not anticipated to have contact with contaminated soil or contaminated groundwater during normal site operations. If subsurface activities are required (e.g., equipment/utility maintenance or repair), the contractor will be notified of the known contamination, activities will be overseen by a qualified person, and the activities will be conducted in accordance with all applicable state and federal regulations. Reasonable Precaution There will be Non-Residential activities on the Property in the future. All subsurface activities will be approved by the Owner of the Property and be conducted in accordance with all applicable state and federal regulations. These actions will protect against the reasonably foreseeable acts or omissions of a third party.



1.0 INTRODUCTION Following is the CA and DCP for the property located at 505 East Alcott Street, City of Kalamazoo, Kalamazoo County, Michigan (Property). A Site Location Map (Figure 1) and a Site Plan (Figure 2) are attached. The Property is owned by Kalamazoo County (Owner), who will use the Property for Non-Residential purposes. The Property consists of approximately 3 acres of undeveloped property that was formerly used for industrial purposes. The Property does not contain any improvements. Potable water is available from the City of Kalamazoo Municipal Water Supply. Sanitary sewer is available from the City of Kalamazoo Sanitary Sewer System. The Property adjoins Alcott Street to the south and Bryant Street to the north. The Property is accessed by driveways to both Alcott Street and Bryant Street. Further details on the historical documentation for the Property are provided in the F&V report Baseline Environmental Site Assessment, 505 East Alcott Street, City of Kalamazoo, Kalamazoo County, Michigan, dated January 2016 (2016 BEA). Based on results of the findings of the Phase I ESA, the following recognized environmental conditions (RECs) were identified for the Property:

1. Historical use of the Property as a portion of the former Performance Paper Company and listing as a portion of the Allied Paper/Portage Creek/Kalamazoo River Superfund Site.

2. The historical use and storage of coal on the Property. 3. The documented presence of soil contaminated with metals and PNAs above Part 201

GRCC. 4. The documented presence of groundwater contaminated with metals above Part 201

GRCC. 5. The documented releases of hazardous substances and petroleum products onto the

basement floor of Mill C. 6. The documented releases of hazardous substances and petroleum products into the Mill C

trench drains and sump in Building 34.



2.0 HAZARDOUS SUBSTANCE INFORMATION 2.1 Known Contamination F&V conducted a Phase II ESA to evaluate the RECs identified in the December 2015 Phase I ESA. The results of the Phase II ESA sampling and analysis are provided in the 2016 BEA. SB/TMW-1 was installed near the north Property boundary in an area that was formerly occupied by rail spurs and located hydraulically downgradient of the paper mill buildings. Soil sample SB-1 (2-3’) was collected from this test boring and contained arsenic at a concentration exceeding Part 201 GRCC. Numerous PNA compounds and metals were detected at concentrations below their respective Part 201 GRCC. Groundwater sample TMW-1 was collected at this location and contained tetrachloroethylene at a concentration equal to its Part 201 GRCC Drinking Water Criterion. SB/TMW-2 was installed near the north Property boundary in an area that was formerly occupied by rail spurs and located hydraulically downgradient of the paper mill buildings. Soil sample SB-2 (3-4’) was collected from this test boring and contained the following compounds at concentrations exceeding their respective Part 201 GRCC: carbon tetrachloride, naphthalene, tetrachloroethylene, trichloroethylene, xylenes and arsenic. Numerous VOCs, PNAs and metals were detected at concentrations below their respective Part 201 GRCC. Groundwater sample TMW-2 was collected at this location and contained tetrachloroethylene at a concentration exceeding its Part 201 GRCC Drinking Water Criterion. SB/TMW-3 was installed near the north Property boundary in an area that was formerly occupied by rail spurs and located hydraulically downgradient of the paper mill buildings. Soil sample SB-3 (3-4’) was collected from this test boring and contained arsenic at a concentration exceeding Part 201 GRCC. Numerous PNA compounds and metals were detected at concentrations below their respective Part 201 GRCC. Groundwater sample TMW-1 was collected at this location and contained tetrachloroethylene at a concentration below its Part 201 GRCC Drinking Water Criterion. SB/TMW-4 was installed near the north Property boundary in an area that was formerly occupied by rail spurs and located hydraulically downgradient of the paper mill buildings. A soil sample was not collected at this location. TMW-4 was collected at this location, and it did not contain tested compounds at concentrations exceeding Part 201 GRCC. A surficial soil sample (SS-2, 0-1’) was collected from undisturbed fill material near the north Property boundary. The sample contained arsenic and mercury at concentrations exceeding their respective Part 201 GRCC. Numerous PNA compounds and metals were detected at concentrations below their respective Part 201 GRCC. The hazardous substances carbon tetrachloride, naphthalene, tetrachloroethylene, trichloroethylene, xylenes, arsenic and mercury have been identified in the Property’s soil and the hazardous substance tetrachloroethylene has been identified in the Property’s groundwater at concentrations exceeding their respective GRCC, as defined in R299.5744 and R299.5746 of the NREPA. Detailed information associated with the known contamination (i.e., sample concentrations of hazardous substances that exceed GRCC) at the Property is provided in the 2016 BEA document prepared by F&V. Based on the results of the sampling and analysis, the Property was determined to be a facility, as defined in Section 20101(1)(r) of Part 201 of the NREPA, P.A. 451 of 1994, as amended, due to the presence of carbon tetrachloride, naphthalene, tetrachloroethylene, trichloroethylene, xylenes, arsenic and mercury in soils, and tetrachloroethylene in groundwater at concentrations, exceeding Part 201 GRCC.



The Property will be used for Non-Residential uses in the future, therefore the soil and groundwater data were compared to Part 201 Generic Non-Residential Cleanup Criteria (GNRCC). The detected concentrations of arsenic, carbon tetrachloride, tetrachloroethylene, and trichloroethylene in soil exceed their respective Part 201 GNRCC Drinking Water Protection Criteria (DWPC). None of the detected concentrations in soil exceed their respective Part 201 GNRCC DCC. Concentrations of detected hazardous substances in soil exceed Part 201 GNRCC GSIPC, however, there is no potential exposure pathway, therefore, this data is not relevant to the Property. The detected concentration of tetrachloroethylene in groundwater exceeds its Part 201 GNRCC Drinking Water Criterion (DWC). The soil and groundwater analytical data are summarized and compared to Part 201 GRCC and Part 201 GNRCC on Tables 3 and 4, respectively. A Site Plan that depicts the sampling locations and analytical data that exceeds Part 201 GNRCC is provided as Figure 2. 2.2 Exposure Pathway Evaluation

A migration pathway and exposure evaluation was conducted to identify certain human and environmental exposures. Potential exposure pathways are listed in relevant guidance documents issued by the MDEQ. The evaluation takes into consideration the Property’s likely future use. The exposure pathways potentially applicable to the Property are evaluated in the following sections. A complete exposure pathway is generally defined by the following four elements:

● A source of chemical release to the environment. ● An environmental medium for transport of the chemical (e.g., air, groundwater, or soil). ● A point of potential exposure for a receptor. ● A route of exposure for the receptor (e.g., ingestion, inhalation, or dermal contact).

An exposure pathway is considered complete or potentially complete, and exposure is considered possible, only if all four of the above elements are present (i.e., exposure is deemed applicable). Following is an evaluation of specific potential exposure pathways for the Property related to identified concentrations of hazardous substances that exceed GNRCC. 2.2.1 Drinking Water (DW) Applicable – Groundwater contamination has been identified on the Property at concentrations exceeding DW criteria. This pathway is relevant and is evaluated in Section 2.3. 2.2.2 Groundwater Direct Contact (GDC) Not Applicable – Groundwater contamination has not been identified at concentrations that exceed GDC criteria. This pathway is not relevant and does not need to be evaluated. 2.2.3 Groundwater Surface Water Interface (GSI) Not Applicable – Groundwater contamination has not been identified at concentrations that exceed GSI criteria. This pathway is not relevant and does not need to be evaluated. 2.2.4 Groundwater Volatilization to Indoor Air – Inhalation (GVIAI) Not Applicable – Groundwater contamination has not been identified at concentrations that exceed GVIAI criteria. This pathway is not relevant and does not need to be evaluated.



2.2.5 Non-Aqueous Phase Liquids (NAPLs) Not Applicable – NAPLs have not been identified on the Property. This pathway is not relevant and does not need to be evaluated. 2.2.6 Soil Direct Contact (SDC) Not Applicable – Soil contamination has not been identified at the Property at concentrations exceeding SDC criteria. This pathway is not relevant and does not need to be evaluated. 2.2.7 Soil Leaching to Drinking Water (SDW) Applicable – Soil contamination has been identified at concentrations that exceed SDW criteria. This pathway is relevant and is evaluated in Section 2.3. 2.2.8 Soil Leaching to Groundwater Direct Contact (SGDC) Not Applicable – Soil contamination has not been identified at concentrations that exceed SGDC criteria. This pathway is not relevant and does not need to be evaluated. 2.2.9 Soil Leaching to Groundwater Surface Water Interface (SGSI) Not Applicable – Soil contamination has not been identified at concentrations that could leach contamination to groundwater above SGSI criteria. This pathway is not relevant and does not need to be evaluated. 2.2.10 Soil Volatilization – Inhalation (SVI) Not Applicable – Soil contamination has not been identified at concentrations that exceed SVI criteria. This pathway is not relevant and does not need to be evaluated. 2.2.11 Soil Transport to Surface Water (STSW) Not Applicable – There are no surface water bodies at the Property. Soil contamination has not been identified at concentrations that exceed STSW criteria. This pathway is not relevant and does not need to be evaluated. 2.2.12 Soil Volatilization to Indoor Air – Inhalation (SVIAI) Not Applicable – Soil contamination has not been identified at concentrations that exceed SVIAI criteria. This pathway is not relevant and does not need to be evaluated. 2.2.13 Surface Water Sediments Not Applicable – there are no surface water bodies on the Property. This pathway is not relevant and does not need to be evaluated.



2.2.14 Exposure Pathway Summary The exposure pathway analysis is summarized as follows:

EXPOSURE PATHWAY APPLICABLE

NOT APPLICABL

E

Drinking Water X

Groundwater Direct Contact X

Groundwater Surface Water Interface X

Groundwater Volatilization to Indoor Air – Inhalation X

Non-Aqueous Phase Liquids (NAPLs) X

Soil Direct Contact X

Soil Leaching to Drinking Water X

Soil Leaching to Groundwater Direct Contact X

Soil Leaching to Groundwater Surface Water Interface X

Soil Volatilization – Inhalation X

Soil Transport to Surface Water X

Soil Volatilization to Indoor Air – Inhalation X

Surface Water Sediments X

Potentially complete human exposure pathways at the Property include: drinking water and contaminated soil leaching to drinking water. Table 1 (soil) and Table 2 (groundwater) compare detected hazardous substance concentrations above GNRCC to potential exposure pathways. 2.3 Exposure Controls This section details exposure controls for the identified relevant exposure pathways that have been determined to potentially be complete at the Property. 2.3.1 Ingestion of Drinking Water Municipal drinking water is provided to the Property. Groundwater contamination at the Property has been identified at concentrations that exceed DWC. There are no land use or resource restrictions in place for the Property that restrict the use of groundwater for drinking water purposes, therefore this exposure pathway has the potential to be completed. The municipal water supply will be utilized for potable water at the Property to prevent completion of this exposure pathway. 2.3.2 Soil Leaching to Drinking Water Soil contamination has been identified on a portion of the Property at concentrations that exceed DWPC. Municipal drinking water is available to the Property. There are no land use or resource restrictions in place for the Property that restrict the use of groundwater for drinking water purposes, therefore this exposure pathway has the potential to be completed. The municipal water supply will be utilized for potable water at the Property to prevent completion of this exposure pathway.



3.0 NOTIFICATIONS AND CONTAMINANT MITIGATION 3.1 Offsite Migration Notification There is no known offsite migration of contamination at the Property. An offsite migration notice has not been filed with the MDEQ, nor is it required for this Property. 3.2 Abandoned Container Notification There are no abandoned containers located on the Property. A notice of abandoned containers has not been filed with the MDEQ, nor is it required for this Property. 3.3 Easement Holder Notification Unacceptable (i.e., hazardous substances in soil or groundwater exceeding non-residential direct contact criteria) exposure risks to utility workers have not been identified at the Property. A notification to all identified easement holders that have the potential to be impacted by hazardous substances in soil or groundwater located on the Property is not necessary. 3.4 Mitigation of Fire and Explosion Hazards Fire or explosion hazards that would require their mitigation have not been identified.



4.0 DUE CARE SUMMARY 4.1 Preventing Exacerbation Soils with concentrations of hazardous substances that exceed Part 201 GNRCC Drinking Water Criteria have been identified on the north side of the Property at depths ranging from the ground surface to 4 feet below the ground surface (refer to Figure 2). Activities that are anticipated to be conducted during daily operations on the Property will not disturb the contaminated soils. Contaminated groundwater has been identified on the Property at depths ranging between 10 and 20 feet below the ground surface. Activities that are anticipated to be conducted during daily operations on the Property will not disturb the contaminated groundwater. Potable water is provided to the Property by the City of Kalamazoo municipal water supply. Site groundwater will not be utilized for any purposes. Any future activities on the Property that may result in the disruption of contaminated soils or contaminated groundwater will be performed in accordance with all applicable state and federal regulations, and a record describing the handling of the contaminated materials and their final disposition will be maintained. Subsurface work being conducted in the area of known contamination on the Property will be overseen by a qualified person. Certain earth-moving and construction activities (Activities) on the Property may result in the disruption of contaminated soils and/or contaminated groundwater. The Owner will confirm that site workers conducting Activities will be:



• required to manage excess soils by properly characterizing, handling and disposing offsite.

• required to record a description of the handling of the contaminated soils and their final disposition.

• required to manage excess groundwater by properly characterizing, handling and disposing offsite.

• required to record a description of the handling of the contaminated groundwater and its final disposition.


The performance of these actions will prevent the exacerbation of the existing conditions. 4.2 Mitigating Unacceptable Exposures Soils with concentrations of hazardous substances that exceed Part 201 NRGCC – DWPC have been identified on the north side of the Property. Groundwater with concentrations of hazardous substances that exceed Part 201 NRGCC – DWC have been identified on the north side of the Property (Figure 2). Potable water is provided to the Property by the City of Kalamazoo municipal water supply. The use of the municipal water supply will mitigate unacceptable exposure to contaminated groundwater. Certain earth-moving and construction activities (Activities) on the Property may result in exposure to soil contaminants. The Owner will confirm that site workers conducting Activities will be:

• made aware of proper management of excess soils.


• operating in accordance with a Health & Safety Plan.



• provided appropriate PPE.



These actions will protect against unacceptable exposure to contaminated soil and groundwater. All future site operations are anticipated to be conducted above the ground surface and/or within buildings. Site personnel are not anticipated to have contact with contaminated soil or contaminated groundwater during normal site operations. If subsurface activities are required (e.g., equipment/utility maintenance or repair), the contractor will be notified of the known contamination, activities will be overseen by a qualified person, and the activities will be conducted in accordance with all applicable state and federal regulations. 4.3 Reasonable Precaution There will be Non-Residential activities on the Property in the future. All subsurface activities will be approved by the Owner of the Property and be conducted in accordance with all applicable state and federal regulations. These actions will protect against the reasonably foreseeable acts or omissions of a third party.

FIGURES

SITE LOCATION MAP

KALAMAZOO COUNTY

FIGURE 1

505 EAST ALCOTT STREET, KALAMAZOO, MI

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825390_Fig1_SiteLoc / amberp 1/20/2016

APPROXIMATEPROPERTYBOUNDARY

APPROXIMATESITE LOCATIONKALAMAZOO CO.

Service Layer Credits: Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA,USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User CommunityEsri, HERE, DeLorme, MapmyIndia, © OpenStreetMap contributorsEsri, HERE, DeLorme, TomTom, MapmyIndia, © OpenStreetMap contributors, and the GIS user community

FIGURE 2

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825390

KALAMAZOO COUNTY


SITE PLAN SHOWING ANALYTICAL DATA

NORTH

1" = 50'

LEGEND:

SOIL BORING/ TEMPORARY

MONITORING WELL (SB/TMW)

SURFACE SOIL SAMPLE (SS)

SAMPLE ID (SCREENED or SAMPLE INTERVAL BELOW GRADE)

Analytical values exceeding one or more criteria - ##

Analytical values below criteria are not shown.

All groundwater samples results are reported in ug/L

All soil samples results are reported in ug/kg

CPC - Carbon Tetrachloride

Naph - Naphthalene

PCE - Tetrachloroethylene

TCE - Trichloroethylene

All samples were collected by F&V on 12/16/2015

SB-1 (2'-3')

Arsenic - 22,000

TMW-1 (15'-20')

PCE - 5

SB-3 (3'-4')

Arsenic - 12,000

TMW-3 (19.5'-14.5')

All analyzed parametersbelow applicable criteria.

SS-2 (0'-1')

Arsenic - 27,000 Mercury - 590

SB-2 (3'-4')

CPC - 490 Naph - 1,200 PCE - 3,800 TCE - 3,000 Xylenes - 1,600 Arsenic - 22,000

TMW-12 (9.5'-14.5')

PCE - 5.7

TMW-4 (9'-14')


AutoCAD SHX Text

825390_Fig2_Analytical / amberp 012816 / amberp 012816amberp 012816 012816012816

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SCALE IN FEET

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TABLES

Table 1: Soil Analytical Results Summary

825390 East Alcott Street

December 2015

Sampling Location SB-1 SB-2 SB-3 SS-2 Trip

Sampling Interval 2-3' 3-4' 3-4' 0-1' Blank Non-Residential Criteria Criteria

Collection Date 12/16/2015 12/16/2015 12/16/2015 12/16/2015 12/16/2015

Hazardous Substance

Chemical

Abstract

Service

Number

Statewide

Default

Background

Level

Non-residential

Drinking Water

Protection

Criteria &

RBSLs

Non-residential Direct

Contact Criteria &

RBSLs

Non-Residential Soil

Volatilization to

Indoor Air Inhalation

Criteria & RBSLs

Residential

Drinking Water

Protection Criteria

& RBSLs

Groundwater

Surface Water

Interface

Protection Criteria

& RBSLs

Residential

Soil

Volatilization to

Indoor Air

Inhalation

Criteria &

RBSLs

Residential

Direct Contact

Criteria &

RBSLs

VOLATILES (8260B)

Benzene (I) 71432 <33 70 <34 <43 <30 NA 100 8.4E+5(C) 8,400 100 4,000 (X) 1,600 1.80E+05

Carbon tetrachloride 56235 <33 490 <34 <43 <30 NA 100 4.4E+5(C) 990 100 900 (X) 190 96,000

Ethylbenzene (I) 100414 <33 150 <34 <43 <30 NA 1,500 7.1E+7(C) 4.6E+5 (C) 1,500 360 87,000 2.2E+7 (C)

n-Hexane 110543 <110 320 <110 <140 <100 NA 5.1E+5(C) 3.0E+8(C) 9.5E+5 (C) 1.8E+5 (C) NA 5.1E+5 (C) 9.2E+7 (C)

Isopropyl benzene 98828 <33 73 <34 <43 <30 NA 2.60E+05 8.0E+7(C) 7.3E+5 (C) 91,000 3,200 4.0E+5 (C) 2.5E+7 (C)

2-Methylnaphthalene 91576 180 1,200 160 300 <30 NA 1.70E+05 2.6E+7 4.9E+6 57,000 4,200 2.70E+06 8.10E+06

Naphthalene 91203 <110 1,200 <110 <140 <100 NA 1.0E+5 5.2E+7 4.7E+5 35,000 730 2.50E+05 1.60E+07

n-Propylbenzene (I) 103651 <33 100 <34 <43 <30 NA 4,600 8.0E+6 ID 1,600 ID ID 2.50E+06

Tetrachloroethylene 127184 37 3,800 <34 <43 <30 NA 100 9.3E+5 (C) 21,000 100 1,200 (X) 11,000 2.0E+5 (C)

Toluene (I) 108883 <33 730 <34 46 <30 NA 16,000 1.6E+8 (C) 6.1E+5 (C) 16,000 5,400 3.3E+5 (C) 5.0E+7 (C)

Trichloroethylene 79016 <33 3,000 <34 <43 <30 NA 100 6.6E+5 (C,DD) 1,900 100 4,000 (X) 1,000 1.1E+5 (C,DD)

1,2,4-Trimethylbenzene (I) 95636 <33 410 <34 <43 <30 NA 2,100 1.0E+8 (C) 8.0E+6 (C) 2,100 570 4.3E+6 (C) 3.2E+7 (C)

1,3,5-Trimethylbenzene (I) 108678 <33 130 <34 <43 <30 NA 1,800 1.0E+8 (C) 4.8E+6 (C) 1,800 1,100 2.6E+6 (C) 3.2E+7 (C)

Xylenes (I) 1330207 <99 1,600 <100 <130 <90 NA 5,600 1.0E+9 (C,D) 1.2E+7 (C) 5,600 820 6.3E+6 (C) 4.1E+8 (C)

SEMIVOLATILES (8270C)Acenaphthene 83329 47 9.8 15 <83 -- NA 8.8E+5 1.3E+8 3.5E+8 3.00E+05 8,700 1.90E+08 4.10E+07

Acenaphthylene 208968 210 <7.9 38 <83 -- NA 5,900 5.2E+6 3.0E+6 5,900 ID 1.60E+06 1.60E+06

Anthracene 120127 240 56 61 210 -- NA 41,000 7.3E+8 1.0E+9 (D) 41,000 ID 1.0E+9 (D) 2.30E+08

Benzo(a)anthracene (Q) 56553 1,300 220 300 640 -- NA NLL 80,000 NLV NLL NLL NLV 20,000

Benzo(a)pyrene (Q) 50328 1,400 220 300 630 -- NA NLL 8,000 NLV NLL NLL NLV 2,000

Benzo(b)fluoranthene (Q) 205992 2,000 330 450 1,000 -- NA NLL 80,000 ID NLL NLL ID 20,000

Benzo(g,h,i)perylene 191242 850 190 210 490 -- NA NLL 7.0E+6 NLV NLL NLL NLV 2.50E+06

Benzo(k)fluoranthene (Q) 207089 730 86 160 430 -- NA NLL 8.0E+5 NLV NLL NLL NLV 2.00E+05

Chrysene (Q) 218019 1,300 320 310 810 -- NA NLL 8.0E+6 ID NLL NLL ID 2.00E+06

Dibenzo(a,h)anthracene (Q) 53703 230 54 53 190 -- NA NLL 8,000 NLV NLL NLL NLV 2,000

Fluoranthene 206440 2,500 370 510 1,500 -- NA 7.3E+5 1.3E+8 1.0E+9 (D) 7.30E+05 5,500 1.0E+9 (D) 4.60E+07

Fluorene 86737 74 <7.9 24 <83 -- NA 8.9E+5 8.7E+7 1.0E+9 (D) 3.90E+05 5,300 5.80E+08 2.70E+07

Indeno(1,2,3-cd)pyrene (Q) 193395 990 150 220 570 -- NA NLL 80,000 NLV NLL NLL NLV 20,000

2-Methylnaphthalene 91576 91 1,100 29 330 -- NA 1.7E+5 2.6E+7 4.9E+6 57,000 4,200 2.70E+06 8.10E+06

Naphthalene 91203 78 720 26 210 -- NA 1.0E+5 5.2E+7 4.7E+5 35,000 730 2.50E+05 1.60E+07

Phenanthrene 85018 1,000 790 260 930 -- NA 1.6E+5 5.2E+6 5.1E+6 56,000 2,100 2.80E+06 1.60E+06

Pyrene 129000 1,000 360 450 1,200 -- NA 4.8E+5 8.4E+7 1.0E+9 (D) 4.80E+05 ID 1.0E+9 (D) 2.90E+07

Residential

FLEIS & VANDENBRINK ENGINEERING, INC. Page 1 of 2 Table 1: Soil Analytical Results Summary

Table 1: Soil Analytical Results Summary


December 2015

Sampling Location SB-1 SB-2 SB-3 SS-2 Trip

Sampling Interval 2-3' 3-4' 3-4' 0-1' Blank Non-Residential Criteria Criteria

Collection Date 12/16/2015 12/16/2015 12/16/2015 12/16/2015 12/16/2015

Hazardous Substance

Chemical

Abstract

Service

Number

Statewide

Default

Background

Level

Non-residential

Drinking Water

Protection

Criteria &

RBSLs

Non-residential Direct

Contact Criteria &

RBSLs

Non-Residential Soil

Volatilization to

Indoor Air Inhalation

Criteria & RBSLs

Residential

Drinking Water

Protection Criteria

& RBSLs

Groundwater

Surface Water

Interface

Protection Criteria

& RBSLs

Residential

Soil

Volatilization to

Indoor Air

Inhalation

Criteria &

RBSLs

Residential

Direct Contact

Criteria &

RBSLs

Residential

METALSArsenic 7440382 22,000 22,000 12,000 27,000 -- 5,800 4,600 37,000 NLV 4,600 4,600 NLV 7,600

Barium (B) 7440393 100,000 140,000 180,000 120,000 -- 75,000 1.3E+6 1.3E+8 NLV 1.30E+06 (G) NLV 3.70E+07

Cadmium (B) 7440439 <560 <770 <690 990 -- 1,200 6,000 2.1E+6 NLV 6,000 (G,X) NLV 5.50E+05

Chromium (III) (B,H) 16065831 8,100 8,300 7,600 15,000 -- 18,000 (total) 1.0E+9 (D) 1.0E+9 (D) NLV 1.0E+9 (D) (G,X) NLV 7.90E+08

Chromium (VI) 18540299 NA 30,000 9.2E+6 NLV 30,000 3,300 NLV 2.50E+06

Copper (B) 7440508 18,000 22,000 11,000 48,000 -- 32,000 5.8E+6 7.3E+7 NLV 5.80E+06 (G) NLV 2.00E+07

Lead (B) 7439921 47,000 72,000 55,000 180,000 -- 21,000 7.0E+5 (DD) NLV 7.00E+05 (G,X) NLV 4.00E+05

Mercury (Total) (B,Z) Varies 52 62 41 590 -- 130 1,700 5.8E+5 89,000 1,700 50 (M); 1.2 48,000 1.60E+05

Selenium (B) 7782492 <1,400 <1,900 <1,700 <1,800 -- 410 4,000 9.6E+6 NLV 4,000 400 NLV 2.60E+06

Silver (B) 7440224 <1,400 <1,900 <1,700 <1,800 -- 1,000 13,000 9.0E+6 NLV 4,500 100 (M); 27 NLV 2.50E+06

Zinc (B) 7440666 54,000 42,000 48,000 240,000 -- 47,000 5.0E+6 6.3E+8 NLV 2.40E+06 (G) NLV 1.70E+08

*Part 201 Residential and Non-residential Generic Cleanup Criteria, Part 213 Tier 1 Risk-Based Screening Levels (RBSLs), MDEQ, December 31, 2013

Values in micrograms per kilogram (µg/kg).

Bolded values exceed one or more of the criterion.

FLEIS & VANDENBRINK ENGINEERING, INC. Page 2 of 2 Table 1: Soil Analytical Results Summary

Table 2: Groundwater Analytical Results Summary


December 2015

Sampling Location TMW-1 TMW-2 TMW-3 TMW-4 Trip

Screened Interval (feet bgs) 15-20 9.5-14.5 9.5-14.5 9-14 Blank

Collection Date 12/16/2015 12/16/2015 12/16/2015 12/16/2015 12/16/2015 #1 #2 #3 #4 #5 #7 #8

Hazardous Substance

Chemical

Abstract

Service

Number

Residential Drinking

Water Criteria

Nonresidential Drinking

Water Criteria

Groundwater Surface

Water Interface

Criteria

Residential

Groundwater

Volatilization to

Indoor Air

Inhalation Criteria

Nonresidential

Groundwater

Volatilization to

Indoor Air

Inhalation Criteria Water Solubility

Flammability and

Explosivity

Screening Level

VOLATILES (8260B)1,1-Dichloroethane 75343 <1 4.3 <1 <1 <1 880 2,500 740 1.00E+06 2.30E+06 5.06E+06 3.80E+05

cis-1,2-Dichloroethylene 156592 <1 6.6 <1 <1 <1 70 (A) 70 (A) 620 93,000 2.10E+05 3.50E+06 5.30E+05

Tetrachloroethylene 127184 5 5.7 1.2 <1 <1 5.0 (A) 5.0 (A) 60 (X) 25,000 1.70E+05 2.00E+05 ID

1,1,1-Trichloroethane 71556 1.8 <1 <1 <1 <1 200 (A) 200 (A) 89 6.60E+05 1.3E+6 (S) 1.33E+06 ID

Trichloroethylene 79016 1.1 3 <1 <1 <1 5.0 (A) 5.0 (A) 200 (X) 2,200 4,900 1.10E+06 ID

Vinyl chloride 75014 <1 1.4 <1 <1 <1 2.0 (A) 2.0 (A) 13 (X) 1,100 13,000 2.76E+06 33,000

METALSArsenic 7440382 <5 <5 <5 <5 -- 10 (A) 10 (A) 10 NLV NLV NA ID

Barium (B) 7440393 140 69 40 190 -- 2,000 (A) 2,000 (A) (G) NLV NLV NA ID

Cadmium (B) 7440439 <2 <2 <2 <2 -- 5.0 (A) 5.0 (A) (G,X) NLV NLV NA ID

Chromium (III) (B,H) 16065831 100 (A) 100 (A) (G,X) NLV NLV NA ID

Chromium (VI) 18540299 100 (A) 100 (A) 11 NLV NLV NA IDCopper (B) 7440508 <5 <5 <5 12 -- 1,000 (E) 1,000 (E) (G) NLV NLV NA ID

Lead (B) 7439921 <5 <5 <5 <5 -- 4.0 (L) 4.0 (L) (G,X) NLV NLV NA ID

Mercury (Total) (B,Z) Varies <0.2 <0.2 <0.2 <0.2 -- 2.0 (A) 2.0 (A) 0.0013 56 (S) 56 (S) 56 ID

Selenium (B) 7782492 <5 <5 <5 <5 -- 50 (A) 50 (A) 5 NLV NLV NA ID

Silver (B) 7440224 <5 <5 <5 <5 -- 34 98 0.2 (M); 0.06 NLV NLV NA ID

Zinc (B) 7440666 <10 <10 <10 <10 -- 2,400 5,000 (E) (G) NLV NLV NA ID

*Part 201 Residential Generic Cleanup Criteria and Screening Levels; Part 213 Tier 1 Risk-Based Screening Levels (RBSLs), MDEQ, December 31, 2013

Values in micrograms per liter (µg/L).

Bolded values exceed one or more of the criterion.

--<5 <5 <5 26

FLEIS & VANDENBRINK ENGINEERING, INC. Page 1 of 1 Table 2: Groundwater Analytical Results Summary

DUE CARE PLAN Tables


Table 1 – Hazardous Substance Concentrations and GNRCC Comparison for Soil Due Care Plan 505 East Alcott Street, Kalamazoo, Michigan

Hazardous Substance

CAS Number

Location and Depth (ft bgs)

Concentration (µg/kg)

Criteria Exceeded

DWP DC GSIP

Carbon Tetrachloride

56235 SB-02 3-4’

490 X

Tetrachloroethylene 127184 SB-02 3-4’

3,800 X

Trichloroethylene 79016 SB-02 3-4’

3,000 X

CAS – Chemical Abstract Service ft bgs – feet below ground surface µg/kg – microgram per kilogram DWP – Drinking Water Protection DC – Direct Contact GSIP – Groundwater Surface Water Interface Protection

Table 2 – Hazardous Substance Concentrations and GNRCC Comparison for Groundwater Due Care Plan 505 East Alcott Street, Kalamazoo, Michigan

Hazardous Substance

CAS Number

Location and Depth (ft

bgs)

Concentration (µg/L)

Criteria Exceeded

DW DC GSI

Tetrachloroethylene 127184 TW-1 15-20’

5 X


5.7 X

CAS – Chemical Abstract Service ft bgs – feet below ground surface µg/kg – microgram per kilogram DW – Drinking Water DC – Direct Contact GSI – Groundwater Surface Water Interface

ATTACHMENT 1

NOTICE TO CONTRACTORS 505 East Alcott Street, Kalamazoo, Michigan

NOTICE Soil and groundwater contamination is present on this site. All Contractors performing subsurface work on this site must conform with the provisions stipulated within this notice. CONTAMINATION SUMMARY Environmental investigations have been conducted at the site and the hazardous substances carbon tetrachloride, naphthalene, tetrachloroethylene, trichloroethylene, xylenes, arsenic and mercury have been identified in the Property’s soil and the hazardous substance tetrachloroethylene has been identified in the Property’s groundwater at concentrations exceeding their respective Part 201 Generic Residential Cleanup Criteria. The attached Figure shows the location and concentrations of the known contamination. HEALTH AND SAFETY It is recommended that the Contractor prepare a Health and Safety Plan to protect their workers against unacceptable exposure to site contamination. The attached tables list the contamination at the site that exceeds Part 201 Non-Residential Criteria. DUE CARE ACTIONS The contractor shall comply with all the Due Care Actions listed below:

• All subsurface work must be approved by the Owner in advance.

• All work will be required to be conducted in accordance with Soil and Sedimentation Erosion Control measures, as required by the implementing agency.

• If construction dewatering is necessary during site development activities, any purged groundwater will be properly characterized, handled and discharged in accordance with applicable local, state and federal regulations.

• Any excess soils generated on the site that have to be removed for offsite disposal will be properly characterized, handled and disposed in accordance with applicable local, state and federal regulations.

REPORTING Contractor shall provide Owner or the designated Owner’s Representative with copies of all permits, waste characterization information and analytical data, and waste disposal documentation.

NOTICE TO CONTRACTORS 505 East Alcott Street, Kalamazoo, Michigan

Table 1 – Hazardous Substance Concentrations and GNRCC Comparison for Soil Due Care Plan 505 East Alcott Street, Kalamazoo, Michigan

Hazardous Substance

CAS Number

Location and Depth (ft bgs)

Concentration (µg/kg)

Criteria Exceeded

DWP DC GSIP

Carbon Tetrachloride

56235 SB-02 3-4’

490 X

Tetrachloroethylene 127184 SB-02 3-4’

3,800 X

Trichloroethylene 79016 SB-02 3-4’

3,000 X

CAS – Chemical Abstract Service ft bgs – feet below ground surface µg/kg – microgram per kilogram DWP – Drinking Water Protection DC – Direct Contact GSIP – Groundwater Surface Water Interface Protection

Table 2 – Hazardous Substance Concentrations and GNRCC Comparison for Groundwater Due Care Plan 505 East Alcott Street, Kalamazoo, Michigan

Hazardous Substance

CAS Number

Location and Depth (ft

bgs)

Concentration (µg/L)

Criteria Exceeded

DW DC GSI


5 X


5.7 X

CAS – Chemical Abstract Service ft bgs – feet below ground surface µg/kg – microgram per kilogram DW – Drinking Water DC – Direct Contact GSI – Groundwater Surface Water Interface

FIGURE 2

F&

V P

RO

JE

CT

N

O.

825390

KALAMAZOO COUNTY


SITE PLAN SHOWING ANALYTICAL DATA

NORTH

1" = 50'

LEGEND:

SOIL BORING/ TEMPORARY

MONITORING WELL (SB/TMW)

SURFACE SOIL SAMPLE (SS)

SAMPLE ID (SCREENED or SAMPLE INTERVAL BELOW GRADE)

Analytical values exceeding one or more criteria - ##

Analytical values below criteria are not shown.

All groundwater samples results are reported in ug/L

All soil samples results are reported in ug/kg

CPC - Carbon Tetrachloride

Naph - Naphthalene

PCE - Tetrachloroethylene

TCE - Trichloroethylene

All samples were collected by F&V on 12/16/2015

SB-1 (2'-3')

Arsenic - 22,000

TMW-1 (15'-20')

PCE - 5

SB-3 (3'-4')

Arsenic - 12,000

TMW-3 (19.5'-14.5')


SS-2 (0'-1')

Arsenic - 27,000 Mercury - 590

SB-2 (3'-4')

CPC - 490 Naph - 1,200 PCE - 3,800 TCE - 3,000 Xylenes - 1,600 Arsenic - 22,000

TMW-12 (9.5'-14.5')

PCE - 5.7

TMW-4 (9'-14')


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