Ge: Doyle: Wilso^IEPA

0

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1 r C EC ~ w ~ SOf EOf . J E V ' - P

f H. AC-»O il uiur,. «•>

September 18, 2014

Naren M . Prasad, P.E., MPH integrys Business Support, LLC 20;0 East Randolph Streeti/ptfi Floor Chicago, Illinois 60601.

Re- PGL SawfoM Station: Farmer MGP Site. ^Removal. Action WorfcPlau- Addendum IA Expanded Parcel L R A A (9/10/14)

^ Administrative Order on Gonsent (Docket M&,'. WW-08-G-917)

Dear Mr. Prasad:

The; Ujriied jtates ErryirpnrrienM Agency (EPA): reviewed ttle:r©vised Mmk plan: for me trme-erJic^ site:(SSID; B5HK). The proposed work involves additional removal of source material at Parcel 1, adjacent to Parcel L. Based on EPA's review, the work plan, dated September 10, 2014, is acceptable and is hereby approved. This action/is consistent with provisions of the the-AdltoM'Su^liy^-Orier on Consent (Docket No. V-W-08-C-917).

Your attention on this matter is appreciated. I can be reachedat: (312) #86-6195.

Ross del Rosario Plemedial Projectl^anager

Ge: Doyle: Wilso^IEPA

N A T U R A L

R E S O U R C E

T E C H N O L O G Y

3 0 0 S . W A C K E R D R I V E , S U I T E 2 0 5 0

C H I C A G O , I L L I N O I S 6 0 6 0 6

(P) 3 1 2 . 4 6 5 . 1 7 4 0

(F) 4 1 4 . 8 3 7 . 3 6 0 8 E N V I R O N M E N T A L C O N S U L T A N T S

Mr. Ross del Rosario USEPA Region 5 - SR-6J

September 10, 2014 (2037.1)

77 W. Jackson Boulevard Chicago, Illinois 60604-3590

RE: Expanded Source Removal Notification and RAWP Removal Action Area Parcel L Former Crawford Station MGP Site, Chicago, Illinois Peoples Gas Light and Coke Company CERCLA Docket No. V-W-08-C-917 CERCLIS ID - ILN0000510192

Dear Mr. del Rosario:

Natural Resource Technology, Inc. (NRT), on behalf of Integrys Business Support, LLC (IBS), is submitting this Expanded Source Removal Notification and associated Removal Action Work Plan (RAWP) Addendum 1A. Excavation activities and subsequent soil boring investigation conducted during the Removal Action work described in the RAWP Addendum 1, Revision 1 (RAWP Add.1, Rev.1), has revealed the presence of additional source material in the southwestern portion of Parcel L which extends to the adjacent Parcel I.

To facilitate the removal of the observed source material, the Removal Action Area (RAA) will be extended to the southwest. This area, Extended Removal Action Area, will be excavated to remove observed source material consistent with the procedures and processes outlined in the RAWP Add.1, Rev.1 submitted to and approved by USEPA in December, 2013. Attached please find RAWP Addendum 1A, an updated version of the previously approved RAWP Add.1, Rev.1, detailing the procedures and activities to be used during the expanded source removal.

Please contact Mr. Naren Prasad of IBS at 312.240.4569 if you have any questions regarding the content ofthis submittal.

Sincerely,

NATURAL RESOURCE TECHNOLOGY, INC.

Attachment: Former Crawford Station MGP Site - Expanded Parcel L RAA RAWP Add 1A

cc: Mr. Doyle Wlson, IEPA Springfield (one hard copy and one CD copy) Mr. Peter Felitti, USEPA (CD copy only) Mr. Dave Klatt, CH2MHNI (via email) Mr. Naren Prasad, IBS (via email)

Timothy B. Norris, P.G. Project Manager

W W W . N A T U R A L R T . C O M

Removal Action Work Plan Addendum 1A - Expanded Parcel L RAA

The Peoples Gas Light and Coke Company Former Crawford Station MGP Site Chicago, Illinois

Project No: 2037.1

September 10, 2014

' N A T U R A L JI I I I .III

R E S O U R C E ' l ifjl^li T E C H N O L O G Y III . | | |

E N V I R O N M E N T A L C O N S U L T A N I S

"1 NATURAL

£ ^ M RESOURCE

Q ^ ^ H T E C H N O L O G Y

3 0 0 S . W A C K E R D R I V E , S U I T E 2 0 5 0

C H I C A G O , I L L I N O I S 6 0 6 0 6

(P) 3 1 2 . 4 6 5 . 1 7 4 0

(F) 4 1 4 . 8 3 7 . 3 6 0 8 E N V I R O N M E N T A L C O N S U L T A N T S

REMOVAL ACTION WORK PLAN ADDENDUM 1A - EXPANDED PARCEL L RAA

THE PEOPLES GAS LIGHT AND COKE COMPANY FORMER CRAWFORD STATION MGP SITE

CHICAGO, ILLINOIS

CERCLA Docket No. V-W-11-C-981 CERCLIS ID - ILN0000510192

Project No. 2037.1

Prepared For:

Integrys Business Support, LLC 200 E. Randolph Street, 24th Floor

Chicago, Illinois 60601

Prepared By:

Natural Resource Technology, Inc. 300 S. Wacker Drive, Suite 2050

Chicago, Illinois 60606

September 10, 2014

Timothy B. Norris, PG Geologist

Environmental Engineer

W W W . N A T U R A L R T . C O M

TABLE OF CONTENTS

1 INTRODUCTION 1

1.1 Overview 1

1.2 Project Background Information 2

1.3 Site History 2

1.4 Site Description 2

1.5 Previous Investigations 2

1.6 Prior Remedial Activities 3

2 SUMMARY OF SITE CONDITIONS 4

2.1 Site Geology and Hydrogeology 4

2.2 Pre-Removal Site Characterization Activities and Findings 4

2.3 Utilities and Site Constraints 5

2.3.1 Existing Utilities 5

2.3.2 Site Ownership 6

2.4 Soil Data Compilation and Interpolation 6

2.5 Characterization of Material for Disposal 7

2.6 Risk to Public Health, Welfare or the Environment 7

3 BASIS FOR REMOVAL ACTION 8

3.1 Removal Action Objectives and Strategy 8

3.2 MGP Source Material Definition 8

3.3 Removal Action Decision Criteria 8

3.4 Estimated Removal Volume 8

4 REMOVAL ACTION IMPLEMENTATION 9

4.1 Preliminary Activities 9

4.1.1 Site Security and Controls 9

4.1.2 Surveying 9

4.2 Site Preparation 9

4.2.1 Protection of Utilities and Construction Utilities 9

4.2.2 Runoff and Erosion Control 10

4.2.3 Clearing and Grubbing 10

4.2.4 Route of Ingress and Egress for Construction 10

4.3 Fugitive Emission Control 10

4.4 Removal Action Operations 11

4.4.1 Shoring 11

4.4.2 Targeted Excavation 11

4.4.2.1 Non-MGP Impacted Construction Debris 12

4.4.2.2 MGP Source Matenal 13

4.4.2.3 MGP Source Material at or above the Subtitle D Landfill Permit Limits ..13

4.4.2.4 Overburden Material 13

4.4.3 On-site Materials Management 13

4.4.4 Excavation Dewatering '. 13

2037 Crawford RAWP Addendum 1A Expanded Parcel L RAA - Final

TABLE OF CONTENTS

4.4.5 Equipment Decontamination 13

4.5 Site Restoration 14

5 STATE AND LOCAL REQUIREMENTS 15

5.1 Storm Water Discharge 15

5.2 Governmental Coordination 15

5.3 Off-Site Disposal 15

6 CONSTRUCTION QUALITY ASSURANCE MEASURES 16

6.1 Air Monitonng Plan 16

6.1.1 Time Weighted Average (24-Hour) Perimeter Air Monitoring 17

6.1.3 Assessment of Meteorological Conditions 18

6.1.4 Action Levels 18

6.2 Fugitive Emissions Management Plan 19

6.3 Health and Safety Plan 19

6.4 Sampling and Analysis Plan 19

7 SCHEDULE 20

7.1 Schedule for Construction 20

7.2 Removal Action Completion Report 20

8 REFERENCES 21

FIGURES

Figure 1 Site Location

Appendix B Site-Specific Perimeter Air Monitoring Acceptable Air Concentrations - Technical

Figure 5 MGP Source Material Removal Extents

Figure 6 Excavation Site Layout and Preparation Plan

Figure 7 Air Monitoring Response Plan Flowchart

TABLES

Table 1 Sampling and Analysis Plan Summary

APPENDICES

Appendix A Pre-Removal Site Characterization Data

A1: Soil Boring Logs

A2: Laboratory Analytical Reports

Appendix B Site-Specific Perimeter Air Monitoring Accept Memorandum

2037 Crawford RAWP Addendum 1A Expanded Parcel L RAA - Final ii

Crawford Station MGP Site - Expanded Parcel L RAA Removal Action Work Plan Addendum 1A

September 10, 2014 Section 1 - Introduction

Page 1 of 21

1 INTRODUCTION

1.1 Overview

This document serves as Addendum 1A to the Removal Action Work Plan (RAWP), Revision 1, dated

September 6, 2011 (RAWP Rev. 1) for the former Crawford Station Manufactured Gas Plant (MGP) site in

Chicago, Illinois (Figure 1). In order to complete the objectives of the Time Critical Removal Action

(TCRA) activities currently underway at the Former Crawford Station MGP site, the existing Parcel L

Removal Action Area (RAA) will be expanded to incorporate recently discovered source material

southwest of Parcel L on the adjacent parcel. This Addendum details the expansion of the removal action

on to the adjacent Parcel I to continue the removal of source material associated with the former MGP.

Parcel I is an approximate 5-acre parcel adjacent to Parcel L to the southwest. Peoples Gas Light and

Coke Company (PGL), a subsidiary of Integrys Energy Group, owned the former MGP. Parcel I is

currently owned by Kostner/Chicago, LLC and is operated by LaGrou Cold Storage Partnership. An

access agreement will be obtained by Integrys Business Support, LLC (IBS) in advance of the initiation of

the expanded removal action. IBS will continue to provide oversight for the removal activities on behalf of

During the current excavation activities performed according to the Removal Action Work Plan,

Addendum 1, Revision 1 (RAWP Add.1, Rev.1), it was determined that source material from Parcel L

appeared to extend on to the adjacent Parcel I to the southwest. As a result, preliminary investigation

steps were conducted as part of the removal action work. This investigation identified MGP source

material from Parcel L subsurface soils extended to Parcel I of the Crawford Station MGP site.

Accordingly, this Addendum has been prepared to address the need for the Parcel L RAA to be expanded

to allow for the removal of the continuous plume of source material onto Parcel I as a continuation of the

current TCRA.

This RAWP Addendum, prepared pursuant to the Administrative Settlement Agreement and Order on

Consent for Removal Action, Docket No. V-W-11-C-981, dated October 12, 2011 (Settlement

Agreement), outlines the scope of the proposed removal action to be undertaken on the Expanded Parcel

L RAA as an expansion of the TCRA currently underway on Parcel L. This removal action will focus on

removing MGP residuals that have been characterized as source material. This portion of the removal

action encompasses only one portion of the Crawford Station MGP site and is intended as an interim


PGL.

[NATURAL I RESOURCE [TECHNOLOGY



Page 2 of 21

action to address subsurface MGP source material. IBS intends to accomplish substantial work on the

referenced area, such that the removal action will contribute to the overall Site remediation goals.

1.2 Project Background Information

See RAWP Add.1, Rev. 1, Section 1.2 (page 2) for project background information. Specific location

information for the Expanded Parcel L RAA is as follows.

Geographic Coordinates: Lat. 41° 49' 39" N Long. 87° 44'04" W

Street Address: 3559 S. Kostner Avenue, Chicago, IL

1.3 Site History

See RAWP Add.1, Rev. 1, Section 1.3 (page 2) for Site history.

1.4 Site Description

See RAWP Add. 1, Rev. 1, Section 1.4 (page 2) for overall Site description.

The Expanded Parcel L RAA incorporates Parcel I, which comprises approximately 5 acres of land,

located in the central portion of the Crawford Station MGP site adjacent to Parcel L. The Expanded

Parcel L RAA Work Zone has been designated to encompass the majority of Parcel I and a portion of

Parcel L. The planned excavation areas are located on the adjacent Parcel I; however, existing

infrastructure on Parcel L will be utilized during the removal action to facilitate operations such as

weighing and loading of trucks, vehicle decontamination, soil amendment (if necessary) and related

construction support tasks. The existing Parcel L RAA, the Expanded Parcel L RAA, the Expanded Parcel

L RAA Work Zone and the proposed extent of excavation are shown on Figure 6. Land use of the

surrounding area is presented on Figure 3.

1.5 Previous Investigations

Refer to the Completion Report, Revision 0, dated December 23, 2011 (Completion Report Rev 0) for a

compilation of previous investigation activity and findings. Section 5 of the Completion Report Rev. 0

(page 84) provides a list of the prior environmental reports and documents pertaining to the Crawford

Station MGP site. According to the historical document review, no previous remedial investigations have

been performed on the Expanded Parcel L RAA. Preliminary source material delineation performed as

part of the removal action work on Parcel L is discussed in Section 2.2 of this Report.




Page 3 of 21

1.6 Prior Remedial Activities

Remedial activities have been conducted on various portions of the Crawford Station MGP site. This

expanded removal action will focus on the source material located to the southwest of Parcel L, on the

adjacent Parcel I. Based on assessment of historical information, no documented remedial activities have

previously been performed on the expanded Parcel L RAA.



September 10, 2014 Section 2 - Summary of Site Conditions

Page 4 of 21

2 SUMMARY OF SITE CONDITIONS

2.1 Site Geology and Hydrogeology

The general geological setting of Crawford Station MGP site is described in the RAWP Add.1, Rev. 1,

Section 2.1 (page 3) as well as the Completion Report Rev. 0, Section 2.4 (page 38) and Section 2.5

(page 39). Details specific to the Expanded Parcel L RAA are as follows:

• Fill Unit - Asphalt/gravel is present at the surface and is approximately 6 to 18-inches thick. The surficial fill unit generally ranges from 4 to 14 feet in thickness. The fill consisted primarily of gravel and sand with smaller amounts of silt, clay, bricks, cinders, glass, and wood.

• Brown/Gray Siltv Clay Unit - Underlying the fill unit is a brown/gray silty clay unit and generally becomes increasingly stiff with depth. The unit is a medium to stiff silty clay with trace to some sand and gravel.

• Gray Silty Clay Unit - Underlying the brown/gray silty clay unit is a native gray silty clay unit. The top of the gray silty clay unit was encountered from 15 to 20 feet below ground surface (bgs). The silty clay unit is made up of equal parts silt and clay with traces of sand and gravel.

A special site feature of the Expanded Parcel L RAA is the former West Fork of the South Branch of the

Chicago River (West Fork) that historically flowed from Parcel I onto Parcel L at the southwestern corner

of Parcel L. The former location of the West Fork is shown on Figure 4. According to the soil boring

observations during the pre-removal site characterization, the portion of former West Fork located in the

Expanded RAA contains fill as deep as 29 feet bgs, where oily sheens were observed at depths between

20 and 29 feet bgs. The MGP source material detected in the portion of former West Fork appears to

extend off of Parcel L to the southwest.

2.2 Pre-Removal Site Characterization Activities and Findings

In December 2013, 15 soil borings were advanced on the Expanded Parcel L RAA to further delineate

suspect areas of MGP residuals located at the northwestern corner and the central area of the adjacent

Parcel I. The investigative work was completed by NRT as part of the TCRA-delineation of non-aqueous

phase liquid (NAPL), and was mainly accomplished through visual, olfactory and photoionization detector

(PID) response observations in the field. The locations of the borings, denoted as 1SB101 through

ISB115, are presented on Figure 4. Soil boring logs are provided in Appendix A1.




Page 5 of 21

Areas of MGP residuals meeting the classification of source material were identified in subsurface soils at

two areas: (1) the central portion of Parcel I in the vicinity of former tar decanters and (2) the northwestern

corner of Parcel I where the former west fork channel traversed the Site.

Nine borings were advanced in the vicinity of the former tar storage tanks and tar separating tank located

at the central portion of Parcel I. Two soil borings exhibited visible tar-like product (ISB104 and ISB105).

The tar-like substance in fractures was noted at a depth of 9 to 10 feet bgs and associated with NAPL.

Several other borings, including ISB102, 1SB108, and ISB 110, were characterized as having suspect tar

like odors as well as elevated PID responses. Two borings (ISB106 and ISB109) located at edge of the

historical structures exhibited slightly elevated PID responses but no odors.

Three soil borings were advanced within the former West Fork Channel along the northwestern corner of

Parcel I. Two borings (ISB103 and ISB114) contained visible NAPL at depths ranging from 20 to 29 feet

bgs, and suspect tar-like or petroleum-like odors within fill materials.

No visual, olfactory or PID evidence of potential MGP effects were observed at soil borings ISB111 and

ISB113 advanced in the western portion of Parcel I. Boring ISB115, located adjacent to the excavation

area in Parcel L, exhibited suspect naphthalene-like and tar-like odors with elevated PID responses at

depths between 6 to 11 ft bgs.

Three soil samples were collected from soil borings advanced within the former West Fork Channel area

for laboratory analysis of volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs),

total petroleum hydrocarbons (TPH), and metals. Consistent with the on-going TCRA work on Parcel L,

TPH was utilized as an indicator of source material and is a combination of gasoline and diesel range

organics. TPH concentrations for soil samples collected from ISB 103 and ISB114 at depths of 20 to

24 feet bgs were reported at 4,251 mg/kg and 46,620 mg/kg, respectively. Laboratory analytical reports

from TestAmerica for these soiLsamples are presented in Appendix A2. As a result of the findings of this

investigation, the RAA will be expanded to incorporate this remainder of the source material extending to

the southwest.

2.3 Utilities and Site Constraints

2.3.1 Existing Utilities

The surface of the Expanded Parcel L RAA is covered in varying grades of asphalt ranging from solid to

crushed asphalt. The Expanded RAA is currently occupied by a truck staging area. No buildings are




Page 6 of 21

present within the area. IBS will coordinate a utility survey within the Expanded RAA in advance of the

initiation of the removal action.

2.3.2 Site Ownership

The Expanded Parcel L RAA is located within a parcel currently owned by Kostner/Chicago, LLC and is

operated by LaGROU Cold Storage Partnership. Negotiation of an access agreement with the site

owners has been initiated. It is anticipated that site access can be secured upon approval ofthis

Addendum by the USEPA.

2.4 Soil Data Compilation and Interpolation

Consistent with the general methodology described in the RAWP Add.1, Rev. 1, Section 2.4 (page 8),

available data for the Expanded Parcel L RAA was evaluated as part of the removal action planning for

purposes of:

1. Estimation of the extent of the excavation area. The extent of source material was estimated based on a combination of analytical soil data and descriptions of visually identified MGP source material in soil boring logs (Figure 5). Soil analytical data were used to correlate visual indicators of NAPL. The proposed removal action areas were verified and refined to include areas where TPH concentrations exceeded the calculated site specific value of 7,858 mg/kg in accordance with the Tiered Approach to Corrective Action Objectives (TACO) regulations for determination of soil attenuation capacity (Illinois TACO: 35 IAC 742, Section 742.215) and as approved by the USEPA as part of the Parcel L RAWP Rev.1 Add 1. TPH as a sum of diesel and gasoline range organics was assumed to be representative of the primary constituents of potential concern (COPC) including benzene, toluene, ethylbenzene, xylenes (BTEX), and total PAHs. The visual descriptions of NAPL as well as associated analytical data were coordinated into a three-dimensional interpolation of the source material at each recent soil probe location. The extent of the excavation area is determined based on the estimated extent of source material.

According to the available site characterization data, no MGP source material within the Expanded RAA

was anticipated to be at or above the Subtitle D landfill acceptance criteria and therefore the excavation

was not subdivided into areas based on amendment requirement. In the event that soils are encountered

during removal action work that exceed landfill acceptance criteria, procedures are in place to amend and

sample material consistent with what was done on previous removal actions at the Crawford MGP site.

The output includes the total volume of material to be removed from the Expanded RAA. The extents of

source material and the proposed excavation are shown on Figure 5. The excavation area encompasses

the two source material areas and the necessary sloping banks. The excavation area is discussed further

in Section 3.3.




Page 7 of 21

2.5 Characterization of Material for Disposal

Material was characterized using the same procedures detailed in the RAWP Add.1, Rev. 1, Section 2.5

(page 5) using information and data specific to the Expanded Parcel L RAA. The waste streams expected

to be generated by this phase of the removal action are consistent with those identified for the completed

removal activity at Parcels A, B, O and L.

2.6 Risk to Public Health, Welfare or the Environment

See RAWP Add. 1, Rev. 1, Section 1.4 (page 6) for details on the Risk to Public Health, Welfare, or the

Environment. In order to obtain the goals and reduce the risk of exposure, it is necessary to expand the

removal action. Based on the site characterization sampling, source material identified at the Expanded

Parcel L RAA are consistent with the source material under current removal action work, implying that the

MGP source material is extended from the existing Parcel L RAA southwest on to the adjacent Parcel I.

Given the nature of the known and suspected hazardous substances, pollutants, or contaminants within

the Expanded Parcel L RAA, removal of these MGP source materials will effectively mitigate the direct

contact exposure pathway to construction/utility workers and reduce the potential for migration to soil,

groundwater, or surface water. If not addressed by implementing the response actions selected in this

Addendum, or by another comparable mitigation method, these conditions pose a potential risk to public

health, welfare, and/or the environment.



September 10, 2014 Section 3 - Basis for Removal Action

Page 8 of 21

3 BASIS FOR REMOVAL ACTION

3.1 Removal Action Objectives and Strategy

The expanded removal action will be conducted to accomplish the overall objectives described in the

RAWP Add.1, Rev. 1, Section 3.1 (page 7).

3.2 MGP Source Material Definition

See the RAWP Add.1, Rev. 1, Section 3.2 (page 7) for information regarding the definition of MGP source

material.

3.3 Removal Action Decision Criteria

Removal action decision criteria will be consistent with those presented in the RAWP Add.1, Rev. 1,

Section 3.3 (page 7). For the Parcel L Expanded RAA, excavation depths are planned to reach 29 feet

bgs in the former West Fork Channel area and to 11 feet bgs at the central portion as shown on Figure 5.

The extent of proposed excavation encompasses the two MGP source material areas and the necessary

sloping banks.

3.4 Estimated Removal Volume

Based on the project objectives and decision criteria, the approximate lateral and vertical extents of MGP

source material to be removed for this portion of the Site are shown on Figure 5. Excavation areas,

extending to 29 feet bgs in the former West Fork Channel area and to 11 feet bgs at the central portion of

the Expanded Parcel L RAA, are proposed to remove these MGP residuals. Details of the removal plan

are presented in Section 4. The total volume of MGP source material planned for off-site disposal

(including materials removed in the designed slope portions) is estimated to be approximately

50,000 cubic yards (80,000 tons).



September 10, 2014 Section 4 - Removal Action Implementation

Page 9 of 21

4 REMOVAL ACTION IMPLEMENTATION

This section describes the components of the removal action plan that will be implemented within the

designated Expanded Parcel L RAA of the Crawford Station MGP site. As noted above, the Expanded

Parcel L RAA Work Zone includes the majority of Parcel I where the excavation activities will take place

as well as portions of Parcel L where supporting construction activities will occur.

4.1 Preliminary Activities

4.1.1 Site Security and Controls

PGL currently maintains a gated and secured entrance to Parcel L at 4201 West 35 t h Place, Chicago,

Illinois. Ingress and egress by trucks to the Expanded RAA will be routed within Parcel L. The existing

gate on the northern boundary of Parcel L will serve as an access point to the Expanded RAA (Figure 6).

All visitors will be required to sign a visitor's log when entering and exiting the Expanded RAA by using

the existing access infrastructure of Parcel L. Access to active construction areas will be limited to

authorized personnel approved by IBS who will be required to participate in a site-specific health and

safety briefing by the site supervisor or health and safety officer prior to entry.

4.1.2 Surveying

See the RAWP Add.1, Rev. 1, Section 4.1.2 (page 8) for information regarding surveying.

4.2 Site Preparation

Site preparation will include protection of utilities to remain in-place, installation of erosion controls, and

establishing a truck route from Parcel L to the Expanded Parcel L RAA including construction of an on-

site temporary truck access road. These activities are discussed further below.

4.2.1 Protection of Utilities and Construction Utilities

A utility survey within the Expanded Parcel L RAA will be conducted in advance of the initiation of the

project. If any underground utilities are found within the Expanded RAA, coordination with all utility

providers and the parcel owner will occur to protect the utilities which will remain in-place during

excavation activities. Discussions with PGL, Chicago Department of Water Management, and the




Page 10 of 21

Metropolitan Water Reclamation District of Greater Chicago MWRD on a proposed plan for protection of

the utilities will be completed if necessary.

Field modification may be necessary based on subsurface conditions encountered during construction. If

utility modifications are necessary, PGL will coordinate with the utility provider. Additionally, coordination

with utility providers will also occur to facilitate installation of utility services necessary for the construction

operations. The construction operations will require, at a minimum, electrical and communication services

for office trailers. In addition, the contractor's site superintendent will be tasked with ensuring all utility

conflicts are cleared as the excavation activity progresses. In the event that in-situ chemical oxidation

(ISCO) or enhanced in-situ bioremediation (EISB) is used, special care will be taken to avoid application

in proximity to sensitive utilities.

4.2.2 Runoff and Erosion Control

See RAWP Add. 1, Rev. 1, Section 4.2.2 (page 9) for information regarding general erosion and site

controls. Silt fence will be placed along the Expanded Parcel L RAA boundary.

4.2.3 Clearing and Grubbing

See RAWP Add.1, Rev. 1, Section 4.2.3 (page 9) for information regarding clearing and grubbing. No

clearing and grubbing activity is anticipated within the Expanded Parcel L RAA.

4.2.4 Route of Ingress and Egress for Construction

Ingress and egress routes to the Expanded Parcel L RAA will be established through the existing

infrastructure on the northern boundary. At the gate, appropriate signage will be posted to identify

entrances and exits. All trucks will be covered and covers will be securely fastened before leaving the

Expanded RAA.

4.3 Fugitive Emission Control

See RAWP Add.1, Rev. 1, Section 4.3 (page 9) for information regarding fugitive emission control. In

addition to the controls measures listed in the RAWP Add.1, Rev. 1, an odor mitigation system may be

utilized to control fugitive emissions, if needed.


a [NATURAL I RESOURCE [TECHNOLOGY



Page 11 of 21

4.4 Removal Action Operations

Removal action operations will consist of the following elements as described in this section:

• Shoring

• Targeted Excavation

• On-site Materials Management

• Excavation Dewatering

• Equipment Decontamination

4.4.1 Shoring

For purposes of excavation stability, a sheet pile wall will be installed along the northern and western

boundaries of the Expanded Parcel L RAA where the excavation area extends to these boundaries, as

shown on Figure 5. An approximate 800 foot long sheet pile wall will be constructed immediately inside

the fence line to allow removal of MGP source material. At project completion, the sheet piles will be left

in place as a vertical barrier to demark the removal area along the property boundary.

In addition, sloping of banks along the perimeter of the excavations will be required to stabilize excavation

side walls as necessary to complete the excavation. Slope cutbacks will be in accordance with applicable,

City of Chicago requirements, industry standards and OSHA requirements.

4.4.2 Targeted Excavation

In order to remove the source material associated with the former MGP located on Parcel L, excavation

activities will continue on to the Expanded Parcel L RAA to achieve removal of MGP source material as

defined in the RAWP Rev 1 and RAWP Add 1. Rev1. The anticipated excavation area for this portion of

the site is shown on Figure 5.

Surface features of the former MGP operations have been removed. It is anticipated that the majority of

the subsurface elements of the former MGP structures remain in place. Structures with subsurface

elements that are expected to be encountered during removal activities include portions of the following:

• Tar Storage Tanks (two are shown on Figure 5)

• Tar Separating Tank

• Ammonia Storage Tank




Page 12 of 21

Removal of these subsurface structures is expected to be necessary, in most instances, to facilitate

excavation of MGP source material. It is anticipated that most or all of the former MGP structures within

the proposed excavation area will be removed by standard excavation techniques. However, if it is

determined that one or more structures is not practical to remove, steps will be taken to assess the

potential impact leaving such structure would have on meeting the objectives stated in Section 3.1.

Where practical, a visual inspection will be made to determine the nature of any MGP source material that

would remain in place should the structure not be removed. If the structure in question exhibits

characteristics that indicate it is MGP source material, or potentially contains or physically impedes

access to additional MGP source material, measures will be taken to limit the extent of potential future

migration of impacts. These measures may include application of in-situ remediation products and/or the

placement of physical barriers. In the event that structures are encountered that extend beyond the

removal action area (i.e., straddle the Expanded Parcel L RAA boundary), their location will be

documented. The remnant structures within the Expanded RAA will be removed to the extent practicable.

Those portions of structures that extend beyond the project limits may be left in place and will be

addressed to limit the extent of future migration of MGP impacts as discussed above.

Overall, the excavation process will occur in a staged progression, designed to effectively achieve

removal goals but minimize duration of open excavations and allow for adequate access to the target

removal areas. Phasing and sequencing of work will be further developed during the final design phase of

the removal action. During excavation activities, materials will be visually inspected for MGP residuals

and segregated into four categories:

• Non-MGP impacted construction debris (i.e., pavement, concrete, etc.)

• MGP source material

• MGP source material at or above the Subtitle D landfill permit limits

• Overburden material

4.4.2.1 Non-MGP Impacted Construction Debris

Given the current site conditions, structures and construction debris will be encountered during removal

activities within the Expanded Parcel L RAA. Structures and construction debris with limited to no MGP

impacts may be crushed and used to backfill the excavation area. Structures and construction debris that

is not reused will be transported off-site for disposal.


a NATURAL RESOURCE TECHNOLOGY



Page 13 of 21

4.4.2.2 MGP Source Material

MGP source material will be directly loaded from the excavation to trucks for transport off-site or will be

temporarily stockpiled within excavation areas to facilitate efficient loading of trucks. MGP source material

will be transported by covered truck to an approved disposal facility as identified in Section 5.3.

4.4.2.3 MGP Source Material at or above the Subtitle D Landfill Permit Limits

According to the available site characterization data, no MGP source material is anticipated to be at or

above the Subtitle D landfill acceptance criteria. However, if any portion of the source material is identified

at or above the criteria based on waste profile samples during excavation, that material will be amended

on-site prior to disposal. Based on experience gained during previous removal activities on site, bed ash

is anticipated to be the preferred amendment material.

Following amendment, a representative sample will be collected for laboratory analysis to confirm

amended soils satisfy landfill acceptance criteria for the Subtitle D facility. All laboratory analytical reports

will be provided to the landfill, as necessary, for approval prior to transporting materials off-site.

4.4.2.4 Overburden Material

See RAWP Add. 1, Rev. 1, Section 4.4.2.4 (page 11) for information regarding the handling of

overburden material.

4.4.3 On-site Materials Management

See RAWP Add.1, Rev. 1, Section 4.4.3 (page 11) for information regarding on-site management of materials.

4.4.4 Excavation Dewatering

See RAWP Add. 1, Rev. 1, Section 4.4.4 (page 11) for information regarding dewatering the excavation

area.

4.4.5 Equipment Decontamination

See RAWP Add.1, Rev. 1, Section 4.4.5 (page 12) for information regarding decontamination of

equipment.




Page 14 of 21

4.5 Site Restoration

See RAWP Add.1, Rev. 1, Section 4.5 (page 12) for information regarding restoration of Expanded

Parcel L RAA after removal activities.


|NATURAL | RESOURCE ITECHNOLOGY


September 10, 2014 Section 5 - State and Local Requirements

Page 15 of 21

5 STATE AND LOCAL REQUIREMENTS

5.1 Storm Water Discharge

Refer to the RAWP Add.1, Rev. 1, Section 5.1 (page 13) for details of the storm water discharge

procedures.

5.2 Governmental Coordination

See RAWP Add.1, Rev. 1, Section 5.2 (page 13) for information regarding coordination with

governmental agencies.

5.3 Off-Site Disposal

MGP-impacted debris and soil is planned to be profiled and disposed at Waste Management's Laraway

Refuse Disposal Facility (RDF), located in Joliet, Illinois, a Subtitle D landfill. This facility has received

similar MGP waste from the ongoing removal action activities. The Laraway facility has been approved by

USEPA with respect to the Off-Site Rule.

As an alternate disposal option, MGP-impacted debris may be disposed of at Waste Management's

Countryside Landfill, located in Grayslake, Illinois, an operating Subtitle D facility, or their CID RDF,

located in Calumet City, Illinois, a closed Subtitle C landfill currently approved to accept non-hazardous

MGP wastes for bioremediation. The Countryside and CID RDF facilities have been confirmed to be in

compliance with the Off-Site Rule for disposal of waste as set forth in the NCP Section 300.440.



September 10, 2014 Section 6 - Construction Quality Assurance Measures

Page 16 of 21

6 CONSTRUCTION QUALITY ASSURANCE MEASURES

This section describes the following principal construction quality assurance measures that will be

employed during the removal action:

• Air Monitoring Plan

• Fugitive Emissions Management Plan

• Health and safety

• Sampling and analysis

6.1 Air Monitoring Plan

Potential emissions to be managed and controlled during the course of the removal action include odor,

fugitive respirable particulate matter with an aerodynamic diameter less than 10 microns (PM 1 0 ) , and

vapor phase COPCs. Potential emission sources include:

• Soil Excavation: Potential emissions consist of VOC vapors and fugitive dust during soil excavation and loading into trucks.

• Excavated Material Management: Potential emissions consist of fugitive dust, vapor, and odor emissions from stockpiles and during material handling.

This phase of the removal action will be performed as a continuation of the removal action currently

underway on Parcel L. Background levels of particulates and vapor phase COPCs were previously

established during the pre-construction air monitoring phase at Parcel L. No pre-construction air

monitoring will be performed at the Expanded Parcel L RAA.

Air monitoring will be conducted at the perimeter of the Expanded Parcel L RAA Work Zone as detailed

on Figure 6 during removal action activities to ensure engineering measures are being protective of public

health and the environment, and to determine when response actions are warranted. Specific air

monitoring elements will include the following:

• Establishing a dedicated continuously operated weather station to monitor meteorological conditions at the Site.

• Collecting 24-hour time-weighted summa canister samples along the Expanded RAA Work Zone perimeter during active construction. Summa canisters will be used to collect 24-hour time-weighted average samples for VOC and naphthalene analysis. Results will be compared to the site-specific risk-based acceptable air concentrations (AAC) presented in Appendix B.


[NATURAL I RESOURCE [TECHNOLOGY



Page 17 of 21

• Collecting 24-hour time-weighted polyurethane foam (PUF) samples along the Expanded RAA Work Zone perimeter during active construction. PUF samples will be analyzed for PAHs and results will be compared to the site-specific risk-based AACs presented in Appendix B.

• Real-time air monitoring data for total volatile organic compounds (TVOC) and PM10 will be collected at regular intervals from around the perimeter of the Expanded Parcel L RAA Work Zone.

Air monitoring activities will be conducted by NRT. NRT will support planning, implementation, and

documentation of a comprehensive perimeter air monitoring program during removal action activities.

NRT will work with the removal action contractor and the engineer through all phases of the removal

action to ensure appropriate control and mitigation of vapor phase, fugitive dust, and odor emissions.

6.1.1 Time Weighted Average (24-Hour) Perimeter Air Monitoring

As stated above, the proposed air sampling strategy is a continuation of the full-scale air monitoring

efforts performed at Parcel L. Frequencies and quantities of air monitoring samples may be revised

during construction. Sampling requirements include the following:

• During construction, 24-hour summa samples will be collected twice per week at upwind and downwind locations along the Expanded RAA Work Zone perimeter. PUF samples will be collected at upwind and downwind locations along the Expanded RAA Work Zone perimeter once per week, or may be monitored indirectly by measuring the P M 1 0 concentration (i.e., using a real-time monitor), rather than using PUF samplers as described in Appendix B.

• Samples will be analyzed within the 14-day holding time unless real-time monitoring results indicate that the sample analysis should be expedited to evaluate potential on-site exceedances of AACs.

• Upwind and downwind samples will be selected based on weather conditions, removal action activities, accessibility, and receptors.

• Field duplicates for the summa canisters and PUF samples will be collected at a frequency of . one per 20 samples. Duplicates will be obtained by collecting two concurrent samples from a single location and having both analyzed by the laboratory.

6.1.2 Real-Time Handheld and Observational Monitoring

Real-time monitoring using portable and handheld devices will be conducted during the removal action.

Real-time air monitoring equipment will operate 24-hours a day, 7 days a week. Key requirements include

the following:

• TVOCs will be monitored using a gas chromatograph (GC) or photoionization detector (PID) at upwind and downwind locations.




Page 18 of 21

• Benzene will be monitored using a GC or handheld PID with a vapor-specific separation tube when sustained concentrations of TVOCs are observed at or above the Action Level presented in Section 6.1.4.

• Continuous monitoring of P M 1 0 will be conducted using aerosol monitoring equipment at upwind and downwind locations.

• Odor (e.g., naphthalene) that could indicate a concern for a public nuisance will be monitored by qualitative olfactory assessment along the Expanded Parcel L RAA Work Zone perimeter.

• Fugitive dust due to on-site operations will be monitored by visual assessment.

6.1.3 Assessment of Meteorological Conditions

An on-site meteorological station will be used to measure wind speed, wind direction, relative humidity,

and ambient air temperature. Meteorological data will be relayed to a computer where it will be reported in

real-time and it will be used to identify upwind and downwind sample locations and to monitor off-site

receptors. The information will be stored electronically and included in daily reports. Average daily

temperatures and barometric pressures will be used to calculate 24-hour time-weighted average air

sample volumes for the summa canister and PUF samples. Meteorological data may also be obtained

from the National Data Buoy Center (Chicago Station CHII2) or the National Weather Station at Midway

Airport (KMDW) in the event that onsite data is unavailable.

6.1.4 Action Levels

Action Levels will be used as a screening tool to manage construction activities to minimize the potential

for off-site emissions. Action Levels are generally constrained by detection limits of the field monitoring

equipment. In addition, Action Levels are selected at appropriate levels to avoid exceedances from

ambient air concentrations (e.g., exhaust from nearby parked cars) versus concerns that could be

resulting from removal action operations. Exceedance of an Action Level at the Expanded Parcel L RAA

Work Zone perimeter will require a response action for vapor phase, particulate, and/or odor mitigation

based on the conditions presented in Section 6.2.1. The effectiveness of the Action Levels to maintain off-

site vapor phase emissions below the AACs will be assessed and may be adjusted, as appropriate.

Proposed Action Levels for periodic real-time perimeter monitoring are summarized in the table below.

Action Levels

Parameter Action Level

TVOCs 0.5 ppm greater than background

Benzene 0.5 ppm

P M 1 0

0.15 mg/m3 greater than background (15-minute average concentration)


[NATURAL [RESOURCE [TECHNOLOGY



Page 19 of 21

These Action Levels are based on the following:

• The proposed Action Levels for TVOCs and benzene have been used at other MGP sites to effectively predict compliance with AACs and can be reliably measured by the proposed equipment.

• The proposed Action Level for benzene is based on the California EPA Reference Exposure Level for acute 6-hour exposure of 0.4 ppm.

• The proposed Action Level for P M 1 0 is based on previously demonstrated performance at other MGP sites and the National Air Quality Standards (40 CFR part 50).

6.2 Fugitive Emissions Management Plan

See RAWP Add.1, Rev. 1, Section 6.2 (page 17) for information regarding the management of fugitive

emissions.

6.3 Health and Safety Plan

See RAWP Add.1, Rev. 1, Section 6.3 (page 17) for information regarding the Site-Specific Health and

Safety Plan (SSHASP) for ongoing removal activities at the Crawford Station MGP site. The SSHASP will

be updated as appropriate to reflect the location of the Expanded Parcel L RAA and other site-specific

characteristics. A copy of the updated SSHASP will be provided to USEPA upon request.

6.4 Sampling and Analysis Plan

See RAWP Add.1, Rev. 1, Section 6.4 (page 18) for information regarding the sampling and analysis plan

for the Expanded Parcel L RAA removal action. The plan is summarized in Table 1.



September 10, 2014 Section 7 - Schedule

Page 20 of 21

7 SCHEDULE

7.1 Schedule for Construction

Construction activities are tentatively scheduled to begin in January 2015, following completion of

remediation activities on the eastern portion of Parcel L and subject to USEPA's review and approval of

this Addendum and governmental approvals. Property access and contractor availability are not expected

to be constraints with respect to the project schedule; however, weather conditions may influence the

production rate of the excavation work. IBS will keep USEPA updated on the work progress and schedule

modifications through weekly progress reports.

The table below summarizes the anticipated construction schedule based on the planned scope of work

described herein. The schedule was determined by assuming construction activities on five days per

week basis.

Preliminary Construction Schedule

Activity Duration (Weeks)

Target Project Start Date January 2015

Mobilization / Site Preparation 3

Excavation/Transport/Disposal 15

Backfill Operations 5

Site Restoration / Close Out 2

Contingency 5

Total Estimated Project Duration 30

Target Completion August 2015

7.2 Removal Action Completion Report

A Removal Action Completion Report for the work outlined in this Addendum will be submitted to USEPA

within 90 days following restoration of the Site to document the work performed.


[ NATURAL [RESOURCE [TECHNOLOGY


September 10, 2014 Section 8 - References

Page 21 of 21

8 REFERENCES

Natural Resource Technology, Inc. September 6, 2011, Removal Action Work Plan, Rev. 1 - (Parcels A, B & O), Crawford Station MGP Site, Chicago, Illinois.

Natural Resource Technology, Inc. October, 2012, Removal Action Work Plan, Add.1, Rev. 1 - (Parcel L), Crawford Station MGP Site, Chicago, Illinois.

Natural Resource Technology, Inc., December 23, 2011, Completion Report, Rev. 0, Crawford Station MGP Site, Chicago, Illinois.

Prepared for Integrys, August 2, 2007, Multi-Site Health and Safety Plan Revision 2.

Prepared for Integrys Business Support, LLC, September 4, 2007, Multi-Site Quality Assurance Project Plan Revision 2.

Prepared for Integrys Business Support, LLC, September 8, 2008, Multi-Site Field Sampling Plan Revision 4.


FIGURES

Service Layer Credits: Source: US National Park Service Copyright:© 2013 National Geographic Society, i-cubed

PROJECT NO: 2037.1

FIGURE NO: 1

s NATURAL RESOURCE TECHNOLOGY

SITE LOCATION

R E M O V A L A C T I O N W O R K P L A N A D D E N D U M 1 A

C R A W F O R D S T A T I O N M G P S I T E

C H I C A G O , I L L I N O I S

DRAWN BY/DATE: TDC 9/4/14

REVIEWED BY/DATE: M_W9/4/14

APPROVED BY/DATE: TBN 9/9/14

a If I ? 2 Hi

S U R R O U N D I N G L A N D U S E

REMOVAL ACTION WORK PLAN ADDENDUM 1A CRAWFORD STATION MGP SITE

CHICAGO, ILLINOIS

D R A W N B Y / D A T E : T D C 9 / 4 / 1 4

R E V I E W E D B Y / D A T E : M _ W 9 / 4 / 1 4

A P P R O V E D B Y / D A T E : T B N 9/9/14

I P Hi

S O I L B O R I N G L O C A T I O N S


CHICAGO, ILLINOIS

D R A W N B Y / D A T E : T D C 9/4/14

R E V I E W E D B Y / D A T E : M _ W 9/4/14


5 P ^

M G P S O U R C E M A T E R I A L R E M O V A L E X T E N T S


CHICAGO, ILLINOIS

D R A W N BY /DATE: T D C 9/4/14

R E V I E W E D B Y / D A T E : M _ W 9 / 4 / 1 4


Identify source of emissions at station(s), or location of

handheld reading indicating alarm condition.

Figure 7 - A i r Monitoring Response Plan Flowchart Expanded Parcel L Removal Action Area Chicago, Illinois

Take practical steps to minimize fugitive dust. Potential actions: cover stockpiles, spray

stockpiles, traffic routes, and other sources of dust activities with water and/or foam (weather

permitting).

EMISSION CONDITION 1 RESPONSE

Take practical steps to minimize vapors and suppress odor. Potential actions: cover soil pile with tarp or foam; temporarily halt nonessential contaminated soil management

operations.

Take all possible steps to minimize fugitive dust.

Potential actions: reduce trucking rate, and continued watering of haul

roads.

Perform focused perimeter air monitoring using portable particulate monitors.

Document source and response actions,

continue work.


Does alarm condition go to RED

and/or is there a

YES

\

Take all possible steps to minimize vapors and odor.

Potential actions: reduce open excavation areas, truck loading

rate, and trucking rate.


continue work, call PM



continue work, call PM

NO

Perform focused perimeter air monitoring using PIDs.

Call PM for further guidance or shutdown.

TABLES

Table 1 - Sampling and Analysis Plan Summary Expanded Parcel L Removal Action Area Crawford station MGP Site Chicago, Illinois

Sample Type

Proposed

Number Samples 1

Matrix / Laboratory

Parameter Method Estimated

Sample Quantity

Field

Duplicates2

(1 extra volume)

MS/MSD 3

(2 extra volumes)

Equipment

Blanks4 T O T A L 5 Estimated No.

of Containers Container

Type Minimum Volume

Preservation {Cool All Samples to 4°

+ 2°C Unless 'None' Indicated)

Holding Time from Sample

Date

Pre-Disposal Samples . • • • • • • • • ••

Composite Test Pit Samples

Areas with known or suspected landfill acceptance criteria exceedances

TBD

Will be assessed for effectiveness during initial stages of project start-up

solid fixed

TCLP Benzene 1311/8260B TBD TBD TBD TBD TBD TBD sets glass 2 o z zero headspace 14/28 days Composite Test Pit Samples


TBD


solid fixed



TBD


solid fixed



TBD


solid fixed

Post-Amendment Samples . ' v . - ._. . --.--.-.-.5--.-'.=- . ... • • y,,/^:. -Composite Stockpile Samples

Stockpiles which exceeded landfill

acceptance criteria and were amended

TBD

Will be assessed based on waste

profile samples

solid

.fixed

TCLP Benzene 1311/82S0B TBD TBD TBD _ TBD TBD sets glass 2 o z zero headspace 14/28 days Composite Stockpile Samples



TBD


profile samples

solid

.fixed

Composite Stockpile Samples



TBD


profile samples

solid

.fixed




TBD


profile samples

solid

.fixed

Overburden Soil Sampling ^:r~~ - _ : . . ^ ^ ^ ^ ^ ^ m c j ^ . ; ; ^ ^ . ; : v - • • '• • •


Surface Soils that are anticipated for

reuse as backfill

0

1 per 1,000 cubic yards of soil planned

for return to the excavation backfill

solid

fixed

TPH GRO 5030/8015B 0 0 0 - 0 0 sets glass 2 o z _ 14 days Composite Stockpile Samples


reuse as backfill

0



solid

fixed

TPH DRO 3541/8015 0 0 0 - 0 0 sets fflass 2 o z - 14/40 days



reuse as backfill

0



solid

fixed

PVOCs 5035/B260B 0 0 0 0 Osets qlass 2 o z - 14 days



reuse as backfill

0



solid

fixed PAHs b 8270C or 8270 SIM D 0 0 - 0 0 sets glass 2 o z - 14/40 days



reuse as backfill

0



solid

fixed

Phenols 7 8270C o- 0 0 ~ 0 0 sets glass 2 o z _ 14/40 days



reuse as backfill

0



solid

fixed

Cyanide 9012A 0 0 0 - 0 0 sets glass 2 o z - 14 days



reuse as backfill

0



solid

fixed

Metals8 6020A/7471A 0 0 0 — 0 0 sets glass 2 o z - 14/40 days

Post-Excavation Soil Sampling - : • . • ' • ' ' ^y^-^-i^y^ ^y^-y-^,-^

Walls and Floors of Excavation

39

1 per every 50 feet of wall and 1 per every 2,500 square feet of floor

solid

fixed

TPH GRO 5030/8015B 39 2 2 - 43 43 sets Fflass 2 o z zero headspace 14 days Walls and Floors of Excavation

39


solid

fixed

TPH DRO 3541/8015 39 2 2 43 43 sets glass 2 o z zero headspace 14/40 days Walls and Floors of Excavation

39


solid

fixed PVOCs 5035/8260B 39 2 2 - 43 43 sets qlass 2 o z methanol 14 days


39


solid

fixed

PAHs D B270C or 8270 SIM 39 2 2 - 43 43 sets amber glass 4 oz _ 14/40 days


39


solid

fixed

Phenols' 8270C 39 2 2 43 43 sets amber glass 4 oz 14/40 days


39


solid

fixed

Cyanide 9012A 39 2 2 - 43 43 sets plastic 16 oz 14 days


39


solid

fixed

MetaJsa 6D20A/7471A 39 2 2 - 43 43 sets plastic 16 oz - 14/40 days

(0-TBN/HMS7/11) Notes: 1. Proposed number of samples does not include contingency investigation locations. 2. Field duplicates will be collected at a frequency of 1 per 10 or fewer investigative water samples, and 1 per 20 or fewer investigative soil/sediment samples.

3. Matrix Spike/Matrix Spike Duplicate (MS/MSD) samples will be collected at a frequency of 1 per group of 20 or fewer investigative water samples or soil samples. Additional volume will be determined by laboratory requirements. 4. Equipment blanks will be collected at a frequency of 1 per soil sampling day with non-dedicated sampling equipment. Analyses will be same as soil sample analyses. 5. Trip blanks will accompany each cooler containing V O C water samples, including equipment blanks; this is an estimate based on number of days sampling and estimation of number of coolers. 6. PAHs as listed in the Multi-Site RAF including naphthalene, acenaphthylene, acenaphthene, fluorene, phenanthrene, anthracene, fluoranthene, pyrene, benzo(a)anthracene, chrysene, benzo(b)fiuoranthene, benzo(k)fluoranthene, benzofpyrene, benzo(a)pyrene, indeno(1,2,3-cd) pyrene, dibenzo(a,h)anthracene,benzo(g,h,i)perylene and 2-methylnaphthalene 7. - Phenols as listed in the Multi-Site RAF including 2,4-dimethylphenol, 2-methylphenol, 4-methylphenol and phenol

8. Metals as listed in Ihe Mufti-Site RAF including aluminum, antimony, arsenic, barium, cadmium, chromium, copper, iron, lead, manganese, mercury, nickel, selenium, silver, vanadium and zinc.

Table 1 - Sampling Analysis Plan Page 1 of 1

APPENDIX A2

LABORATORY ANALYTICAL RESULTS

Sample ID Date Location Sample Type Start Time End Time Depth Matrix Site Location Personnel Sent to

Lab Date

ISB114 12/9/2013 ISB114 Soil 14:20 . . . 20-22 Black Sand Parcel I MDC 12/10/2013 ISB103 12/9/2013 ISB103 Soil 13:00 . . . 20-22 Black Sand Parcel I MDC 12/10/2013 ISB113 12/9/2013 ISB113 Soil 11:35 — 22-24 Black Sand Parcel I MDC 12/10/2013

File Name: 500-68293-1_StdChiPivot.xls Site Name: Crawford Station - Parcel I Date: 12/17/2013

500-68293-1 500-68293-2 500-68293-2-DL 500-68293-3 File Name: 500-68293-1_StdChiPivot.xls Site Name: Crawford Station - Parcel I Date: 12/17/2013

ISB114 ISB103 ISB103 ISB113 File Name: 500-68293-1_StdChiPivot.xls Site Name: Crawford Station - Parcel I Date: 12/17/2013 12/09/2013 12/09/2013 12/09/2013 12/09/2013

G C / M S V O A 1,2,4-Trimethylbenzene 8260B M G / K G 1.8 59 < 0.0065

1,3,5-Trimethylbenzene 8260B M G / K G 0.47 19 < 0.0065

Benzene 8260B M G / K G 0.10 2.0 < 0.0065

Ethylbenzene 8260B M G / K G 0.16 38 < 0.0065

m&p-Xylene 8260B M G / K G 0.15 23 < 0.013

o-Xylene 8260B M G / K G 0.17 22 < 0.0065

Toluene 8260B M G / K G 0.065 2.6 < 0.0065

Xylenes, Total 8260B M G / K G 0.32 46 < 0.013

G C / M S SEMI V O A 2,4-Dimethylphenol 8270D M G / K G < 76 < 160 < 17

2-Methylnaphthalene 8270D M G / K G 13 J 3000 < 8.6

2-Methylphenol 8270D M G / K G < 39 < 80 < 8.6

3 & 4 Methylphenol 8270D M G / K G < 39 < 80 < 8.6

Acenaphthene 8270D M G / K G 83 1600 < 1.7

Acenaphthylene 8270D M G / K G 8.5 110 < 1.7 Anthracene 8270D M G / K G 71 690 1.0 J Benzo[a]anthracene 8270D M G / K G 61 480 4.2

Benzo[a]pyrene 8270D M G / K G 47 320 3.8 Benzo[b]fluoranthene 8270D M G / K G 49 310 4.8 Benzo[g,h,i]perylene 8270D M G / K G 19 120 2.2

Benzo[k]fluoranthene 8270D M G / K G 22 130 2.0 Carbazole 8270D M G / K G < 39 67 J < 8.6 Chrysene 8270D M G / K G 61 480 4.5

Dibenz(a,h)anthracene 8270D M G / K G 5.8 J 49 0.68 J Dibenzofuran 8270D M G / K G < 39 140 < 8.6 Fluoranthene 8270D M G / K G 130 810 8.0 Fluorene 8270D M G / K G 69 1000 0.36 J lndeno[1,2,3-cd]pyrene 8270D M G / K G 16 100 1.9 Naphthalene 8270D M G / K G 25 3500 1.4 J Phenanthrene 8270D M G / K G 180 3400 3.8 Phenol 8270D M G / K G < 39 < 80 < 8.6 Pyrene 8270D M G / K G 130 930 8.9

G C V O A Gasoline Range Organics (C6-C9) 8015C M G / K G 51 620 5.9

G C SEMI V O A Diesel Range Organics [C10-C28] 8015C M G / K G 4200 46000 780 J Result is less than the RL but greater than or equal to the MDL and the concentration is an approximate value.

File Name: 500-68293-2 StdChiPivot.xls Site Name: Crawford Station Soil Sampling Date: 12/12/2013

500-68293-1 500-68293-2 500-68293-3 File Name: 500-68293-2 StdChiPivot.xls Site Name: Crawford Station Soil Sampling Date: 12/12/2013

ISB114 ISB103 ISB113 File Name: 500-68293-2 StdChiPivot.xls Site Name: Crawford Station Soil Sampling Date: 12/12/2013 12/09/2013 12/09/2013 12/09/2013 METALS Aluminum 601 OB MG/KG 5100 5200 8400 Antimony 601 OB MG/KG 8.8 4.5 2.0 J Arsenic 6010B MG/KG 14 18 14 Barium 6010B MG/KG 120 180 160 Cadmium 6010B MG/KG 6.8 B 16 B 1.5 B Chromium 6010B MG/KG 170 B 330 B 28 B Copper 6010B MG/KG 3900 4900 790 Iron 6010B MG/KG 16000 15000 19000 Lead 6010B MG/KG 800 1000 310 Manganese 6010B MG/KG 170 190 200 Nickel 6010B MG/KG 120 110 36 Selenium 6010B MG/KG 0.66 J 1.2 1.3 Silver 6010B MG/KG 5.2 B 3.6 B 1.5 B Thallium 6010B MG/KG 0.77 J < 1.2 < 1.3 Vanadium 6010B MG/KG 17 B 20 B 19 B Zinc 601 OB MG/KG 1100 B 910 B 510 B Mercury 7471B MG/KG 32 5.6 16

GENERAL CHEMISTRY Cyanide, Total 9014 MG/KG 2.0 12 2.0 B Compound was found in the blank and sample. J Result is less than the RL but greater than or equal to the MDL and the concentration is an approximate value.

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