PAOC 23/24 Interim Measures Work Plan Haulaway Building Part I

Transcription

1 PAOC 3/ Interim Measures Work Plan Haulaway Building Part I COMPANY VEHICLE OPERATIO YPSILANTI, MICHIGAN RCRA CA U.S. EPA ID MID Prepared For: Revitalizing Auto Communities Environmental Response Trust (RACER) Prepared by: CRA Engineering Inc. DECEMBER 013 REF. NO () 19 Sheldon Rd, Unit 00 Plymouth, Michigan 170 Office: (73) Fax: (73) web: Worldwide Engineering, Environmental, Construction, and IT Services

2 Revitalizing Auto Communities Environmental Response Trust (RACER) PAOC 3/ Interim Measures Work Plan Haulaway Building Part I Table of Contents Page Section 1.0 Introduction Site Location Site History Project Overview Site Sources Applicable Regulations Toxic Substances Control Act Evaluation RCRA Waste Evaluation Non-Listed Waste Evaluation Point of Generation and Area of Contamination Future Land Use Site Geology and Hydrogeology Investigation Results Paint Sludge and Product Data Soil and Groundwater Characterization Data Indoor Air and Soil Gas Data... Section.0 Scope of Work Shoring Excavation....3 Winterizing the Material.... Infiltration Gallery Vapor Mitigation Activities... 9 Section 3.0 References... 9 List of Figures (Following Text) Figure 1.1 Figure 1. Figure 1.3 Figure.1 Figure. Figure.3A Figure.3B Site Layout Area of Contamination Paint Sludge Delineation Extent of Excavation Cross Section Location Map Cross Section A-A Cross Section Details for Excavation Area A () December 013

3 Revitalizing Auto Communities Environmental Response Trust (RACER) PAOC 3/ Interim Measures Work Plan Haulaway Building Part I Figure. Figure.5 Figure. Infiltration Gallery Building Features Required SSDS Area List of Tables (Following Text) Table 1.1 Soil Analytical Results 013 Investigation List of Appendices Appendix A-1 Pre-197 Determination from the U.S. EPA on March, 013 Appendix A- Non-Listed Evaluation to the MDEQ on October 1, 013 Appendix B Appendix C Stratigraphy Logs Near and Beneath the Haulaway Building Databox Figures and Tables from the RFI Report () December 013

4 Revitalizing Auto Communities Environmental Response Trust (RACER) PAOC 3/ Interim Measures Work Plan Haulaway Building Part I List of Acronyms AOC bgs CFR COC CRA CVO GM ID IMWP in. WC Kaiser-Frazer LDRs LNAPL MDEQ PAOC PID ppm RACER RCRA RFI Site SSDS TCL TCL S TSCA UHCs U.S. EPA WRAP Area of Contamination Below Ground Surface Code of Federal Regulations Constituents of Concern CRA Engineering Inc. Company Vehicle Operations General Motors Identification Number Interim Measures Work Plan Inch Water Column The Kaiser-Frazer Company Land Disposal Restrictions Light Non-Aqueous Phase Liquid Michigan Department of Environmental Quality Potential Area of Concern Photoionization Detector Polychlorinated Biphenyls Parts Per Million Revitalizing Auto Communities Environmental Response Trust Resource Conservation and Recovery Act Resource Conservation and Recovery Act Facility Investigation CVO, Ypsilanti, Michigan Subslab Depressurization System Target Compound List Volatile Organic Compounds Target Compound List Semi-Volatile Organic Compounds Toxic Substances Control Act Volatile Organic Compounds Underlying Hazardous Constituents United States Environmental Protection Agency Willow Run Assembly Plant () December 013

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6 Revitalizing Auto Communities Environmental Response Trust (RACER) PAOC 3/ Interim Measures Work Plan Haulaway Building Part I Section 1.0 Introduction On behalf of Revitalizing Auto Communities Environmental Response Trust (RACER), CRA Engineering Inc. (CRA) has prepared this Interim Measures Work Plan (IMWP) Part I for the Willow Run Company Vehicle Operations (CVO) property located in Ypsilanti, Michigan (Site) for the excavation of paint sludge and impacted soils beneath the northern portion of the Haulaway Building at the Site. An infiltration gallery and subslab depressurization system (SSDS) will also be installed as part of the IMWP activities. Soil and groundwater impacts, including the presence of paint sludge within the area, are the result of historic filling practices with industrial waste. Specifically, this IMWP addresses impacts beneath the Haulaway Building located within Potential Area of Concern (PAOC) 3. This IMWP does not include post excavation activities. Post excavation activities including soil conditioning and disposal of the excavated material will be presented in a separate work plan, PAOC 3/ IMWP Part II (IMWP Part II). The IMWP Part II will be based on the characterization results of the excavated material under this IMWP Part I and will be submitted in Spring 01. RACER has signed a purchase agreement with a new owner for the Site. The work included in this IMWP-Part I, which includes paint sludge removal, has been separated from future work that will be completed within the area to facilitate the property transfer and use of the Haulaway building by the new owner. RACER anticipates the transfer of the property to the new owner to take place in January Site Location The Site is located at 901 Tyler Road in Ypsilanti, Michigan. It is bordered to the north and east by Tyler Pond, to the west by the Willow Run Business Center and to the south by Tyler Road. There is only one building, the Haulaway Building, located at the Site as shown on Figure 1.1. The Haulaway Building is located in the southwest quadrant of the Site. The west side of the Haulaway Building is office space whereas the east side is garage/maintenance workshop space. The garage/maintenance workshop is approximately 0,000 square feet. 1. Site History The CVO Site consists of the eastern acres of the former Willow Run Assembly Plant (WRAP). The Site has had many owners. The Kaiser-Frazer Company (Kaiser-Frazer) leased the area from the War Asset Administration in November 195 and purchased the facility in December 19. Kaiser-Frazer is thought to have constructed an administration building to house design and engineering facilities on the WRAP site. Kaiser-Frazer owned the property until its sale to General Motors (GM) in December 195. The original building at the WRAP was used by GM as a parts storage warehouse until In 195, light () December 013 1

7 Revitalizing Auto Communities Environmental Response Trust (RACER) PAOC 3/ Interim Measures Work Plan Haulaway Building Part I truck assembly began at the plant. Following assembly operations, vehicles were distributed to dealers by both truck and railway systems. Production operations ceased in July of 1993 and deactivation and decommissioning operations proceeded to prepare the WRAP facility for an eventual sale in GM retained ownership of the CVO property, which was used to store and maintain GM owned company vehicles until 0. The Site is currently owned by RACER Properties LLC and operated by RACER. RACER was created in March 011 by the United States Bankruptcy Court to clean up and position for redevelopment properties and other facilities owned by the former General Motors Corporation before its 009 bankruptcy. Historically, waste material (including paint sludge and various drummed wastes) were dumped in various locations within the CVO Site during the 190s and 1950s. Historical aerial photos (199) show an excavated area along with material piles just northeast of where the Haulaway Building now stands. The aerial photos show excavated pits dark in color suggesting the presence of liquids. The area of the 199 pit is referred to as the PAOC Fill Area. Two pits were also observed in northwest of Haulaway Building in a 195 aerial. These pits are dark in color indicating that they may contain liquid. This area has previously been identified as PAOC. The identification of the additional paint sludge between these two previously identified PAOCs suggests they may be one fill area. Analytical results from samples of the groundwater, soil and buried waste material beneath the Haulaway Building suggest the possibility that volatile organic compounds () could volatilize from these media and subsequently migrate into the indoor air of the Haulaway Building. Soil gas and indoor air samples from the Haulaway Building confirm that VOC vapors are migrating into the building. Investigations indicate that the paint sludge is a contributing factor to elevated levels of in soil gas beneath the Haulaway Building. The paint sludge removal is not expected to fully remediate the VOC impacts in the area, rather to remove a source for soil gas and potentially groundwater impacts. Additional interim measures will likely be conducted. In anticipation of that an infiltration gallery will be installed prior to backfilling the excavation to enable delivery of amendments to the area to reduce groundwater concentrations in the future. 1.3 Project Overview The Site is currently under Michigan Department of Environmental Quality(MDEQ) led Resource Conservation and Recovery Act (RCRA) Corrective Action due to the submission of a RCRA Part A Permit application in 190 by GM. The RCRA history of the Site is summarized in the Site Summary Report (CRA, July 0), previously provided under separate cover. The United States Environmental Protection () December 013

8 Revitalizing Auto Communities Environmental Response Trust (RACER) PAOC 3/ Interim Measures Work Plan Haulaway Building Part I Agency (U.S. EPA) identification number (ID) associated with the November 190 RCRA Part A permit application, subsequent waste activities for the former WRAP (which included the CVO property) and RCRA Corrective Action is MID This U.S. EPA ID is not currently used for any activity at the CVO Site. Currently the CVO Site has large quantity generator status and uses U. S. EPA ID MIK93311 for waste shipments related to the environmental remediation work. RCRA Corrective Action addresses impacts due to the release of hazardous substances. This interim measure addresses source removal at one area at the Site and will be completed as a portion of the overall RCRA corrective action at the Site. An interim measure is currently ongoing with PAOC 1 at the Site. Other activities will be completed under the RCRA Corrective Action at the Site by additional interim measures and/or deed restrictions. 1. Site Sources As discussed in Section 1. historic filling practices have impacted Site soils and groundwater. Several aerial photographs of the Site from 190 to 199 were reviewed; these included 190, 199, 195, 1955, 195, 193, 199, 197, 190, 195, 1990, 199, 1995, and 199. In reviewing the aerial photographs, several areas of soil disturbances, filling and open pits were observed on the CVO property. Copies of these aerial photographs are provided in Appendix B of the Site Summary Report (CRA, July 0). The 199 aerial photograph shows an excavated area along with material piles just northeast of where the Haulaway building now stands. This photo shows excavated pits dark in color suggesting the presence of liquids. Several aerial photographs show filling activities along the south shore of Tyler Pond from Outfall #11, the northwest corner of the CVO Site, to the east. The 195 photo shows that the area south and west of Tyler Pond was being used as a construction materials storage area. While remnants for the excavated pit identified in the 199 photo are present, there is evidence of two additional pits directly west of the pit identified in the 199 photo. These pits are dark in color indicating that they may contain liquid. The area of the 195 pits is referred to as PAOC, 195 Pits. Based on the review of aerial photos, it appears the filling and apparent waste operations in the vicinity of the Site occurred prior to 193, with the majority of the filling activities taking place prior to By 193 the entire Site area, including the eastern most section but not the bank of Tyler Pond, was completely paved. 1.5 Applicable Regulations This IMWP-Part I involves excavation of paint sludge material and adjacent impacted soils and placing the excavated material in piles as described in Section.. As stated above, IMWP-Part II will be () December 013 3

9 Revitalizing Auto Communities Environmental Response Trust (RACER) PAOC 3/ Interim Measures Work Plan Haulaway Building Part I submitted for the conditioning and off-site disposal of the excavated material. This section describes regulations as they apply to the activities associated with the excavation of the materials Toxic Substances Control Act Evaluation Low levels of polychlorinated biphenyls () are present within the area to be excavated. Generally levels beneath the Haulaway building are less than 5 part per million (ppm), therefore, excavated material will not be considered Toxic Substances Control Act (TSCA) material. In addition, U.S. EPA has previously concurred that contamination at the Site occurred prior to 197 based on information provided from Site history and aerial photographs. Therefore, according to 0 Code of Federal Regulations 71.50(b)(3)(i) (A), the at as-found concentrations less than 50 ppm are not subject to TSCA. A copy of the submittal to the U.S. EPA and their concurrence is provided in Appendix A RCRA Waste Evaluation Non-Listed Waste Evaluation Due to the historic nature and unknown origin of the waste material, paint sludge, impacted soils, groundwater in the area, they are not listed wastes. An summarizing this justification was sent to the MDEQ via on October 1, 013. A copy of the submittal to the MDEQ is provided in Appendix A Point of Generation and Area of Contamination The point of generation is the concept that a material must be characterized (hazardous or non-hazardous) and, if applicable, Underlying Hazardous Constituents or Land Disposal Restrictions (LDRs) evaluated after the point the material becomes a waste (i.e., after the point of generation). The point of generation of remediation waste is typically considered to be when the material is actively managed. Actively managed may include excavation for soils, pumping for groundwater or dredging for sediments. The Area of Contamination (AOC) concept was discussed in the preamble to the National Contingency Plan (55 FR 75-70, March, 1990) as well as several federal guidance documents including "Management of Remediation Wastes Under Resource RCRA", October, 199 (EPA530-F-9-0). The AOC concept allows for the consolidation and in-situ treatment of hazardous waste within the AOC without creating a new point of generation and therefore does not trigger LDRs. The point of generation becomes the point at which the waste leaves the AOC. Michigan Rule 99.95() identifies the AOC concept and allows a work plan approved by the MDEQ pursuant to R99.95 to use the AOC concept. For the purposes of this IMWP-Part I, the AOC is () December 013

10 Revitalizing Auto Communities Environmental Response Trust (RACER) PAOC 3/ Interim Measures Work Plan Haulaway Building Part I defined as the historic waste disposal area around PAOC 3 and PAOC as shown on Figure 1.. Therefore, the handling of soils within this AOC and conditioning that will be described in a subsequent IMWP have been designed to occur prior to the point of waste generation. The AOC boundary identified in Figure 1. was defined by the 199 and 195 pits identified in the aerial photos review. The aerials indicate evidence of fill activities within these areas. In addition, similar impacts including chlorinated in soil and groundwater, and paint sludge are observed within this area. Additional information on the impacts observed within the area is discussed in Section 1.. As stated above, the historic filling practices at the Site included the deposition of waste material (i.e. paint sludge and other debris). The paint sludge has been observed in three areas (Areas A, B, and C) as shown on Figure 1.3. Paint sludge is observed at locations inside (mainly Area A) and outside (Areas B and C) the Haulaway Building; however, the excavation outside the Haulaway Building will not be completed at this time. 1. Future Land Use The property has been sold for non-residential use. To facilitate the reuse of the building by a new owner in early 01, this IMWP Part I addresses paint sludge impacts beneath the Haulaway Building only. 1.7 Site Geology and Hydrogeology The Site-wide geology consists of a fill and upper sand unit in the upper 15 to 0 feet. The fill unit varies from fill sands and clays to construction debris and historical waste material. The upper sand unit generally consists of fine to medium grained sands with silts and gravels. The sand/clay interface is observed approximately 17 feet below ground surface (bgs) near the Haulaway Building area. The upper fill and sand units contain limited groundwater that is typically encountered in unconfined conditions at shallow depths (i.e. approximately 11 feet) near the building. Details of geology and hydrogeology are provided in the RCRA Facility Investigation (RFI) Report submitted to MDEQ in October 013 (CRA, October 013). 1. Investigation Results Soil, groundwater and indoor air/soil gas impacts have been identified within the AOC during investigation activities. Details of the investigation activities are included in the Site Summary Report (CRA, July 0) and the RFI Report (CRA, October 013). The following subsections summarize the () December 013 5

11 Revitalizing Auto Communities Environmental Response Trust (RACER) PAOC 3/ Interim Measures Work Plan Haulaway Building Part I investigation results near the Haulaway Building area. Detailed stratigraphy logs for the soil borings completed near the Haulaway Building are included in Appendix B Paint Sludge and Product Data Investigations completed at the Site identified paint sludge, yellow-green in color, in the northwest corner of the building. Delineation activities were completed to identify the extent of the paint sludge near the Haulaway Building. Figure 1.3 shows the locations where paint sludge was observed. Light non-aqueous phase liquid (LNAPL) has also been observed near the Haulaway Building. The observed LNAPL does not appear continuous, widespread or consistently present in measurable quantities. Non-aqueous phase liquid (NAPL), brown in color, and mixed with paint sludge was observed at SB Petroleum type odor and sheen was observed at MW19-. LNAPL was also observed at IW-1 and IW-0. It should be noted that IW-0 is not near the excavation area. Figure 1.3 shows the locations where product was observed. Analytical results for paint sludge and NAPL samples are included in the RFI Report (CRA, October 013). These results are also presented in Appendix C of this IMWP-Part I. 1.. Soil and Groundwater Characterization Data Soil and groundwater samples were collected and submitted to laboratory for TCL, TCL S,, and inorganics during investigation activities completed at the Site. Review of the soil and groundwater data near the Haulaway building, identified several constituents that exceeded the generic MDEQ screening criteria. are the predominant constituents of concern in soil and groundwater within the area. Constituents of Concern (COCs) for soil and groundwater were defined as any constituent that exceeded residential criteria anywhere on Site for that matrix. Databox figures are included in the RFI Report (CRA, October 013) to present soil and groundwater data for COCs for that matrix. Databox figures from the RFI Report which summarizes data collected through 0 are provided in Appendix C of this IMWP-Part I. Table 1.1 presents the analytical results for investigation activities completed in 013 that are not included in the databox figures Indoor Air and Soil Gas Data In 005, eight permanent soil vapor probes were installed beneath the north portion of the Haulaway Building to investigate the potential for to volatilize from groundwater to soil gas within the unsaturated overburden. Following review of the data collected from the soil gas probes, indoor air samples were also collected. Soil gas and indoor air investigation activities are presented in Appendix D and E of the Site Summary Report (CRA, July 0) () December 013

12 Revitalizing Auto Communities Environmental Response Trust (RACER) PAOC 3/ Interim Measures Work Plan Haulaway Building Part I Soil gas data was collected and was reviewed for evaluating VOC source areas in vadose zone soils within the Haulaway Building and the surrounding area in 0. A regenerative blower was used to extract relatively high volumes of soil vapor from shallow temporary wells (approximately 5 feet deep). Extracted soil vapors were analyzed using a photoionization detector (PID) at the discharge outlet of the blower. The highest concentrations were observed at a location in the northwest corner of the building. In May 013 investigation, a total of 15 soil vapor pins were installed throughout the entire building to delineate impacts beneath the footprint of the building. Appendix C includes the soil vapor results. Section.0 Scope of Work The scope of work for this IMWP Part I includes removal of paint sludge and associated impacted soils in Area A only to facilitate the reuse of the building by a new owner in early 01. Excavation outside the building (Areas B and C) may be initiated based on the findings of the Area A excavation. A network of horizontal wells will be installed while backfilling the excavation to create an injection gallery for potential future use to reduce VOC levels in groundwater. In addition, vapor intrusion mitigation activities will be completed to prevent soil gases from infiltrating the building. These include the installation of a SSDS and sealing of cracks, gaps, and seams within a portion of the building. Based on the reviewed technologies/approaches, RACER and MDEQ determined that excavation of the paint sludge was the best technical option for achieving source material removal and allowing reuse of the building in a timely manner. Following that decision various options within this approach were reviewed to evaluate a manner in which cost uncertainty associated with waste stream variability could be decreased. The limited space inside the building poses restrictions for excavation and conditioning activities. These challenges cannot be avoided under the building. The uncertainty of the characterization of the excavated material is decreased once excavated and sampled. Therefore, the full scope of work was separated into two stages, (1) excavation and () material sampling, conditioning and disposal, to reduce the costs associated with the risk of the waste stream variability..1 Shoring Due to the depth and location of the excavation, helical piers will be installed to support existing foundations and footings enable excavation to feet bgs () December 013 7

13 Revitalizing Auto Communities Environmental Response Trust (RACER) PAOC 3/ Interim Measures Work Plan Haulaway Building Part I. Excavation The objective is to remove paint sludge and adjacent soils until no visible paint sludge remains. Based on the investigations completed to date, the extent of excavation including the depth profile is presented on Figure.1. A cross section within the AOC is also completed to provide details such as paint sludge and concentrations of select constituents. Figures.,.3 A, and.3 B present the cross section location map, the cross section A-A and cross section details of the excavation Area A. It should be noted only select constituents i.e. those exceeding the groundwater surface water interface protection criteria and the non-residential soil volatilization to indoor air inhalation criteria are presented on the cross section. Data for the soil borings completed within the excavation area is provided in Table 1.1. The material will be segregated into of 5 piles by depth as indicated below and shown in the depth profile on Figure.1. Soils and paint sludge will be excavated and relocated to piles outside the building within the AOC as shown on Figure 1.. The segregation is based on similar impacts observed within the depth interval and is anticipated to aid in the evaluation of disposal options in IMWP Part II. If paint sludge is observed in any interval, it will be placed in Pile 3. Pile 1: feet bgs (soils) Pile : feet bgs (soils) Pile 3: feet bgs (Paint sludge) Pile : feet bgs (soils) Pile 5: feet bgs (soils) The piles containing soils will be winterized as discussed in Section.3. The excavated soils will be sampled, evaluated, conditioned if required and disposed off-site in 01. These activities will be discussed in IMWP Part II..3 Winterizing the Material Excavated material will be relocated to piles within the AOC and placed on 15 mm plastic sheeting and will be covered with a minimum of mm plastic sheeting. The sheeting will be constructed to provide total protection from adverse weather and wind, prevent infiltration of precipitation or snow melt, and prevent any leaching of moisture from the piles. The piles will be winterized/protected and are expected to be staged onsite for months () December 013

14 Revitalizing Auto Communities Environmental Response Trust (RACER) PAOC 3/ Interim Measures Work Plan Haulaway Building Part I. Infiltration Gallery A network of horizontal wells will be installed while backfilling the excavation to create an injection gallery. Figure. provides further details on the approximate layout and installation of the horizontal wells..5 Vapor Mitigation Activities To prevent soil gases from infiltrating the building, cracks, concrete penetrations, manholes (unused) and trenches will be filled and capped with concrete within the area of the building identified on Figure.5. A subslab depressurization system (SSDS) will be designed and installed underneath a portion of the Haulaway Building. The area to be covered by SSDS is shown on Figure. and was defined by subslab soil gas results. The installation of the SSDS will be based on the A E-11 Standard Practice for Installing Radon Mitigation Systems in Existing Low-Rise Residential Buildings. The system will be designed to provide a minimum of 1 inch water column (in. WC) and maximum in. WC at the suction side of the fan and 11 in. WC throughout the subslab is achieved. Upon the installation of the SSDS, exhaust will be evaluated and operation and maintenance events will be completed. Section 3.0 References CRA, October 013. RFI Report, Former General Motors Company Vehicle Operations Property, Ypsilanti, Michigan CRA, July 0. Site Summary Report, Former General Motors Company Vehicle Operations Property, Ypsilanti, Michigan U.S. EPA, October, 199. Management of Remediation Wastes Under Resource Conservation and Recovery Act (RCRA)", (EPA530-F-9-0) () December 013 9

15 SAN SAN SAN R.S. R.S. 15"Ø LEGEND DITCH, STREAM OR RIVER FENCE LINE TREE LINE SAN SANITARY SEWER STORM SEWER FORMER SLUDGE LINE PAOC BOUNDARY M.H. CB15 M.H. R.S. CATCH BASIN MANHOLE FENCE GATE POST C.B. CB SAN SAN SAN SAN SAN SAN SAN SAN SAN SAN SAN SAN ft CB R.S. TYLER POND R.S. CB3 SAN SAN SAN SAN SAN SAN SAN CB SAN M.H. SHEET PILE WALL MH ABANDONED OUTFALL # CB R.S. R.S. R.S. R.S. R.S. R.S. SUMP SUMP 1FT RIM MH 7 SAN MH M.H. MH1 CB9 CB MH STORM M.H. SAN SAN "Ø SAN M.H. SAN M.H. SAN M.H. SAN M.H. SAN M.H. M.H. SAN SAN SAN CB5 SAN SAN SAN MH SAN SAN SAN SAN 3" FORCE MAIN SAN SAN SAN SAN SAN M.H. SAN SAN SAN SAN SAN SAN SAN SAN SAN SAN 1" FORCE MAIN(OLD) SAN R.S. R.S. SAN MH R.S. R.S. CB 11 M.H. R.S. R.S. CB- CB1 CB M.H. M.H. MH 1 CB-15 CB 1 BELL M.H. R.S. R.S. CB 13 MH 17 figure 1.1 SITE LAYOUT PAOC 3/ IMWP HAULAWAY BUILDING - PART I COMPANY VEHICLE OPERATIO AREA T0(0)GN-DE001 NOV /013

16 SAN SAN OUTFALL #11 C.B. CB M.H. TYLER POND CB R.S. R.S ft 0 CB3 CB TM MH LOCATION OF PILES STORM M AREA C AREA B CAR WASH BAY A IW-1 IW- IW- IW-1 IW-5 IW- IW- IW-3 IW-7 IW- IW-9 IW-11 IW- IW-13 IW-1 IW-15 IW-19 IW-0 IW-1 IW- IW-7 IW-33 IW-3 IW-3 IW- IW- IW-9 IW-30 IW-3 IW-35 IW-3 IW-39 IW-0 IW-1 IW-5 IW-31 SUMP IW-17 SUMP IW-37 IW- IW R IW-3 SHED MH1 CB9 CB CB OFFICE GARAGE INNER BLOCK WALL 1FT RIM R.S. R.S. R.S. R.S. R.S. R.S. M.H. STORM SEWER FENCE LINE AREA OF ECAVATION AREA OF CONTAMINATION PAOC BOUNDARY LEGEND R.S. CB15 M.H. CATCH BASIN MANHOLE FENCE GATE POST DITCH, STREAM OR RIVER TREE LINE INJECTION WELL AREAS CONTAINING PAINT SLUDGE figure 1. AREA OF CONTAMINATION PAOC 3/ IMWP HAULAWAY BUILDING - PART I COMPANY VEHICLE OPERATIO AREA T0(0)GN-DE00 DEC 11/013

17 IW- IW-5 IW- MW-7 SB SB19-73 AREA B SB19-75 IW- SEWER SB19-79 IW-11 IW- IW-13 IW-1 SB19-0 IW-15 SUMP IW-1 SUMP SB IW-17 AREA C SB19- SB 19-9 (-11') SB19-1 FORMER DIESEL LINE SG19-0 SB (.7-.7') SB19- (3.-5.5',.5-7.7') SG19-15 SG19- SB19-0 (.3') SG (1.5') SG19-1 SG 19-0 (3-3.') SB19-5 SB19-0 (5.5-', 7.0') SB19-59 (.1-.',.-5.',.-.') SB19-59A SB19-5 (-7.5') SB19-7 (-.5') SG19-09 (., 5.5-') SB19-97 SB19-9 SB19- SB19-5 SB19-7 GP19-03D (3.5, 5-7') MW19-5 SG19-3 SB SG19- (3.5, 5-7') SB19-3 SG MW19- SG19-17 SG19- SG 19-0 SB19-3 AREA A IW-1 IW-19 SG SB19-1 SB19-A (5.0) SB19-9 SB19-1 (.5-7') SB19-57A SB19-5 SG19-11 SB19- * SB19-57 SG19- ( ') (.9-5.', ', ') SB19-95 (3.5-5', ') SB19-1 SB19- SB19- SB19-9 (5', 5.7) SB19-99 SG19-1 SG19-19 SG 19-5 SG 19- SG 19-0 SB19-1 IW-0 CAR WASH SB19-19 SB19-1 SG19-13 SG19-0b SG19-0 (3.') SG19-0a SB19-55 MW19-09 SG 19-7 SB3-03 SG (3.') SG 19-1 SG 19- IW-1 IW-7 IW-33 SG 19-1 MW3-01 IW-3 SB19-3 SB19- IW- IW- IW-3 SB IW-39 (3-5.5') SB19- SB19-5 (.5-3') IW-3 SB3-0 IW-35 IW-9 IW-0 (3.0') MW3-0 IW- SB19- IW-3 SB3-0 IW-30 (5-.5') SB19-7 SB19-9 IW-5 IW-31 SB 1 IW-37 (13-15') SB19- SUMP MW19-7 IW- IW-3 S 0 0 0ft 0 SG 19-9 SG SG SG 19-3 SG SG 19-3 SB19- SB19-7 SB19-3 SB19-39 SB19-37 MW19- SB19- SB19-3 MW19-31 MW19-9 MW19-30 SB 19-9 (-11') SG 19-9 SB19-1 UE LEGEND LOCATIO WHERE PAINT SLUDGE OBSERVED ( OBSERVED) LOCATIO WHERE NO PAINT SLUDGE OBSERVED NO BORING LOG LOCATIO WHERE PRODUCT OBSERVED AREAS CONTAINING PAINT SLUDGE UNDERGROUND ELECTRIC ESTIMATED LOCATIO figure 1.3 PAINT SLUDGE DELINEATION PAOC 3/ IMWP HAULAWAY BUILDING - PART I COMPANY VEHICLE OPERATIO AREA T0(0)GN-DE003 NOV /013

18 AVERAGE GROUND SURFACE: 71. amsl 0.5' CONCRETE (REMOVAL AND OFF-SITE DISPOSAL) 0 0ft 0 PILE 1 1.5' ECAVATION DETAILS: AREA 5ft x 1ft PROFILE - SEE CROSS SECTION PILE PILE 3 - SLUDGE PILE - SOILS PILE 5 PAINT SLUDGE 1.5' 5.5' 1.0' -.0'.5' (AVERAGE SLUDGE THICKNESS 3 FEET) WITHIN THIS ZONE ANTICIPATED OF ECAVATION ( - 11' bgs) FORMER DIESEL LINE SG19-0 SB19-59 (.1-.',.-5.', SG19-15 SG19-.-.') SB19-59A SB (.7-.7') SB19-9 AREA A SB19-5 (-7.5') SB19-97 SB19- SG19-09 (., 5.5-') SB19- (3.-5.5',.5-7.7') SG19-1 GP19-03D (3.5, 5-7') SG19-3 SB19-5 MW19-5 SG 19-9 SB19-5 SB19-0 (5.5-', 7.0') SB19-7 (-.5') SB MW19- SG19- (5' (TRACE)) SB19- ( ') SB19-3 SB19-A SB19-9 (5', 5.7) SB19-99 SG19-17 SG19- SB19-1 (5.0) SB19-57A SG SB19-3 SB19-9 (.5-7') SG19-11 * SB19-57 (.9-5.', ', ') SB19- SB19-95 (3.5-5', ') SB19- SB19-1 SG19-1 SG 19-5 SG SB19-1 SG CAR WASH SB19-5 SG19- SG19-19 SG 19- SG 19-3 SG19-13 SG19-0b SB19-19 SG19-0 SG19-0a (3.') SB19-1 SB19-55 MW19-09 SG 19-7 SG SG 19-1 SG 19-1 SG 19- SG 19-3 IW-7 SB19- IW-33 IW-3 TYPICAL ECAVATION CROSS-SECTION SB 19-9 (-11') SG 19-9 SB19-1 UE LEGEND LOCATIO WHERE PAINT SLUDGE OBSERVED ( OBSERVED) LOCATIO WHERE NO PAINT SLUDGE OBSERVED NO BORING LOG EPECTED LIMITS OF ECAVATION UNDERGROUND ELECTRIC ESTIMATED LOCATIO 1. PAINT SLUDGE OBSERVED AT ANY /PILE WILL BE PLACED IN PILE #3 figure.1 ETENT OF ECAVATION PAOC3/ IMWP HAULAWAY BUILDING - PART I COMPANY VEHICLE OPERATIO AREA T0(0)GN-DE0 DEC 9/013

19 SB19-03 SB MH MW19-11 SB1-03 SB1-01 SB1-05 MW ft 0 MW SB SB19-73 SB19-75 IW- SB19-7 IW-1 IW- IW-3 SB19-77 IW- IW-5 IW- SB19-79 SB3-01 IW-7 MW-7 IW-11 IW- IW-13 IW-1 MW- IW- SB19-0 IW-15 SB19-7 IW-9 IW-1 SUMP SB IW-17 SB19-90 SHED S SB19-0 SB19-7 AREA A SB19-1 SB3-03 MW3-01 SB19- MW3-0 SB3-0 MH1 SB-0 SB-03 SB19-93 SB19-9 SB19-9 SB-0 SB-01 SB19-91 SB19- SB 19-9 SB19-1 FORMER DIESEL LINE SG19-0 SB19- SG IW-1 IW-19 MW19- SB19-5 SB19-3 SB19-0 SB19-1 SB19-A SG19- IW-7 IW- SB19-5 SB19-5 SB19-7 SB19-9 SB19-1 SB19-59 SG19-13 IW-9 SB19-5 SG 19-1 SB19-57A SB19-59A SG19-09 * SB19-57 SG19- SG19-11 SB19- SB GP19-03D SB19-95 SB3-0 SB19-1 SB19- SB SG19-0b SB19-97 SB19-9 SB19- SB19-19 IW-33 IW-3 IW-35 SB19- SB19-3 SB19-5 SB19- SG19-0 SG 19-1 SG19-19 SG19-0a SG19-15 SB19-9 SG19-1 SB SG19-17 SG19-1 SB19-99 SG19- SG 19-0 MW19-5 SG19-3 SG SG19- SG 19-0 SG SG 19-5 SG 19- SG 19-0 IW-0 CAR WASH SB19-1 SB19-55 MW19-09 SG 19-7 SG SG 19- IW-1 IW-3 SB19-3 IW- IW-39 IW-3 IW-0 IW- SB19- IW-3 IW-30 SB19-7 SB19-9 IW-5 IW-31 SB 1 IW-37 SB19- SUMP MW19-7 IW- IW-3 SB19-1 MW19-0 ST MW-7 SG 19-9 SG SG SG 19-3 SG SG 19-3 SB19- SB19-7 SB19-3 SB19-39 SB19-37 MW19- SB19-0 MW 19-3 MW19-31 MW19- SB19-3 SB19- LEGEND SB19-1 SOIL BORING LOCATION MONITORING WELL LOCATION UE ECAVATION AREA UNDERGROUND ELECTRIC STORM LINE AREA OF CONTAMINATION PAOC BOUNDARY ESTIMATED LOCATIO A A' SOIL GAS PROBE LOCATION INJECTION WELL LOCATION CROSS-SECTION LINE figure. CROSS-SECTION LOCATION MAP PAOC 3/ IMWP HAULAWAY BUILDING - PART I COMPANY VEHICLE OPERATIO AREA TEST PITS T0(0)GN-DE01 DEC 11/013

20 A WEST 7 SEE ZOOMED IN FIGURE.3B HAULAWAY BUILDING A' EAST 7 SG19-11 SG19- SG SB-0 ASPHALT SB19-9 ASPHALT SB19-91 ASPHALT DIESEL ASPHALT SLUDGE SB SB19-5 GP19-03D CONCRETE SB19-7 SB19- CONCRETE SLUDGE SB19-9 CONCRETE WOOD CONCRETE CONCRETE SG19-1 CONCRETE SB19- ASPHALT SB19-5 SLUDGE ASPHALT SB19-7 ASPHALT LEGEND STORM LINE ESTIMATED ETENT OF ECAVATION (AREA A) APPROIMATE GROUNDWATER TABLE ELEVATION BASED ON FIELD OBSERVATION ON 11/19/13 NO ECEEDANCES OTHER THAN METALS CHLORINATED BTE ELEVATION (FT) 7 70 SILTY SAND/SAND CLAY SLUDGE EOB = ' CONCRETE FILL SLUDGE VOID w/ NAPL SLUDGE EOB = ' EOB = 7' EOB = 7' EOB = 7' CLAY EOB = 7' 7 70 S CHROM VI NOTE: SOIL ANALYTICAL RESULTS INDICATED BY COLORED SHADING INDICATE COTITUENTS WERE DETECTED ABOVE GSIPC OR NRSVIIC PER MDEQ ACT 51 PART 01. ONE OR MORE METALS (OTHER THAN HEAVALENT CHROMIUM) WERE DETECTED AT CONCENTRATIO ABOVE GSIPC IN ALL SOIL S. 70 SILTY SAND/SAND EOB = 15' 70 A COMPLETE SET OF ANALYTICAL DATA IS PROVIDED IN TABLE 1.1 AND APPENDI C OF THE PAOC3/ IMWP HAULAWAY BUILDING - PART I. - GROUND - WELL 700 CLAY SCREEN 9 EOB = 0' EOB = 0' EOB = 0' DISTANCE ALONG BASELINE (FT) EOB = 0' EOB = 0' EOB = 0' EOB = 0' 9 EOB = END OF BORING SCALE HORIZONTAL - 1" = 0' VERTICAL - 1" = ' figure.3a GEOLOGIC CROSS-SECTION A-A' PAOC 3/ IMWP HAULAWAY BUILDING - PART I COMPANY VEHICLE OPERATIO AREA T0(0)GN-DE017 DEC 11/013

21 A WEST 7 HAULAWAY BUILDING A' EAST 7 LEGEND 7 SG STORM LINE ESTIMATED ETENT OF ECAVATION (AREA A) NO ECEEDANCES OTHER THAN METALS CHLORINATED BTE S CHROM VI 71 ASPHALT SB SB19-5 CONCRETE GP19-03D SB19-7 CONCRETE SB19- SB19-9 CONCRETE 71 NOTE: SOIL ANALYTICAL RESULTS INDICATED BY COLORED SHADING INDICATE COTITUENTS WERE DETECTED ABOVE GSIPC OR NRSVIIC PER MDEQ ACT 51 PART 01. ONE OR MORE METALS (OTHER THAN HEAVALENT CHROMIUM) WERE DETECTED AT CONCENTRATIO ABOVE GSIPC IN ALL SOIL S. ELEVATION (FT) SLUDGE WOOD A COMPLETE SET OF ANALYTICAL DATA IS PROVIDED IN TABLE 1.1 AND APPENDI C OF THE PAOC3/ IMWP HAULAWAY BUILDING - PART I. - GROUND - WELL SLUDGE - SCREEN CONCRETE FILL EOB = END OF BORING 7 SLUDGE SILTY SAND/ SAND SLUDGE VOID w/ NAPL SLUDGE EOB = 7' E 7 SCALE HORIZONTAL - 1" = 0' VERTICAL - 1" = ' 7 7 figure.3b 70 EOB = ' EOB = ' DISTANCE ALONG BASELINE (FT) 70 CROSS-SECTION DETAILS OF THE ECAVATION AREA A PAOC 3/ IMWP HAULAWAY BUILDING - PART I COMPANY VEHICLE OPERATIO AREA T0(0)GN-DE01 DEC 11/013

22 0 0ft 0 APPROIMATELY 1" RUBBER O-RING SEAL REMOVEABLE LID FLUSH-MOUNT ROAD BO Ø = " ± H = "± RISER 1 I AREA A RISER RISER 3 CAR WASH H="± CONCRETE SECURITY SEAL 30-50mm CLEARANCE AIR SPACE LOCKABLE J-PLUG " TO 3"± II RISER RISER 5 RISER D=1" TO "± BELOW SURROUNDING GRADE PARTIALLY FILLED WITH SAND FOR DRAINAGE SET 1" INTO SAND LAYER " TO " THICK SAND LAYER FOR DRAINAGE BACKFILL MATERIAL PERFORATED PIPE " RISER PIPE ECAVATION FILLED WITH 1 FOOT OF PEA STONE GRAVEL ECAVATION FILLED WITH 1 - FOOT OF PEA STONE FLUSH MOUNT WELL DETAIL SCALE: NTS LEGEND EPECTED LIMITS OF ECAVATION figure. INFILTRATION GALLERY PAOC 3/ IMWP HAULAWAY BUILDING - PART 1 COMPANY VEHICLE OPERATIO AREA T0(0)GN-DE013 DEC 9/013

23 D C B A 1 M.H ft 0 F E M.H. M.H. MECHANICS TRENCH A M.H. 9 9A A 11 11A A M.H. M.H. M.H. 13 B M.H. BC AB LEGEND FORMER VEHICLE EHAUST SYSTEM - TO BE FILLED (SUB SLAB) - OPENINGS/ESTIMATED SURFACE CRACKS M.H. M.H. MANHOLES - TO BE FILLED MANHOLES - NOT TO BE FILLED EISTING TRENCH - TO BE FILLED figure.5 BUILDING FEATURES PAOC 3/ IMWP HAULAWAY BUILDING - PART I COMPANY VEHICLE OPERATIO AREA EISTING TRENCH - NOT TO BE FILLED T0(0)GN-DE01 DEC 9/013

24 SEWER 0 0 0ft 0 F E D C B A CAR WASH OFFICES 9 GARAGE 11 A 13 LEGEND BC AB REQUIRED SSDS AREA STORM SEWER FENCE LINE SUB SLAB SOIL GAS PROBES SHALLOW GAS PROBES (<5) DEEP GAS PROBES (>5) figure. REQUIRED SSDS AREA PAOC 3/ IMWP HAULAWAY BUILDING - PART I COMPANY VEHICLE OPERATIO AREA T0(0)GN-DE015 DEC 9/013

25 TABLE 1.1 Page 1 of SOIL ANALYTICAL RESULTS SUMMARY AUGUST 013-NOVEMBER 013 FORMER COMPANY VEHICLE OPERATIO AREA YPSILANTI, MICHIGAN PAOC Sample Location: Statewide Default Nonresidential Nonresidential Nonresidential Nonresidential Nonresidential Nonresidential Nonresidential Groundwater Contact Groundwater Surface Water Soil Saturation Concentration SB19- SB19-3 Sample Depth: Background Levels Finite VSIC for Meter Finite VSIC for 5 Meter Infinite Source Volatile Direct Contact Criteria Drinking Water Soil Volatilization to Particulate Soil Protection Criteria Interface Protection Criteria Screening Levels 0-0- Sample ID: Source Thickness Source Thickness Soil Inhalation Criteria (VSIC) Protection Criteria Indoor Air Inhalation Criteria Inhalation Criteria S CT-001 S CT-005 Sample Date: 11/0/013 11/0/013 Sample Type: Parameters Units a b c d e f g h i j k 1,1,1-Trichloroethane C C U U U 1,1-Dichloroethane C C U C U 1,,-Trichlorobenzene C,DD. 10 C C U 1,-Dibromo-3-chloropropane (DBCP) C 1 M 1. C C ID U 1,-Dibromoethane (Ethylene dibromide) M U 1,-Dichlorobenzene C 1 C C U 0.5 U U C U C U 0.5 U 1,-Dichlorobenzene U 0.5 U -Butanone (Methyl ethyl ketone) (MEK) C,DD C C Hexanone C C ID U 1 U C C C ID U 1 U C C C U Bromodichloromethane W ID U 0.5 U Bromoform C 1. W C ID U 0.5 U Bromomethane (Methyl bromide) U Carbon disulfide C,DD C ID 0 1. U C U C C U Chloroethane C C C U Chloroform (Trichloromethane) C 1. W C U Chloromethane (Methyl chloride) C C ID U C C 0.1 f 0. cis-1,3-dichloropropene 0. U Cyclohexane U.7 U Dibromochloromethane W ID 0. U Dichlorodifluoromethane (CFC-) C C ID U 0.5 U C C C U C C C U Methyl acetate U.7 U Methyl cyclohexane U.7 U C C C U C C U Styrene C.7 50 C U C C U C 1 50 C C U 0.5 U C C U trans-1,3-dichloropropene 0. U C,DD fgj. fgj Trichlorofluoromethane (CFC-11) C C C U 0.5 U C 550 C 550 C C U U C C C U S,'-Oxybis(1-chloropropane) (bis(-chloroisopropyl) ether) 0. U 0. U,,5-Trichlorophenol NLV NLV NLV NLV U 0. U,,-Trichlorophenol NLV NLV NLV NLV M 0. U 0. U,-Dichlorophenol NLV NLV NLV 100 C,DD. NLV M U 0. U,-Dimethylphenol NLV NLV NLV NLV U 0. U,-Dinitrophenol 0.1 U 0.1 U,-Dinitrotoluene NLV NLV NLV 0 0. NLV U 0. U,-Dinitrotoluene 0. U 0. U -Chloronaphthalene ID ID ID ID ID U 0. U -Chlorophenol U 0. U -Methylnaphthalene J 0. U CRA Rpt Table 1.1.xlsx

26 TABLE 1.1 Page of SOIL ANALYTICAL RESULTS SUMMARY AUGUST 013-NOVEMBER 013 FORMER COMPANY VEHICLE OPERATIO AREA YPSILANTI, MICHIGAN PAOC Sample Location: Statewide Default Nonresidential Nonresidential Nonresidential Nonresidential Nonresidential Nonresidential Nonresidential Groundwater Contact Groundwater Surface Water Soil Saturation Concentration SB19- SB19-3 Sample Depth: Background Levels Finite VSIC for Meter Finite VSIC for 5 Meter Infinite Source Volatile Direct Contact Criteria Drinking Water Soil Volatilization to Particulate Soil Protection Criteria Interface Protection Criteria Screening Levels 0-0- Sample ID: Source Thickness Source Thickness Soil Inhalation Criteria (VSIC) Protection Criteria Indoor Air Inhalation Criteria Inhalation Criteria S CT-001 S CT-005 Sample Date: 11/0/013 11/0/013 Sample Type: Parameters Units a b c d e f g h i j k -Methylphenol NLV NLV NLV NLV M 0. U 0. U -Nitroaniline Nitrophenol NLV NLV NLV NLV ID 100 ID 0. U 0. U 3&-Methylphenol NLV NLV NLV NLV M 0. U 0. U 3,3'-Dichlorobenzidine NLV NLV NLV 30 M NLV 00. M 0. U 0. U 3-Nitroaniline 0. 0.,-Dinitro--methylphenol NLV NLV NLV M NLV Bromophenyl phenyl ether 0.1 U 0.1 U -Chloro-3-methylphenol NLV NLV NLV NLV ID U 0. U -Chloroaniline 0. U 0. U -Chlorophenyl phenyl ether Nitroaniline Nitrophenol Acenaphthene U 0. U Acenaphthylene ID 0. U 0. U Acetophenone C 10 C C ID U 0. U Anthracene D ID 0. U 07 J Atrazine NLV NLV NLV 330 DD NLV ID Benzaldehyde 0. U* 0. U* Benzo(a)anthracene NLV NLV NLV 0 NLL NLV ID NLL NLL 0. U 7 J Benzo(a)pyrene NLV NLV NLV NLL NLV 1900 NLL NLL 0. U 59 J Benzo(b)fluoranthene ID ID ID 0 NLL ID ID NLL NLL 15 J 7 J Benzo(g,h,i)perylene NLV NLV NLV 7000 NLL NLV NLL NLL 0. U 9 J Benzo(k)fluoranthene NLV NLV NLV 00 NLL NLV ID NLL NLL 0 J J Biphenyl (1,1-Biphenyl) 0. U 0. U bis(-chloroethoxy)methane 0. U 0. U bis(-chloroethyl)ether M 00 U bis(-ethylhexyl)phthalate (DEHP) NLV NLV NLV 000 C NLL NLV NLL NLL U 39 J Butyl benzylphthalate (BBP) NLV NLV NLV 3 C 3 C NLV C U 0. U Caprolactam NLV NLV NLV 3000 DD 30 NLV D 0. U 0. U Carbazole NLV NLV NLV NLV U 0. U Chrysene ID ID ID 000 NLL ID ID NLL NLL 1 J 5 J Dibenz(a,h)anthracene NLV NLV NLV NLL NLV ID NLL NLL 0. U 0. U Dibenzofuran ID ID ID U 0. U Diethyl phthalate NLV NLV NLV 70 C 30 NLV C U 0. U Dimethyl phthalate NLV NLV NLV 790 C 790 C NLV C U 0. U Di-n-butylphthalate (DBP) NLV NLV NLV 70 C 70 C NLV C JB 3 JB Di-n-octyl phthalate (DnOP) NLV NLV NLV C NLV C ID U 0. U Fluoranthene D J J Fluorene D U 0. U Hexachlorobenzene U 0. U Hexachlorobutadiene C C C Hexachlorocyclopentadiene C C ID U 0. U Hexachloroethane U 0. U Indeno(1,,3-cd)pyrene NLV NLV NLV 0 NLL NLV ID NLL NLL 0. U J Isophorone NLV NLV NLV 00 C NLV C 00 J 0. U U 0. U Nitrobenzene M U 0. U N-Nitrosodi-n-propylamine NLV NLV NLV M NLV U 0. U N-Nitrosodiphenylamine NLV NLV NLV 700 NLV U 0. U Pentachlorophenol NLV NLV NLV 30 NLV G, 0.1 U 0.1 U Phenanthrene J 9 J Phenol NLV NLV NLV 000 C,DD 0 NLV C U 0. U Pyrene D ID J J Metals Antimony NLV NLV NLV 70.3 NLV Arsenic 5. NLV NLV NLV 37. NLV B 3.7 B Barium 75 NLV NLV NLV NLV D 50 G, 3 B 0 B Beryllium NLV NLV NLV NLV D 9 G 0. J 0.15 J Cadmium 1. NLV NLV NLV 0 NLV G, Chromium 1 NLV NLV NLV NLV fj 50 fj Chromium VI (hexavalent) NLV NLV NLV NLV B j -- Cobalt. NLV NLV NLV 9000 NLV CRA Rpt Table 1.1.xlsx

27 TABLE 1.1 Page 3 of SOIL ANALYTICAL RESULTS SUMMARY AUGUST 013-NOVEMBER 013 FORMER COMPANY VEHICLE OPERATIO AREA YPSILANTI, MICHIGAN PAOC Sample Location: Statewide Default Nonresidential Nonresidential Nonresidential Nonresidential Nonresidential Nonresidential Nonresidential Groundwater Contact Groundwater Surface Water Soil Saturation Concentration SB19- SB19-3 Sample Depth: Background Levels Finite VSIC for Meter Finite VSIC for 5 Meter Infinite Source Volatile Direct Contact Criteria Drinking Water Soil Volatilization to Particulate Soil Protection Criteria Interface Protection Criteria Screening Levels 0-0- Sample ID: Source Thickness Source Thickness Soil Inhalation Criteria (VSIC) Protection Criteria Indoor Air Inhalation Criteria Inhalation Criteria S CT-001 S CT-005 Sample Date: 11/0/013 11/0/013 Sample Type: Parameters Units a b c d e f g h i j k Copper 3 NLV NLV NLV NLV D 17 G Lead 1 NLV NLV NLV 900 DD 700 NLV 000 ID 00 G,.7 30 Manganese 0 NLV NLV NLV NLV G, 130 B 150 B Mercury M 39 U U Nickel 0 NLV NLV NLV NLV D 1 G.9.5 Selenium 0.1 NLV NLV NLV 900 NLV j Silver 1 NLV NLV NLV NLV M 37 J 30 J Thallium NLV NLV NLV NLV J 79 J Vanadium NLV NLV NLV 5500 DD 990 NLV ID D Zinc 7 NLV NLV NLV NLV ID D 377 G Aroclor-1 (PCB-1) T NLL NLL NLL 0. U -- Aroclor-1 (PCB-1) T NLL NLL NLL 0. U -- Aroclor-3 (PCB-3) T NLL NLL NLL 0. U -- Aroclor- (PCB-) T NLL NLL NLL 0. U -- Aroclor- (PCB-) T NLL NLL NLL 0. U -- Aroclor-5 (PCB-5) T NLL NLL NLL 0. U -- Aroclor-0 (PCB-0) T NLL NLL NLL 0. J -- Total T NLL NLL NLL Footnotes: The analytical data is compared to the Michigan Part 01 generic cleanup criteria developed by the MDEQ under the authority of the Natural Resources and Environmental Protection Act (199 PA 51, as amended). Environmental Protection Act (199 PA 51, as amended). U-Not detected at the associated reporting limit. J-Estimated concentration. 1 Samples collected from SB19-57A, SB19-59A, SG19-A were composite of soils and paint sludge within the interval indicated above. CRA Rpt Table 1.1.xlsx

28 TABLE 1.1 Page of SOIL ANALYTICAL RESULTS SUMMARY AUGUST 013-NOVEMBER 013 FORMER COMPANY VEHICLE OPERATIO AREA YPSILANTI, MICHIGAN PAOC Sample Location: Sample Depth: Sample ID: Sample Date: Sample Type: Parameters Units SB19- SB19-5 SB19- SB19-7 SB19- SB19-9 SB19-1 SB SB19-1 SB SB19-7 SB19- SB S CT-009 S CT-013 S CT-01 S CT-01 S CT-01 S CT-03 S CT-0 S CT-030 S CT-033 S CT-031 S CT-019 S CT-00 S CT-00 11/0/013 11/0/013 11/0/013 11/0/013 11/0/013 11/0/013 11/0/013 11/0/013 11/0/013 11/0/013 11/0/013 11/0/013 11/0/013 1,1,1-Trichloroethane 1,1-Dichloroethane 1,,-Trichlorobenzene 1,-Dibromo-3-chloropropane (DBCP) 1,-Dibromoethane (Ethylene dibromide) 1,-Dichlorobenzene 1,-Dichlorobenzene -Butanone (Methyl ethyl ketone) (MEK) -Hexanone Bromodichloromethane Bromoform Bromomethane (Methyl bromide) Carbon disulfide Chloroethane Chloroform (Trichloromethane) Chloromethane (Methyl chloride) cis-1,3-dichloropropene Cyclohexane Dibromochloromethane Dichlorodifluoromethane (CFC-) Methyl acetate Methyl cyclohexane Styrene trans-1,3-dichloropropene Trichlorofluoromethane (CFC-11) 3 U U 9 U U 7 U 3 U U 9 U U 7 U 3 U U 9 U U 7 U 3 U U 9 U U 7 U 3 U U 9 U U 7 U 0.3 U U U 0.3 U U U 0.3 U U U 9 U.3 U 0.3 U 0. U 99 U 9 U 3 U U 3 U U 9 U 3 U U 9 U U 7 U 3 U U 9 U U 7 U 9 U.3 U 0.3 U 0. U 99 U 9 U 3 U U 3 U U 9 U 9 U.3 U 0.3 U 0. U 99 U 9 U 3 U U 3 U U 9 U 0. U 0. U U U U U U. 1 U 5.7 U 17 U U.3 U. 1 U 5.7 U 17 U U 0. U 0. U U U U U U U 9 U U 7 U 9 U.3 U 0.3 U 0. U 99 U 9 U 3 U U 3 U U 9 U 9 U.3 U 0.3 U 0. U 99 U 9 U 3 U U 3 U U 9 U 0.3 U U U 0.3 U U U 3 U U 9 U U 7 U 3 U U 9 U U 7 U 0.3 U U U 3 U U 9 U U 7 U 0.3 U U U 39 J 3 U. f 9 J 0.31 J U U U U 9 U U 7 U U U U 9 U U 7 U 9 U.3 U 0.3 U 0. U 99 U 9 U 3 U U 3 U U 9 U 3 U U 9 U U 7 U 0.3 U U U U U U U U 0.3 U U J 3 U U 9 U U 7 U 3 U U 9 U U 7 U 9 U.3 U 0.3 U 0. U 99 U 9 U 3 U U 3 U U 9 U 3 U U 9 U U 7 U 3 U U 9 U U 7 U 1. f 3. fg 170 bcdfgj 7.7 fgj 13 fgj 3. fg 3. fg 0.33 f.5 fg fg.7 fg 1. f 9 U.3 U 0.3 U 0. U 99 U 9 U 3 U U 3 U U 9 U 0.3 U U U 3 U 3 U U 3 U U 39 U 33 U 3 33 U 33 U 3 U 0.1 U 0.13 U. U 0.3 U 37 J 3 J 11 J 11 J 0.13 U 19 J 0.13 U 0.1 U S,'-Oxybis(1-chloropropane) (bis(-chloroisopropyl) ether),,5-trichlorophenol,,-trichlorophenol,-dichlorophenol,-dimethylphenol,-dinitrophenol,-dinitrotoluene,-dinitrotoluene -Chloronaphthalene -Chlorophenol -Methylnaphthalene U U.9 U 0.9 U 0. U 0. U U U.9 U 0.9 U 0. U 0. U U U.9 U 0.9 U 0. U 0. U U U.9 U 0.9 U 0. U 0. U U U.9 U 0.9 U 0. U 0. U U 0. U 0. U 0.17 U U 0.19 U 0.19 U 3.9 U 0.1 U 0.1 U 0.1 U 0.1 U U U.9 U 0.9 U 0. U 0. U U U.9 U 0.9 U 0. U 0. U U U.9 U 0.9 U 0. U 0. U U U.9 U 0.9 U 0. U 0. U J U 0. J 0.9 U 0. U 0. U 0.3 CRA Rpt Table 1.1.xlsx