RESPONSE ACTION PLAN

EPA Region 5 Records Ctr.

259799 ^MwEngineeringIntegrated Environmental Solutions

RESPONSE ACTION PLANHiawatha Business CenterFormer Lite Yard Property

Minneapolis, Minnesota

Prepared for:

Ryan Companies US, Inc.

March 31,2005

Peer Engineering, Inc.

4801 West 81st Street, Suite 118Bloomington, Minnesota 55437952 831-3341 Fax 952 831-4552

Integrated Environmental Solutions

Mr. Thomas Krueger, Esq. April 4, 2005U.S. Environmental Protection AgencyU.S. EPA, Region 5 (C-14J)77 West Jackson BoulevardChicago, Illinois 60604

RE: Response Action PlanRyan Companies Proposed DevelopmentCMC Heartland Partners Lite Yard PropertyMinneapolis, Minnesota

Dear Mr. Krueger:

Pursuant to the request of Betty Goodman, legal counsel for Ryan Companies US, Inc. (Ryan),Peer Engineering, Inc. (Peer) is providing the enclosed copy of the following document:

• Response Action Plan (RAP), Hiawatha Business Center, Former Lite Yard Property,Minneapolis, Minnesota, dated March 31, 2005 and prepared by Peer on behalf of Ryan.

The March 31, 2005 RAP addresses additional response actions that will be implemented byRyan at the Lite Yard Property following acquisition as part of their planned developmentactivities. The RAP was submitted on March 31, 2005 to the Minnesota Department ofAgriculture (MDA) Agricultural Voluntary Investigation & Cleanup (AgVIC) Program forreview and approval. A copy of MDA's approval letter will be provided to you when it isavailable.

If you have any questions regarding the enclosed document, please feel to contact me at (952)831-3341.

Sincerely,

Peer Engineering, Inc.

Stephen T. Jansen, M.S.President

PC: Ms. Betty GoodmanMs. Marie McCallum, RyanMs. Genevieve McJilton, RyanMr. Mark Schoening, Ryan.

RESPONSE ACTION PLANHIAWATHA BUSINESS CENTERFORMER LITE YARD PROPERTY

MINNEAPOLIS, MINNESOTA

MARCH 31, 2005

Prepared for:

Ryan Companies US, Inc.50 South 10th Street, Suite 300

Minneapolis, Minnesota 55403-2012

Prepared by:

Peer Engineering, Inc.4801 West 81S| Street, Suite 118Bloomington, Minnesota 55437

Phone:(952)831-3341Fax (952) 831-4552

Peer File #5253.53© Peer Engineering, Inc., 2005

TABLE OF CONTENTS

1.0 INTRODUCTION 12.0 BACKGROUND 1

2.1 SITE DESCRIPTION 12.2 SITE HISTORY 22.3 2004/2005 RESPONSE ACTIONS 3

2.3.1 General 32.3.2 Approved RAP 32.3.3 Completed Response Actions - 2004 42.3.4 Remaining Response Actions - 2005 4

2.4 PROPOSED DEVELOPMENT PLAN 53.0 ADDITIONAL RESPONSE ACTIONS FOR DEVELOPMENT 6

3.1 OVERVIEW 63.2 PERMITTING REQUIREMENTS 7

3.2.1 NPDES General Permit 73.2.2 Sanitary Sewer Discharge Permit 73.2.3 Hazardous Waste Permits 8

3.3 ADDITIONAL INVESTIGATIONS 83.4 RESPONSE ACTION DETAILS 9

3.4.1 General 93.4.2 Site Preparation 93.4.3 Excavation Activities 103.4.4 Soil Management 113.4.5 Soil Treatment 123.4.6 Soil Disposition 13

4.0 ENVIRONMENTAL MONITORING AND TESTING PLAN 144.1 OVERVIEW 144.2 FIELD SCREENING 154.3 POST EXCAVATION SAMPLING AND TESTING 16

4.3.1 Documentation Samples 164.3.2 Imported Clean Fill 174.3.3 Field Duplicates 17

4.4 DISPOSAL CHARACTERIZATION SAMPLING 184.4.1 Sampling Procedure 184.4.2 Analytical Testing 18

4.5 AIR MONITORING PROGRAM 194.5.1 Overview 194.5.2 Potential Exposure to the General Public 214.5.3 Air Monitoring for Site Workers 24

5.0 RESPONSE ACTION IMPLEMENTATION REPORT 266.0 SITE SAFETY AND HEALTH PLAN 277.0 SCHEDULE 28

LIST OF FIGURES

Figure

1 Property Location Map2 Property Diagram3 Historical Land Use4 Proposed Excavation Areas5 Proposed Sample Locations6 Perimeter Air Monitoring Locations

LIST OF APPENDICES

Appendix

A Approved RP-Funded RAP Document ListB Proposed Development PlanC Soil Disposition Flow ChartD Field Methods and Procedures

1.0 INTRODUCTION

Peer Engineering, Inc. (Peer) has prepared this Response Action Plan (RAP), on behalfof Ryan Companies, US Inc. (Ryan), to address additional environmental responseactions that will be implemented as part of development of the Lite Yard Property(Property) in Minneapolis, Minnesota. Response actions (i.e. Cleanup Actions) arecurrently being conducted at the Property by the identified Responsible Parties (RPs)

under the direction of the Minnesota Department of Agriculture (MDA) to addressidentified arsenic and lead contamination from past agricultural chemical manufacturingoperations. Following completion of these RP-funded Cleanup Actions, Ryan intends topurchase and develop the Property with a light industrial building for lease to a businessor businesses interested in operating in the area. Additional environmental responseactions will need to be completed to address residual soil contamination encounteredduring excavation-related development activities. These development-related responseactions are above and beyond the scope of the RP-funded Cleanup Actions currentlybeing conducted.

This RAP has been prepared for submittal to and approval by the MDA AgriculturalVoluntary Investigation & Cleanup (AgVIC) Program. Following issuance of MDA-approval, Ryan intends to submit this RAP to the Minnesota Pollution Control Agency(MPCA) Voluntary Investigation & Cleanup (VIC) and Petroleum BrownfieldsPrograms for approval of non-agricultural chemical impacts at the Property (e.g.petroleum).

2.0 BACKGROUND

2.1 SITE DESCRIPTION

The Property is a triangular shaped parcel that is approximately 4.99 acres in size and islocated at the northwest intersection of East 28lh Street and State Highway 55 in the Cityof Minneapolis (City), County of Hennepin, State of Minnesota. The Property is locatedin part of the southwest V* of Section 36, Township 29 North, Range 24 West. Figure 1shows the location of the Property. Figure 2 is a diagram of the Property showing

existing features.

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The western edge of the Property is bordered by the Northwest Hennepin County Regional

Railroad Authority (NW HCRRA) Corridor parcel (a 100 feet wide former railroad right-of-way), with The Roof Depot building beyond. To the east of the Property is StateHighway 55 (also known as Hiawatha Avenue), with a multi-tenant office/warehouse

building and buildings occupied by Pro Floor, Inc. and by DC Sales beyond. To the southof the Property is a 10-foot wide City right-of-way and East 28th Street, followed by theSouth HCRRA Corridor (also a former railroad right-of-way) and beyond by buildings forJohn Dalsin & Sons Roofing and Sheetmetal, Jadco Supply & Equipment and The GreenInstitute; the Smith Iron Foundry is located immediately southwest of the Property acrossEast 28th Street. To the north of the Property is the City asphalt plant and State Highway 55,with the Allweather Roof building beyond.

The Property is currently vacant and all former structures have been razed. The Property atone time included addresses of 2000 to 2100 East 28th Street. A six-foot high chain linkfence surrounds the Property. Four groundwater monitoring wells are currently located onthe Property.

The Property was originally part of a 7.7-acre parcel (Original Parcel), which included anarea that extended approximately 100-feet east and parallel to the current eastern propertyboundary. In May 1998, the Minnesota Department of Transportation (Mn/DOT) acquiredthe easternmost approximately 2.8 acres of the Original Parcel, and subsequentlyredeveloped it as part of the Hiawatha Corridor reconstruction project.

2.2 SITE HISTORY

The Property had been developed as a railroad yard from at least 1885 through the early1970's. Historical information indicates a former leaseholder, Reade Manufacturing,operated an agricultural chemical business on the south-central portion of the Property at2100 East 28th Street. Arsenical-based herbicides were mixed and produced at thislocation as early as 1940. U.S. Borax subleased the property from Reade between 1963and 1968 and operated on the Property for a portion of the sublease period.

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Two former bulk storage facilities were also previously located on the south-central

portion of the Property. One of the storage facilities was operated by Rollins OilCompany (2000 East 28th Street) from as early as 1933 through the mid-1980s. TheRollins facility operated up to five Aboveground Storage Tanks (ASTs) and one

Underground Storage Tank (UST) that contained petroleum products at the Property. Asecond storage facility (Reade Manufacturing, then U.S. Borax) was located immediatelyeast of the Rollins facility and contained up to 14 ASTs at various times between 1912and the early 1970s. Use of the storage tanks prior to Reade Manufacturing operations isnot known.

Figure 3 shows historical land use at the Property.

2.3 2004/2005 RESPONSE ACTIONS

2.3.1 General

CMC Heartland Partners (CMC) and U.S. Borax (Borax) have been identified by theMDA as RPs for the arsenic and lead contamination at the Property. The RPs retainedPeer as the engineer of record and Carl Bolander and Sons, Inc., (Bolander) as theremediation contractor, to implement Cleanup Actions of arsenic and lead impacted soilat the Property in October 2004. These RP-funded Cleanup Actions will be completed byJune 2005, at which time Ryan intends to construct a light industrial building at theProperty. In order to successfully develop the Property, additional environmental actionswill be required as part of construction that are above and beyond the scope of the currentRP-funded Cleanup Actions being required by the MDA.

2.3.2 Approved RAP

An original RAP dated March 12, 2004 was prepared by Exponent, Inc., on behalf of theRPs to address arsenic and lead contamination at the Property. The March 12, 2004 RAP

summarized previous investigation activities, known soil and groundwater conditions,remedial alternatives and proposed cleanup actions for the Property. MDA issued ini t ia lapproval and comments regarding the March 12, 2004 RAP in letters dated March 10,2004, March 15, 2004 and April 23, 2004; and final approval in a letter dated April 29,2004. The final MDA approval letter requested that supplemental information regarding

RAP implementation be submitted in a "Response Action Design and ImplementationPlan (RAD/IP)". Peer prepared the RAD/IP dated June 21, 2004, which was


subsequently submitted to and approved by the MDA in a letter dated July 28, 2004. A

list of regulatory comment and approval letters related to the original RAP and RAD/EPare included in Appendix A.

2.3.3 Completed Response Actions - 2004

Response actions completed in 2004 include the following:

• Clearing and grubbing of the Property, and removal of former building foundations.

• Installation of storm water controls (silt fence, sediment traps and rock entrances).

• Excavation of approximately 21,000 cubic yards of contaminated soil from the "HotSpot" area. Of this volume, 11,600 cubic yards of soil was stabilized and disposedoff-site as industrial waste, 5,700 cubic yards was disposed as industrial wastewithout stabilization, and 1,100 yards was disposed as daily cover. Approximately2,610 cubic yards of contaminated soil was approved by the MDA for reuse asbackfill at a depth of approximately 11 to 13 feet below planned development gradewithin the Hot Spot area.

• Excavation of an additional 8,820 cubic yards of soil and recycled asphalt exceedingcleanup standards that was located within the upper 4 feet of planned developmentgrade in areas of the Property outside of the Hot Spot. This soil was disposed asindustrial waste.

• Import and placement of clean granular fill to restore excavation areas at the Propertyto planned development grades.

• Continuous daily air paniculate monitoring, sampling and testing around theperimeter of the Property.

• Collection of documentation samples from the base of excavations to verifyremaining concentrations of arsenic and lead in the soil located four feet belowplanned development and restored grades.

2.3.4 Remaining Response Actions - 2005

The following remaining response actions will be completed by the RPs in May/June

2005:

• Excavation of an additional 15,000 cubic yards of arsenic and lead contaminated soilwithin 4 feet of the planned development grades to achieve established cleanup

standards on the Property and the adjoining NW HCRRA parcel and the East 28*

Street Right-of-Way parcel.

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• Import and placement of clean granular fill to restore excavation areas to planned

development grades at the Property and existing grades in the adjoining areas.

• Continuous daily air paniculate monitoring, sampling and testing around the

perimeter of the Property.

• Collection of documentation soil samples from all areas of the Property on a 50 by 50

foot grid spacing at the bases of excavation areas and any undisturbed areas to verify

remaining concentrations of arsenic and lead within four feet of planned development

grades meets the approved cleanups standards.

• Sealing of any remaining on-site monitoring wells obstructing remediation activities,

installation of new monitoring wells as required to develop a groundwater quality

monitoring network, and implementation of long term groundwater monitoring.

• Preparation of a response action implementation report for submittal to the MDA with

request for No Action Determination related to soil contamination.

2.4 PROPOSED DEVELOPMENT PLAN

Ryan intends to purchase and develop the Property with a light industrial building for

lease to a business or businesses interested in operating in the area. A figure depicting

Ryan's currently proposed grading and utility plan is included in Appendix B. The

development would include a 60,200 square foot, one-story, "L" shaped building with

slab-on-grade construction with a finished floor slab elevation of 844 feet National

Geodetic Vertical Datum (NGVD). A bituminous paved, recessed loading dock area

would be located on the west side of the building, which ranges in finished elevation

from 840 to 843 feet. Bituminous paved parking and drive areas would surround the

building and range in elevation from 841 to 843 feet. An unlined, on-site storm water

retention pond is planned at the north end of the Property, with finished elevations

ranging from 829 to 840 feet. Other unpaved areas of the Property would be landscaped.

Access would be off of 28lh Street East, from the southwest corner of the Property.

Storm water lines and associated catch basins would be located beneath the loading dock

and paved parking/drive areas and discharge to the storm water pond. Invert elevations

for the storm water lines would range from approximately 833 to 837 feet. The sanitary

sewer service would run from the east side of the building and connect to the main in

East 28th Street. Elevations for the sanitary sewer line would range from approximately

835 to 836 feet. The building would have two water service connections, with a

continuous loop water line that encircles the building and ties into the water main located

in East 28lh Street. The water line would be located a minimum of 7.5 feet below

finished grade.

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3.0 ADDITIONAL RESPONSE ACTIONS FOR DEVELOPMENT

3.1 OVERVIEW

Additional investigation and response actions will need to be completed by Ryan as part

of purchase and development of the Property to address residual soil contaminationencountered during construction-related activities. These development-relatedinvestigation and response actions, which are above and beyond the scope of the RP-funded Cleanup Actions currently being conducted, generally include:

1. Completion of the environmental due diligence activities, including preparation of aPhase I Environmental Site Assessment (ESA), and obtaining regulatory liabilityassurances.

2. Completion of additional investigations in support and preparation of acquisition anddevelopment of the Property.

3. Completion of required environmental monitoring, testing and documentation tofacilitate proper identification, segregation and characterization of contaminated soilremoved during completion of development-related excavation activities.

4. Management of contaminated soil that must be removed to complete the developmentactivities.

5. Chemical stabilization (i.e. treatment) of any contaminated soil identified withelevated concentrations of arsenic and lead to render the soil non-hazardous andallow for disposal as industrial waste.

6. Off-site disposition of arsenic, lead and petroleum contaminated soil removed duringdevelopment.

Details concerning the additional investigations and response actions required fordevelopment are provided in the following sections.

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3.2 PERMITTING REQUIREMENTS

This section describes anticipated environmental permitting requirements for

implementation of additional development-related response actions.

3.2.1 NPDES General Permit

The National Pollutant Discharge Elimination System (NPDES) program regulates stormwater runoff as it may affect surface water quality. In Minnesota, the U.S. EnvironmentalProtection Agency (EPA) has delegated authority to administer the federal NPDES stormwater discharge permit program to the MPCA.

Storm water runoff during development-related earthwork and response actionimplementation will be covered by a "General Permit". General permits are NPDESpermits that contain the terms and conditions of a permit. General permits are notspecific to any one discharger; instead the general permit identifies which dischargersmay be eligible for coverage under the general permit. Prior to implementation of theresponse actions, the following must be completed to obtain a General Permit:

1. Prepare a Storm Water Pollution Prevention Plan outlining potential pollutantsources, best management practices, implementation, and evaluation methods.

2. Submit an "Application for General Storm-water Permit for Construction Activity(MN R00001)" along with the permit fee to the MPCA.

Upon review, the MPCA will issue a General Permit within approximately one week.

3.2.2 Sanitary Sewer Discharge Permit

Native soils below a depth of 4 feet below ground surface (bgs) and backfill materialplaced at the Property as part of the RP-funded Cleanup Actions is permeable granular

soil. This type of soil is well drained, and it is not anticipated that significant amounts ofstorm water runoff will accumulate in the development related excavations for thebuilding foundation, utilities and the storm water pond. In addition, ground water occurs

at a depth of 27 feet bgs, and will not be encountered during construction activities.

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Therefore, a Metropolitan Council Environmental Services (MCES) TemporaryDischarge permit will not be obtained for the project at this time.

3.2.3 Hazardous Waste Permits

The proposed additional response actions will be conducted in a manner that ensurescontaminated soils are handled and treated in a manner that will not trigger hazardouswaste permitting requirements under State or Federal hazardous waste regulations.Specifically, all contaminated soil will be handled and treated (as necessary) so that nohazardous wastes subject to Resource Conservation and Recovery Act (RCRA) permitrequirements are generated. Consequently, no permits for the treatment, storage anddisposal of hazardous wastes are anticipated to be required for implementation of the

additional response actions.

3.3 ADDITIONAL INVESTIGATIONS

Two additional investigations will be completed at the Property in support ofdevelopment, including a geo-environmental investigation of planned construction areas,and a petroleum vapor impact investigation in the area of the former bulk storagefacilities. A Work Plan specifying components of the additional investigation activitieswill be prepared and submitted under separate cover for regulatory review and approvalprior to initiation. Summaries of the proposed additional investigations are presented

herein.

Geo-Environmental Investigation

An estimated six to ten additional soil borings will be advanced at the Property to provideadditional subsurface soil data for the proposed development. The borings will be placedat appropriate locations across the Property based on geotechnical considerations. It isanticipated that the borings will be advanced in areas of planned excavation forunderground utilities, building footings, parking/drive areas, and the storm water pond.

Environmental monitoring, sampling and testing will be conducted during completion ofthe geotechnical borings to confirm the subsurface environmental conditions in theseconstruction areas.

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Petroleum Soil Vapor Investigation

In response to proposed MPCA Petroleum Brownfields Program changes, a soil vaporintrusion (SVI) investigation will be completed at the Property in the areas of the former

bulk storage facilities. Approximately four to five sampling probes will be advanced onthe south-center portion of Property to investigate the potential for petroleum soil vaporaccumulation associated with past use of the Property as a bulk storage facility. Theinvestigation will include completion of sampling probes, and collection of soil vaporsamples for analytical testing from each probe. The SVI investigation will quantify theconcentration of subsurface petroleum vapors (if present) and provide data for evaluatingthe need for engineering controls to mitigate the potential for vapor intrusion into theproposed building.

3.4 RESPONSE ACTION DETAILS

3.4.1 General

Additional environmental response actions will be completed concurrently withdevelopment earthwork activities. At this time, it is anticipated that Bolander, the currentremediation contractor for the RPs, will be retained by Ryan to conduct the excavationactivities and additional response actions (i.e. soil management and disposition). If adifferent contractor is retained to perform the work described herein, the MDA will benotified.

3.4.2 Site Preparation

Following Ryan's purchase of the Property and start of construction, the followingactivities will be completed in preparation for response action implementation:

• Silt fencing and other necessary erosion control features will be installed at theperimeter of the Property (Note: erosion control features may be left in-placefollowing completion of the RP-funded Cleanup Actions; if so, they will be utilized to

the extent practical).


• A Temporary Staging Area for excavated soil will be established on the Property.The area will be used for the temporary stockpiling of contaminated and potentially

contaminated soil segregated during development excavation that requires

characterization prior to disposition. The location of the Temporary Staging Areawill be determined prior to the start of excavation activities.

3.4.3 Excavation Activities

General

Excavation will be required as part of development activities for installation ofunderground utilities, building footings, construction of a storm water retention pond, andfor geotechnical soil correction in planned paved drive and parking areas outside of theproposed building footprint. Proposed excavation areas that may encounter potentiallycontaminated soil below a depth of four feet from planned development grades are shown

on Figure 4. Soil management procedures and environmental monitoring will beimplemented during development activities to insure the proper identification, handlingand disposition of any contaminated material removed.

Shallow Soil (within four feet of planned development grades)

Following completion of the RP-funded Cleanup Actions, shallow soil within four feetthe planned development grades will consist of either clean imported granular fill orintermittent areas of native soil that did not require cleanup because it was verifiedthrough analytical testing that the soil met the approved cleanup standards of 20milligrams per kilogram (mg/kg) arsenic and 525 mg/kg lead. Thus, shallow soilexcavated during construction within four feet of planned development grades will beexcavated and stockpiled (without engineering controls) separately from contaminatedand potentially contaminated deeper soil. Because the shallow soil will have alreadybeen documented to meet the approved cleanup standards, no environmental monitoringor analytical testing will be conducted. If there is any shallow soil that is excavated anddetermined to be geotechnically unsuitable and can not be reused on-site, that material

will be disposed of off-site using previous documentation sampling analytical results

from the RP-funded Cleanup Actions.

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Deep Soil (below four feet of planned development grades)

Based on existing analytical testing data, all excavations below four feet of planneddevelopment grades have the potential to encounter contaminated soil. Potentiallycontaminated soil will be segregated, managed (see Section 3.4.4), treated if required(see Section 3.4.5), and then characterized for proper disposition (see Section 4.4).Environmental monitoring and testing will be conducted as described in Section 4.0. For

purposes of this RAP, it is anticipated that the maximum volume of contaminated soilremoved and requiring off-site disposition will be 5,000 cubic yards.

Segregation activities will be directed utilizing existing soil documentation data collectedduring the RP-funded Cleanup Actions that was linked to an established 50 by 50 footsurveyed grid system on the Property. Soil excavated from grid cells with higher residualcontaminant concentrations will be stockpiled separately from soil in grid cells withlower residual contaminant concentrations.

During excavation below four feet of planned development grades, the remediationcontractor will be required to take measures to control dust generation. Air monitoringwill be conducted during periods of excavation to verify that dust generation isminimized and controlled to appropriate levels. Information concerning air monitoringprocedures is provided in Section 4.5.

3.4.4 Soil Management

Contaminated and potentially contaminated soil segregated during development-relatedexcavation activities will be stockpiled with engineering controls in the TemporaryStaging Area at the Property until it is characterized to determine appropriate dispositionoptions. Individual stockpile volumes will not exceed 250 cubic yards. The TemporaryStaging Area will be constructed and operated in a manner to eliminate potential run-offduring precipitation events, and to minimize dust generation. The base of the stagingarea will be lined with 10-mil reinforced polyethylene sheeting. Stockpiled soil will becovered with 10-mil reinforced polyethylene sheeting. The sheeting will be secured with

clean soil or other suitable materials (e.g., tires). Note: air monitoring will be conductedduring soil stockpiling activities as discussed in Section 4.5.


3.4.5 Soil Treatment

Based on previous investigation and Cleanup Action implementation data, there is a

potential that some deeper soil (below four feet of planned elevation grades) at theProperty has elevated residual arsenic and/or lead at concentrations that may exceedhazardous waste criteria as determined by the Toxicity Characteristic Leaching Procedure(TCLP). The respective TCLP criterion for both arsenic and lead is 5.0 milligrams perliter (mg/L). Previous TCLP testing data for the Property indicates that soil containingtotal arsenic concentrations greater than 800 mg/kg and total lead concentrations greaterthan 2,300 mg/kg have the potential to exceed the established TCLP criteria of 5.0 mg/Lfor both arsenic and lead.

Segregated and stockpiled contaminated and potentially contaminated soil will besampled and analyzed for TCLP arsenic and lead concentrations as described in Section4.4. Stockpiled soil found to exceed the TCLP hazardous waste criteria will be treated inthe Temporary Staging Area and stabilized to render the materials non-hazardous for

disposal purposes using the soil treatment chemical Enviroblend®. Soil treatment was

successfully conducted during the RP-funded Cleanup Actions using Enviroblend®.

It is not expected that large quantities of soil removed during development excavationwill require stabilization. However, contaminated soil with elevated levels of arsenic andlead have been identified on the south portion of the Property below four feet of planneddevelopment grades, which may be encountered during utility excavations. For purposesof this RAP, it is anticipated the maximum volume of contaminated soil requiringtreatment will be 250 cubic yards.

Specific soil treatment procedures will include:

• Stockpiled materials that exceed the established arsenic and/or lead TCLP criterion

will be stabilized using treatment chemical Enviroblend®. The treatment chemical

will be added at the appropriate proportion to the stockpiled materials within theTemporary Staging Area using a front end loader and/or a backhoe bucket. Abackhoe will be used to thoroughly mix the additional treatment chemical into thestockpiled material. Mixing will continue unti l visual observations indicate that the

stockpiled soil and treatment chemical are well mixed.


• Samples of the treated materials will be collected for laboratory analysis to verify that

stabilization activities effectively achieved the established TCLP criterion.

• Anticipated sampling frequencies and procedures for the treated material verification

sampling are described in Section 4.5.

Additional soil treatment and re-sampling of the stockpiled materials will be continued

until it is demonstrated that the TCLP criterion have been achieved.

3.4.6 Soil Disposition

The flow chart included in Appendix C presents the anticipated management procedures

and disposition options for soil removed during development. Disposition options for theexcavated soil will depend on environmental monitoring and testing results as described

in Section 4.0 and geotechnical suitability. Disposition options will include:

Unrestricted Use On-Site

Excavated soil will be considered acceptable for "unrestricted" reuse on-site if it meets

the following criteria:

• Geotechnically suitable (i.e. compactable, granular material).

• No visual or olfactory evidence of impacts are present.

• Photoionization Detector (PID) readings less than 5 part per million (ppm).

• The arsenic concentration is less than 20 mg/kg and lead concentration is less than525 mg/kg (these are the criteria established by MDA for the RP-funded CleanupActions).

Restricted Use On-Site

Excavated soil will be considered acceptable for "restricted" reuse on-site at depths

below four feet of planned development grades (e.g. in util i ty trenches) if it meets the

following criteria:

• Geotechnically suitable (i.e. compactable, granular material).

• PID readings less than 10 ppm.

• Arsenic and lead concentrations less than the MPCA established Short-Term Worker

Soil Reference Values (SRVs) of 55 mg/kg and 700 mg/kg, respectively.

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Off-Site Disposition

If excavated soil is found to be geotechnically unsuitable and/or does not meet the

environmental on-site reuse criteria, it will be disposed of off-site as either alternative

daily cover or industrial waste at a permitted facility. The specific off-site disposal

facility to be used will be determined at a later date. The MDA will be informed of the

selected disposal facility.

Contaminated soils requiring off-site disposal will be manifested, loaded and transported

to selected disposal facility. All soil transported off-site for disposal will be loaded

directly from the stockpiles in the Temporary Material Staging Area. The remediation

contractor will be required to take measures to control dust and surface water runoffduring the loading activities. Sampling and analysis of soil to be disposed off-site will be

completed based on the specific disposal facility requirements. Air monitoring will beconducted as discussed in Section 4.5 during periods when contaminated soil is being

loaded for off-site transport.

4.0 ENVIRONMENTAL MONITORING AND TESTING PLAN

4.1 OVERVIEW

Environmental monitoring and testing will be performed during response actionimplementation to ensure that contaminated soil excavated during development excavations

is identified, managed, and characterized for proper disposition. Sampling and testing willalso be conducted to document remaining concentrations of arsenic and lead in the soil inconstruction excavations. Air monitoring and testing will be conducted during activitiesinvolving significant disturbance of contaminated or potentially contaminated soil to

minimize the potential risk of exposure to site workers and the general public.


4.2 FIELD SCREENING

XRF Screening

A portable X-ray fluorescence (XRF) analyzer will be used to determine relative

concentrations of arsenic and lead in excavated materials. Specifically, a Niton XL-309Spectrum Analyzer will be used. This instrument contains a Cd-109 isotope source andis calibrated to detect metals. Information supplied by the manufacturer (Niton) indicatesthe XRF has the following approximate soil detection limits based on a 60 source secondmeasurement:

- Arsenic: 114 ppm- Lead: 45 ppm

Samples of the stockpiled soil will be screened using the XRF at an estimated frequencyof one sample for every 50 cubic yards of stockpiled material. The XRF results will beused as a guide to determine if the soil contains elevated arsenic and/or leadconcentrations and may require treatment. Soil removed from the development-relatedexcavations is anticipated to contain relatively low concentrations of arsenic and lead (ator below the XRF detection limits) thus, the XRF results will be confirmed by laboratoryanalytical testing.

Organic Vapor Screening

Previous investigations have identified petroleum-impacted soil in the vicinity of theformer bulk storage facilities on the south-central portion of the Property. Thus, organicvapor monitoring will also be conducted during excavation activities in areas of theProperty where potential petroleum-impacted soil may be encountered.

Organic vapor monitoring will be conducted using a PID. The PID will be equipped witha 10.6 eV lamp and will be calibrated to an isobutylene standard to read in ppm benzene.PID screening will be used to evaluate if significant concentrations of organic vapors arepresent within the breathing zone of site workers. Evaluation criteria for petroleum

vapors will be included in the Site Safety and Health Plan prepared for the Property (seeSection 6.0).

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4.3 POST EXCAVATION SAMPLING AND TESTING

4.3.1 Documentation Samples

Soil samples will be collected from the development-related excavations to document the

levels of arsenic and lead remaining in-place. Based on the planned development grades,this type of sampling will primarily apply to the base of the utility trench excavations and

base and sidewalls of the storm water pond. Sample collection and handling proceduresare described in Appendix D. No documentation sampling is planned in parking areas

requiring potential soil correction or at the base of building footing excavations, because

documentation samples will have already been collected from these areas as part of theRP-funded Cleanup Actions.

Utility Trenches

Grab samples will be collected from the base of each utility trench excavation, which

represent the upper 4-inches of soil at the respective locations. In general, one base

sample will be collected from every 100 linear foot of excavated utility trench. Actual

sampling locations and frequencies will be based on field determinations and professionaljudgment.

Storm Water Pond

Grab samples will be collected from the base and sidewalls of the storm water pond to

characterize the upper 4-inches of soil at the respective locations. The anticipated stormwater pond sample locations are shown on Figure 5.

Analytical Testing

The documentation soil samples will be submitted to an off-site laboratory for analysis of

total arsenic and total lead using EPA Method 6010.


4.3.2 Imported Clean Fill

It is anticipated that less than 5,000 cubic yards of imported fill will be required forbackfilling of the development-related excavations. Samples of the imported fill will becollected as follows:

• A minimum of one sample will be collected from each separate fill source utilized forthe project.

• A minimum of one sample will be collected for each 2,000 cubic yards of filldelivered to the Property from a specific fill source. Samples of the imported fill willbe collected at more frequent intervals if the fill materials appear inhomogeneous orappear different from previously sampled materials.

The imported fill samples will be submitted to an off-site laboratory for analysis of thefollowing parameters:

• Volatile Organic Compounds (VOCs) by EPA Method 8260.

• Semi-Volatile Organic Compounds (SVOCs) by EPA Method 8270 (base-neutralfraction).

• 8 RCRA Metals (EPA Methods 6010/7421).

• Polychlorinated Biphenyls (PCBs) by EPA Method 8082.

Only imported fill that meets the MPCA residential SRVs and Soil Leaching Values(SLVs) for detected compounds will be considered acceptable for use on the project.

4.3.3 Field Duplicates

Field duplicate soil samples will be collected to provide a means to evaluate laboratoryperformance by comparing analytical results of two samples from the same location.Field duplicate samples are also collected to evaluate field sample collection procedures.Field duplicate samples are co-located samples collected from one sample location andsent to the laboratory blind (with two different sample numbers).


Field duplicates will be collected for approximately 10% of the samples collected during

the project. The duplicate samples will consist of an equal division of a randomlyselected sample. The sampling technician will record the duplicate sample's unique

identifier along with the primary sample's identification number in the field notes.

4.4 DISPOSAL CHARACTERIZATION SAMPLING

4.4.1 Sampling Procedure

Soil Samples will be collected from the stockpiles of contaminated or potentiallycontaminated soil to characterize it for proper disposition (i.e. on-site reuse of off-sitedisposal). One composite sample will be collected from each soil stockpile requiringcharacterization. Each composite sample will consist of twelve equal volume aliquots.Field sampling and handling procedures are described in Appendix D. The followingadditional information related to the proposed sampling is provided:

• Each stockpile will be assigned a unique identification number.

• Each stockpile will be visually divided into four quadrants of approximately equal size.

• Aliquots of equal volume will be collected from the top, middle and bottom thirds ofeach quadrant (total of 12 grab samples) using hand tools, to create a composite sample.

• The aliquots will be placed in a scalable one-gallon plastic bag and thoroughly mixed toform a composite sample that is representative of the stockpile.

• The soil within the bag will be transferred to a labeled sampling container.

• Disposable sampling equipment (sampling gloves, plastic bags, plastic trowel) will bediscarded as trash. All non-disposable equipment used for sampling will be cleaned anddecontaminated between sampling events.

4.4.2 Analytical Testing

The stockpile samples will be submitted to an off-site laboratory for analysis of total andTCLP arsenic and lead. Sampling and analysis for additional parameters may beconducted if required by the selected disposal facility. Waste characterization,manifesting and disposal will also be discussed and coordinated with the MDA, as

appropriate.


4.5 AIR MONITORING PROGRAM

4.5.1 Overview

General

This air monitoring program describes the procedures that will be used to conduct airmonitoring and air sampling during development-related excavation that will encountercontaminated or potentially contaminated soil, handling of that soil, and during loading ofsoil for off-site disposal. Air monitoring will help to ensure protection of both thegeneral public and site workers during completion of the work.

Field instruments that measure and display the concentration of particulates in air areavailable and are commonly used to monitor both total particulates and to estimate theconcentration of metals (i.e., arsenic and lead) in the air. Since arsenic and lead areassumed to be present only in particulate form, not vapor or gas, measurement ofparticulates can give a real-time approximation of the maximum possible arsenic or leadconcentrations in air and can be used to determine if the air meets or exceeds theappropriate standards. Based on previous investigation results in the proposed areas ofexcavation, the maximum concentration of arsenic expected to be encountered is 2,500mg/kg or 0.25%. Therefore the assumed worst-case arsenic concentration will be 0.25%of the observed particulate concentration. The maximum concentration of lead in soilexpected to be encountered is approximately 1,000 mg/kg or 0.1%. Therefore, theassumed worst case lead concentration will be 0.1% of the observed particulateconcentration.

Laboratory analysis of air samples or air filter samples can provide a more accurateconcentration of arsenic or lead in a given air volume. However, the results won't beavailable unti l a few days after the sample is collected. Each sample will be collectedwith a sampling pump calibrated to draw air at a specific flow rate and volume. NationalInstitute for Occupational Safety and Health (NIOSH) Method 7300 will be used todetermine the concentration of arsenic in air. The air samples will be drawn at a flow rate

of 4 liters per minute (L/min) to reach a volume of 500 liters (125 minutes). The sampleswill pass through a 0.8 urn cellulose ester membrane filter that is 37 mm in diameter andhoused in a cassette filter holder. The filters will be sealed and provided to the laboratoryfor analysis of arsenic and lead.


Wind Speed and Direction

The wind speed and direction will be monitored during each day of excavation with a

portable weather station. The weather station will record the wind speed and direction at

regular intervals throughout the work day. Results of the monitoring will be reviewed todetermine the perimeter monitoring locations to be used to determine the upwind and

downwind sampling locations.

Perimeter Monitoring

Four perimeter air monitoring locations will be established. The monitoring locations are

spaced apart to provide reasonable coverage of the air in all directions from the Property.

The perimeter locations were selected to provide the least potential interference withconstruction activities and to adequately monitor the air leaving the property.

The four perimeter monitoring locations are shown on Figure 6. The monitoring

locations will be identified as:

• Pxxx

• where:- P represents a perimeter monitoring location.

- xxx represents the direction to the monitoring location in degrees from the center of the

Property.

Each monitoring location will be equipped with an aerosol monitor (i.e., MIEDataRAM) capable of monitoring and recording the average, Short Term Exposure

Limit (STEL) and maximum paniculate concentration over the entire day. The aerosolmonitor can measure particulates in the range from 0.001 to 400 milligrams per cubic

meter (mg/m3). The four aerosol monitors will be set to record continuous paniculate

concentrations during periods of work involving the disturbance of contaminated or

potentially contaminated soil. The monitors will also be checked at least three times a

day at staggered intervals by qualified field personnel to determine if particulate

exceedances have occurred.

Peer Engineering, Inc.March 31, 2005 Bloominglon, Minnesota -Page 20

In addition, an MIE Active Sampling Conversion kit will be used to enable the collection

of particulate samples for laboratory analysis. The participate samples will be collectedin mixed cellulose ester (MCE) filters housed in plastic cassettes. The filters are 37 mm

in diameter and have a 0.8 u. pore size. Each sample collected will represent 500 liters of

air taken over a 125 minute time period. To ensure that the air flow is properly measured,

the active sampler will be calibrated regularly. One particulate samples will be collected

daily during an interval when disturbance of contaminated or potentially contaminatedsoil excavation is occurring.

Worker Monitoring

Workers will be monitored for particulate concentrations during excavation and soil

handling activities. The monitoring will be conducted by the remediation contractor using

an aerosol monitor (i.e., MIE pdm-3 Miniram) capable of monitoring and recording

aerosol concentrations from 0.01 to 100 mg/m3. The aerosol monitor will be carried witha specific worker or placed on a vehicle in an appropriate position to monitor the air

within the work area. The monitor will be set to alarm when the particulate

concentrations reach a pre-determined level. At that point, site workers will takeappropriate actions as described in Section 4.5.3.

4.5.2 Potential Exposure to the General Public

Exposure Standards

The previously approved RAD/IP established short-term time-weighted averages(TWAs) for total particulates, arsenic, and lead and will be utilized during

implementations of this RAP. The established limits are:

Parameter Maximum Allowable Levels

Total Particulates 10 mg/m3 (TWA)

Total Arsenic 0.01 mg/m3 (TWA)

Total Lead 0.05 mg/m3 (TWA)

Those maximum allowable levels will be used to trigger action criteria related to airborne

contaminants.

Peer Engineering, Inc.March 31, 2005 Bloomington, Minnesota -Page 21

For real-time measurement of arsenic and lead, the worst case concentrations of those

contaminants as observed in soil samples along with the observed concentrations of totalparticipates will be used to calculate the assumed arsenic or lead concentrations in air.The worst-case concentration of arsenic was 0.25% and of lead was 0.1%. Therefore theTWA for total particulates due to either arsenic or lead is:

Arsenic: 0.01 mg/m3 / 2.5/1000= 4 mg/m3 total particulatesLead: 0.05 mg/m3 / 1/1000 = 50 mg/m3 total particulates

Based on these calculations, the lowest TWA is due to the presence of arsenic inparticulates. Therefore, a TWA of 4 mg/m3 for total particulates will be used as theoverall exposure standard for field measurements taken at the perimeter of the Property.

Real-Time Measurement

The highest concentration of air-borne contaminants measurable at the Property boundarywill determine the exposure to the general public on that day. The concentration of air-borne contaminants will be determined each day as follows:

1. The current wind direction will be measured and recorded in degrees relative to truenorth (0°).

2. The ambient concentration of air-borne particulates will be measured at the perimetermonitoring location closest to the up-wind direction of the Property as determined bythe measurement in step #1.

3. The concentration of particulates in air leaving the Property will be measured alongthe perimeter on the down-wind side of the Property as determined by the winddirection. The highest observed concentration of particulates from those threemeasurements will be used to determine the concentration of air-borne arsenic andlead.

4. The particulate concentration from step #2 will be subtracted from the highestconcentration from step #3. That concentration will be multiplied by the maximumarsenic percentage (0.25%) and lead percentage (0.1%) to determine the highest

potential concentration of arsenic or lead in air leaving the Property. If updatedinformation collected during the cleanup provides evidence of more accurate arsenicor lead concentrations in particulates based on laboratory reports, the updated arsenic

or lead concentration will be used instead of 0.25% or 0.1%, respectively.


Daily Sampling

During each day of soil excavation, removal or placement a sample of the air on the

downwind side of the Property will be collected in a sample filter and analyzed for

arsenic and lead by an analytical laboratory. The sampling to be completed while the soil

movement is being conducted as follows:

• The current wind direction will be measured and recorded in degrees relative to truenorth (0°).

• A sample of the particulates in air leaving the Property will be collected at thelocation along the perimeter closest to the down-wind side of the Property as

determined by the wind direction. The sample will be collected over a 125 minute

period as necessary to obtain a sample from 500 liters of air.

• The filter will be sealed and transferred to the laboratory under Chain of Custodyprocedures.

• The filter will be analyzed for arsenic and lead by NIOSH method 7300.

• The analytical results for arsenic and lead, in units of (mg/m3), will be reported to the

Engineer within 48 hours of submittal.

Data Management and Reporting

Each day's measurements will be recorded and made available as described herein.

Field Recording

The monitoring results will be maintained by the Engineer. At the end of the day, theEngineer will collect, calculate and analyze the day's results. The results will include:

• Wind speed and direction recorded at regular intervals.

• Daily average, STEL, and maximum particulate readings from each of the four

perimeter monitoring stations.

• Calculated daily highest potential arsenic and lead concentration in air.


Reporting

Before the end of the next work day after collection of the monitoring results and/or

receipt of analytical test results, the Engineer will compare the paniculate, arsenic and

lead concentrations to the appropriate standards. The following results will be made

available to the designated MDA representative via FAX or email.

• Hours of operation during the preceding work day.

• Average wind speed and direction during each hour of operation.

• Daily average, STEL and maximum particulate concentration from each of the four

monitoring locations.

• Calculated arsenic and lead concentration at the perimeter.

• Results of analysis of air samples collected on preceding days, but made available on

the previous day.

• Comparison of observed, calculated and laboratory analyzed particulate, arsenic, and

lead concentrations to standards.

• Actions taken to mitigate air borne contaminants, if any.

• Recommended future actions or changes in operation, if any.

Action Criteria

If the airborne contaminant concentrations at the perimeter of the Property exceed theexposure standard, one or more of the following actions shall be taken:

• Apply water to all accessible drive areas with a water truck.

• Spray water on exposed stockpiles or excavations.

• Cover exposed stockpiles or excavations with plastic or foam.

• Stop work.

4.5.3 Air Monitoring for Site Workers

Exposure Standard

The Occupational Safety and Health Administration (OSHA) have established maximum

allowable TWAs for workers exposed to specific airborne contaminants throughout a 10-

hour workday. The TWAs are:


Parameter Maximum Allowable Levels

Total Particulates 5 mg/m3 (TWA)

Total Arsenic 0.01 mg/m3 (TWA)

Total Lead 0.05 mg/m3 (TWA)

For real-time measurement of arsenic and lead, the worst case concentrations of those

contaminants as observed in soil samples will be used along with the observed

concentrations of total particulates to calculate the assumed arsenic or lead concentrations

in air. The worst-case concentration of arsenic was 0.25% and of lead was 0.1%.

Therefore, the TWA for total particulates due to either arsenic or lead are:

Arsenic 0.01 mg/m3 / 2.5/1000 = 4 mg/m3 total particulates

Lead 0.05 mg/m3 / 1/1000 = 50 mg/m3 total particulates

Based on these calculations, the lowest TWA is due to the presence of arsenic in

particulates. Therefore, a TWA of 4 mg/m3 for total particulates will be used as the

overall exposure standard for site workers.

Personal Protective Equipment

Site workers will be required to follow a site-specific health and safety program that

includes the use of personal protective equipment (PPE) to protect from air borne

particulates, arsenic and lead. Due to the potential occurrence of air borne particulates

with contaminants, the health and safety program will assume the use of level C PPE

including a half face (protection factor 10) or full-face air-purifying respirator (protection

factor 50) with PI00 paniculate cartridges. If monitoring indicates that actual exposures

are consistently less than the TWA for all potential contaminants, site workers may

downgrade their PPE to optional use of air purifying respirators.

The use of air purifying respirators will allow site workers to continue to work in

environments that contain contaminants at concentrations exceeding the TWA. Half-face

respirators allow workers to operate in atmospheres containing contaminant

concentrations up to 10 times higher than the TWA. Full-face respirators allows workers

to operate in atmospheres greater than 50 times the TWA.

Peer Engineering, Inc.March 31, 2005 Bloominglon, Minnesota -Page 25-

Worker Monitoring

One worker will be monitored for particulate concentrations within the work area during

all hours of operation. The monitoring will be conducted with aerosol monitors (i.e.,

MIE pdm-3 Miniram) capable of monitoring and recording aerosol concentrations from

0.01 to 100 mg/m3. The aerosol monitors will be carried with the workers or placed onvehicles in use within the work zone in an appropriate position to monitor the air within

the work zone.

The monitors will be set to alarm when the particulate concentrations reach theparticulate TWA (i.e., 1.6 mg/m3). At that point, site workers must take appropriateactions as described below.

Action Criteria

If the total particulate concentration in the work zone exceeds the TWA (1.6 mg/m3), oneor more of the following actions shall be taken:

• Apply water to all accessible drive areas with a water truck.

• Spray water on exposed stockpiles or excavations.

• Cover exposed stockpiles or excavations with plastic or foam.

• Stop work.

If the particulate concentration in the work zone exceeds the concentration allowed by theworker's respirator, all workers with that type of respirator in that vicinity must leave the

work area immediately.

5.0 RESPONSE ACTION IMPLEMENTATION REPORT

A Response Action Implementation Report will be prepared following completion of the

development-related response actions. The report will summarize the response actions

that were completed and will include discussions and documentation that all appropriate

response action and standards have been achieved. The Response Action Implementation

Report will include the following elements at a minimum:

• Overview of response actions completed.

• Photographic documentation of response actions.

Peer Engineering, Inc.March 31, 2005 Bloominglon, Minnesota -Page 26

• Description and documentation of on-site treatment methods employed, equipment

used and general operations.

• Analytical results for final documentation samples (including QA/QC results).

• Excavated soil characterization analytical results.

• Copies of waste disposal manifests and other pertinent disposal documentation.

• Descriptions of health and safety procedures employed.

• Perimeter air monitoring and sampling results.

• Any necessary modifications to the approved RAP.

• Recommendations for any modifications to the institutional controls (e.g. "Affidavit

Concerning Real Property Contaminated with Hazardous Substances" and possibly a"Restrictive Covenant") which are placed on the Property following completion of

the RP-funded Cleanup Actions.

6.0 SITE SAFETY AND HEALTH PLAN

The selected remediation contractor for the project will be required to prepare a SiteHealth and Safety Plan (SSHP) prior to implementation of the approved RAP. The

SSHP will establish the detailed procedures and protocols necessary for the recognition,

evaluation, and control of environmental hazards associated with the remediationactivities. The SSHP will be prepared and signed by a Qualified EnvironmentalProfessional with experience in preparation of such plans. Qualified Environmental

Professional means a person with specific training, knowledge and experience inpreparation and implementation of Site Safety and Health Plans.

The SSHP will include the topics specified by OSHA Standard 29 CFR 1910.120(b)(4)and will include the following at a minimum:

• Procedures and equipment for air quality monitoring to be conducted by the

contractor during completion of the work.

• Training requirements for workers involved with handling and moving contaminated

media. Note: All contractor personnel and individuals who are involved in the

specific handling and moving of contaminated media (including groundwater) shallbe required to meet the training requirements of 29 CFR 1910.120(e).

• Procedures for decontaminating workers and personal protective equipment during

completion of the work.

• Detailed description of procedures to be followed in the event of emergencies.


• Name and qualifications of the designated Site Safety and Health Supervisor. Site

Safety and Health Supervisor means the individual located on a hazardous waste site

who is responsible to the employer and has the authority and knowledge necessary to

implement the site safety and health plan and verify compliance with applicable

safety and health requirements.

A copy of the SSHP will be submitted to the MDA within one week prior to the

contractor mobilizing to the Property.

7.0 SCHEDULE

A schedule will be prepared for implementation of response actions and submitted to the

MDA once the site acquisition date is confirmed and the remediation contractor is

selected.


FIGURES

MAP LOCATION

TAKEN FROM:ST.PAULWEST.MNtMINNEAPOLIS SOUTH, UN7.5 MINUTE SERIESTOPOGRAPHIC MAP1967 (REVISED 1»3)UHTED STATES GEOLOGICAL SURVEY

aOOM2ay625a.5M2M.i3 PromMoallgi MgSKF

SCALE IN MILES0.5

2000 4000SCALE IN FEET

1.0

6000

PROJECT*: 5253.53

PROPERTY LOCATION MAP

HIAAWJHA BUSINESS CENTERFORMER LITE YARD PROPERTY


LN

MARCH 2005

FIGURE

1

APPENDIX A

APPROVED RP-FUNDED RAP DOCUMENT LIST

Appendix AApproved RP-Funded RAP Document List

Lite Yard PropertyMinneapolis, Minnesota

1. RAP for the Property, prepared for CMC Heartland Partners (CMCHP) by Exponent, datedMarch 12, 2004 (the 2004 RAP).

2. Letter to Borax and CMCHP from Teresa McDill with the MDA, dated March 15, 2004,Subject: Approval of the 2004 RAP and Approval of the 2004 GW Modeling Report withcomments (the MDA 2004 RAP and 2004 GW Modeling Report Conditional Approval.

3. Letter to Borax and CMCHP from Karlene A. French-Raschig with the MPCA re: RAPApproval, dated April 13, 2004 with comments (the MPCA 2004 RAP Conditional ApprovalLetter).

4. Letter to Borax and CMCHP from Teresa L. McDill with the MDA, Subject: Final Approvalof the 2004 RAP, including Public Comments, dated April 29, 2004 (the MDA Final 2004RAP Approval Letter w/comments).

5. Response Action Design and Implementation Plan prepared for CMCHP by Peer, dated June21, 2004 (the 2004 RAD/IP).

6. Letter to Borax and CMCHP from Teresa L. McDill with the MDA, Subject: Approval ofthe 2004 RAD/IP with comments and request for additional information, dated July 28, 2004(the 2004 RAD/IP Conditional Approval Letter).

7. Project Manual Response Action Implementation prepared for CMCHP by Peer, datedAugust 23, 2004 (the 2004 Project Manual-Response Action Implementation).

8. Letter to Teresa McDill with the MDA from Peer, dated August 27, 2004, Re: Response tothe 2004 RAD/IP Conditional Approval Letter.

9. Addendum No. 1 to the 2004 Project Manual-Response Action Implementation prepared byPeer, dated September 1, 2004.

10. Addendum No. 2 to the 2004 Project Manual-Response Action Implementation prepared byPeer, dated September 1, 2004.

11. Letter to Robert Anderson with the MDA from Peer, dated December 7, 2004, Re: 2004RAD/IP Addendum, Additional Soil Excavation.

12. Letter to CMCHP and Borax from Robert Anderson with the MDA, dated December 15,2004 Subject: Approval of RAD/IP Addendum for Peer's December 7, 2004 Addendum tothe June 21, 2004 RAD/IP (the 2004 RAD/IP Addendum Approval).

APPENDIX B

PROPOSED DEVELOPMENT PLAN

© Peer Engineering, Inc., 2003 1 of 1

Standard Operating Procedure 110

Field Notes

Purpose

Complete and accurate field notes are essential to the success of both small and large

projects. They allow project managers to reconstruct the exact sequence of events and

manage data efficiently and accurately.

Required Equipment

• Field Report form and other appropriate field forms as necessary

• Tape measure

• Graph paper or photocopy of existing map for site diagram (optional)

Procedures

1. Fill out a Field Report form for each day in the field. Include any significant

correspondence with the client or contractors and a summary of the work completed. Be

sure to get the name and affiliation of all site visitors using correct spelling. Obtain

business cards if possible.

2. Use as much detail as possible when documenting data on the standard forms (e.g. Boring

or Sampling Probe logs, Monitoring Well Sampling Data form, Survey Level Notesform). Details which are not documented in the field can lead to gaps in the final report.

3. Draw a good site map using accurate measurements or revise a photocopy of an existing

site map. A good site map will include:

• Site boundaries (or features such as street curbs, fencelines etc. that can later be

related to site boundaries)

• Street names or other references that can be related to a site location map

• Boring and well locations with dimensions to site landmarks

• Major structures with dimensions

• North arrow

• Scale

January 1,2003 SOP 110


• Date

• Initials of field person

4. When you get back to the office, organize your notes and data. Then place the Field

Report form on top of the rest of your notes and staple them together. If necessary, make

a photocopy of forms that require word processing.

5. Put the stapled field notes into a file folder that is clearly labeled as containing field notes

for the project.


i Peer Engineering, Inc., 2003 1 of 1

Standard Operating Procedure 211Field Soil Classification

Purpose

As soil samples are collected in the field, a visual identification and description will becompleted in accordance with ASTM D2488-93. Logs are later prepared from the fieldnotes, and since soil samples are not commonly sent to a lab for further identification andverification of the field classification, the proper description of soils in the field becomeseven more important.

Required Equipment

• Log form (Boring, Sampling Probe, Trench, etc.) or field notebook.

Procedure

When visually describing soils in the field, the following information should be included(in the order shown):

1. A description of the main soil group within the sample in all capitol letters (e.g., SILTYSAND, CLAY, SILT, etc.).

2. If the soil group is sand or gravel (coarse-grained), include a brief description of theparticle grain size (i.e., fine, medium, coarse).

3. Any other soil group present should be described based on the percentages present withinthe sample (e.g., with few gravel, with trace sand).

4. Describe the color of the main soil group (e.g., brown, gray, etc.).

5. Describe the overall moisture of the soil sample using dry, moist, or wet.

6. Describe the consistency of fine-grained soil (i.e., very soft, soft, firm, hard, very hard).

7. If any unusual occurrences are encountered, information should also be included (e.g.,bricks, glass, petroleum odor present, fill).

Examples

The following are examples of correct visual soil classifications:

• SILTY SAND: fine to medium grained, with few gravel, dark brown, moist.

• SANDY CLAY: with trace silt, gray, wet, soft, petroleum odor.



ASTM Group Symbol

Once a field soil classification is completed, a group symbol (e.g., CL, MH) should beassigned to each soil sample in accordance with ASTM D 2488-93. This group symbolshould be included on the final sampling log.




Organic Vapor Screening

Purpose

Use this procedure to obtain a fast, general measurement of volatile organic

compounds in soil.

Safety Equipment

• Wear nitrile gloves to reduce the incidence of skin contact with potentially

contaminated soil and to reduce the risk of cross-contamination.

• Refer to the site-specific Health and Safety Plan for other safety concerns and

applicable personal protective equipment.

Required Equipment

• Photoionization detector (PID) equipped with a 10.6 or an 11.8 eV lamp (refer to

the site-specific sampling and analysis plan or proposal for proper lamp size)

• PID calibration equipment

• One quart scalable bags, or soil jars, lids and aluminum foil

• Appropriate log forms or note pad for field notes

• Sharpie or permanent marker

Procedure

1. Select a PID equipped with the proper lamp size the afternoon before the field

work is scheduled and charge the battery overnight by plugging in the adapter. As

the PIDs have no battery gauge, failure to recharge the battery may leave you with

a discharged battery and an unusable PID.



2. Calibrate the PID upon arrival at the site or prior to leaving the office. Record allpertinent information on the calibration record located in the case of each PID andrecord the calibration on the Field Report form.

3. With a gloved hand, fill a dedicated scalable bag or soil jar approximately half fullwith soil to be screened. Refer to the site-specific sampling and analysis plan orwork plan for appropriate sample container. Manually break up the soil clumpswithin the bag. Seal the bag, or cover the opening of the soil jar with aluminumfoil and screw on a lid. Use a marker to write the sample identifier and depth onthe bag or jar lid.

4. Shake the sealed bag or soil jar for approximately 15 seconds, then allow the soil

to volatilize for at least 10 minutes in an atmosphere of at least 70°F. On colddays it may be necessary place the bag or soil jar inside a heated room or vehicle.

5. After headspace development, shake the sample for another 15 seconds.

6. Complete organic vapor screening within approximately 20 minutes of samplecollection. If using soil jars, remove the lid. Pierce the aluminum foil or plasticbag with the probe of the PID. Record the highest meter response within a timeperiod of two to five seconds.

7. Discard the soil samples on-site and dispose of used bags, soil jars, foil, and lidsas trash.




Field Measurement of Metals in Soil by XRF Analysis

Purpose

Use the X-Ray Fluorescence (XRF) unit to obtain a fast, general measurement of

lead (and some other metals) in soil samples.

Safety Equipment

• Wear a dedicated pair of nitrile gloves for preparation and analysis of each sample

to reduce the risk of potential cross-contamination and to reduce the incidence of

skin contact with the soil.

• Prior to XRF use, field personnel are required to be certified in the proper use of

the XRF unit and an appropriate radiation exposure monitoring program should be

implemented.

Required Equipment

• XRF unit

• XRF sample cup and ring

• Mylar film

• Soil screen (1/4" mesh or as required by specifications)

• XRF soil screening adapter

• XRF Analysis Data form

• Radiation exposure monitoring ring



Procedurei

1. Ensure XRF sample cups, rings, and soil screens are clean and dry before starting.

2. Screen soil through a soil screen. Try to remove all gravel, soil clumps,vegetation, etc.

3. Fill a soil cup with the screened soil. The soil cup should be rilled completely, but

not packed tightly.

4. If soil is excessively wet it should be dried either by air drying or by an external

heat source, such as a microwave oven. Dry soils yield more accurate results.

5. Place a dedicated sheet of Mylar film over the XRF soil cup rim and snap on a soil

cup ring to secure the Mylar to the soil cup. Be sure to label the soil cup with the

sample designator, or place the sample into a labeled plastic bag.

6. Place your personal radiation exposure monitoring ring on your finger and keep it

on during XRF operation.

7. Turn on the XRF unit and choose the soil bulk analysis mode. When the

appropriate mode has been chosen, select the calibrate and test option on the

screen.

8. When the XRF unit is finished with the calibration and test mode, select andanalyze one of the factory standards using steps 9 and 10. When the analysis is

complete, compare the results to the actual chemical compositions found in

Appendix E of the User's Guide to Measuring Lead in Soil (found in the bulk

analysis protective case). Prior to sample analysis, determine if the XRF unit is

reading the standard within an acceptable range of the actual chemical

composition.

9. Place the soil sample into the XRF soil screening adapter and lock the XRF unit

into place to begin analysis. Soil samples should be screened for at least 60

source seconds; however, longer readings are often necessary for more precise

measurements.


1 Peer Engineering, Inc., 2003 3 of 3

10. Record sample designator, sample result, standard deviation and total source

seconds on the XRF Analysis Data form.

Note: Re-calibrate the XRF at least once every hour during continuous operation.

11. Empty the soil cups and discard the Mylar film.

12. Decontaminate empty soil cups, rings, and screens using an Alconox wash

followed by a clean water rinse. Soil cups, rings and screens must be dried

completely before reusing.




Grid Layout

Purpose

To accurate divide an area of investigation into smaller, equal-sized areas that can

be sampled individually.

Required Equipment

• Two people are commonly required to lay out a grid system

• Map or site diagram indicating the location of the intended grid area, the grid

spacing and identification of grid axis.

• Stakes with hammer and/or wire flags and/or marking paint

• Permanent marker

• Survey gear (tripod and survey level or hand level)

• 200 or 300 foot tape measure

Procedure (see figure on Page 3 of this SOP)

1. If not previously selected, choose an origin for the grid. A right-angle corner of abuilding or fence makes an excellent origin for a grid. Ideally the origin will be

located at the southwest corner of the intended grid area allowing axis identifiers

to increase from west to east and from south to north. However, the origin can be

placed anywhere, as necessary, with grid lines extending in cardinal directions (or

some other applicable directions) from the origin. If necessary, place a stake or

flag at the origin.

2. Lay out one axis (line) of the grid system to the extent possible. Use a tape

measure to set a stake or wire flag along the axis at equal distances from the origin

or previous stake as defined by the grid spacing. If necessary, use the survey level

or hand level to place each stake in a straight line along the axis.

August 13, 2003 SOP 214


3. Begin another axis perpendicular to the original axis. Use the tape measure todetermine the locations of points on the perpendicular axis and use the surveylevel to ensure they are on a straight line at a 90 degree angle from the originalaxis.

4. Repeat step 3 with another axis perpendicular to the original axis approximately200 to 300 feet along the original axis.

5. Once set, measure the distance from the two end points set in step 3 and step 4 toensure they are correct. The points should be within 1 foot of the expectedmeasurement. If not, determine the reason for the error and correct the stakelocations as appropriate.

6. Use the tape measure to fill in intermediate axis locations at appropriate gridspacing along the axis' laid out in steps 2, 3 and 4. Mark each axis location with astake or flag with the appropriate identifier (x and y axis).

7. Continue the grid as necessary in all directions to completely cover theinvestigation area.

August 13,2003 SOP 214



Collecting Soil Samples for Laboratory Analysis

Purpose

Use this procedure to collect soil or other solid media samples for laboratory

analysis. Proper sample collection technique will improve the accuracy of results

and will help avoid cross contamination.

Safety Equipment

• Wear nitrile gloves to reduce the incidence of skin contact with potentially

contaminated soil and to reduce the risk of cross-contamination.



Required Equipment

• Laboratory sample containers

• Clean cooler(s)

• Temperature blank bottle

• Trip blank for VOC sampling (SOP 327)

• Ice or frozen cold-packs

• Electronic scale

• Permanent marker

• Scalable bags

• Plastic syringe with end cut off (EPA CRL/CLP samples only)

• Methanol Preservation Record form (EPA CRL/CLP volatile samples only)

• Laboratory chain-of-custody form

February 4, 2005 SOP 215


Procedure

1. Several days before field work is scheduled to begin, call or FAX the laboratory or

other lab supply source to order sample containers. Be sure to order extra bottles

to allow for breakage, extra samples, etc. If you are unsure of the required sample

volumes or proper laboratory sample containers for specific analytical parameters,

ask that a written description be included with the bottle order which clarifies

sample requirements.

2. Before you leave for the field, be sure that you have the appropriate sample

containers and that extra containers are included. Be sure you are aware of

sample volume and container requirements.

3. Place ice or a frozen cold pack into each sample cooler before collecting any

samples. Double-bag the ice in scalable gallon bags to avoid potential contact of

water in the cooler with sample containers.

4. Place a temperature blank into each cooler and under the ice.

5. If some samples may be analyzed for GRO, BETX, or VOCs include a trip blank

in each cooler as described in SOP 327.

6. Before taking a sample, put on a new pair of nitrile gloves.

7. Samples taken for volatile organic analysis are to be taken immediately after the

soil is exposed (i.e., directly from the split spoon, excavation side wall, hand

auger, etc.). Samples for DRO are to be collected second and samples for non-VOC or non-DRO analysis are taken last.

Standard Sampling

a. Prior to sample collection the scale must be verified to read a mass of greater

than 50 grams within one gram of the expected result. Place a weight of

known mass (calibration mass or pre-weighed bottle) on the scale and verify

the reading. If the reading is within one gram of the expected result the scale

is usable. Record the weight verification on the Field Log. If the reading is

more than one gram from the expected weight the scale must be re-calibrated

(see SOP 218 if applicable) or a scale that is verified to be correct must be

used.



b. Samples collected for GRO, BTEX, or VOCs need to be placed into one pre-

weighed glass container containing the preservative methanol and one plastic

vial (if necessary). Place one empty glass container on the scale and zero the

scale. Carefully add approximately 25 grams of soil to the jar. Sample

containers with more than 35 grams of soil or less than 20 grams of soil may

be rejected or flagged as outside testing parameters by the laboratory. In

addition, if there is no non-volatile analysis, fill a plastic vial with soil to be

used to by the lab to calculate the moisture content of the soil. The soil in the

plastic vial need not be weighed.

c. Samples collected for DRO need to be placed in two pre-weighed glass

containers with no methanol and one plastic vial (if necessary), using the

procedure described in step b, above.

d. Samples for non-volatile analysis (i.e., metals, PCBs, pesticides, semi-VOCs,

etc.) are to be thoroughly mixed prior to sampling. Place the sample in a

resealable plastic bag and shake the bag for at least 10 seconds. Sample

containers should be filled, but not packed, with soil from the bag.

EPA CLP/CRL Program Samples

a. Prior to sample collection the scale must be verified to read a mass of greater

than 50 grams within one gram of the expected result. Place a weight of

known mass (calibration mass or pre-weighed bottle) on the scale and verify

the reading. If the reading is within one gram of the expected result the scale

is usable. Record the weight verification on the Field Log. If the reading is

more than one gram from the expected weight the scale must be re-calibrated

(see SOP 218 if applicable) or a scale that is verified to be correct must be

used.

b. Samples collected for GRO, BTEX, or VOCs need to have 10 grams of soil

(weights between 9 and 12 grams are acceptable). They will be preserved

with a laboratory-prepared vial containing 10 grams (10 ml) of methanol

(MeOH).

i) Verify that the methanol vial still contains 10 grams of methanol.

Place the pre-weighed vial containing methanol on the scale. If the weight of

the methanol is not 10 grams, discard the methanol vial and use another.

ii) Tare an empty syringe on the field balance.


> Peer Engineering, Inc., 2005 4 of 4

iii) Use the tarred syringe to collect a 10 gram sample of soil, as confirmed

by weighing the filled syringe.

iv) Place an empty sample bottle on the field balance. Record the weight

of the bottle on the Methanol Preservation Record.

v) Empty the vial of methanol into the sample bottle. Record the weight

of the bottle and methanol on the Methanol Preservation Record.

vi) Extrude the soil from the syringe into the bottle. Record the weight of

the bottle, methanol, and soil on the Methanol Preservation Record.

vii) In addition, if there is no non-volatile analysis, fill a plastic vial with

soil to be used to by the lab to calculate the moisture content of the soil. The

soil in the plastic vial need not be weighed.

c. Samples for non-volatile analysis (i.e., metals, PCBs, pesticides, semi-VOCs,

etc.) are to be thoroughly mixed prior to sampling. Place the sample in a

resealable plastic bag and shake the bag for at least 10 seconds. Samplecontainers should be filled by hand, but not packed, with soil from the bag.

7. Before placing the lid back on the sample container, clean the jar threads to assure

a tight seal.

8. After collecting soil samples, use a permanent marker to label the sample

containers with the project name, sample identifier including depth interval, time,

date, and your initials.

9. Place the filled sample containers for each location in their own scalable bag.

Larger, more fragile containers should be placed in bubble wrap to avoid

breakage. Place the sample containers and bags into the cooler immediately.

Cover all samples with ice.

10. When all samples are collected, complete the laboratory chain-of-custody form

and arrange for shipment to the contract laboratory (as described by SOP 620 -

Chain of Custody Procedures, SOP 630 - Sample Shipping - Peer or Local

Carrier, and SOP 640 - Sample Shipping - Overnight Carrier).




Calibration and Verification of a Thermo Environmental Model 580B PID

Purpose

1. Use this procedure to systematically set the output response of the

photoionization detector (PID) to a benzene standard.

2. Use the procedure (starting at step 16) to verify that the response of the PID

matches the actual concentration of the calibration gas.

Safety Equipment



Required Equipment

• Thermo Environmental Instruments, Inc. model 580B photoionization detector

(PID) equipped with a 10.6 or an 11.8 eV lamp (refer to the site-specific sampling

and analysis plan or proposal for proper lamp size)

• 100 ppm or 250 ppm isobutylene gas cylinder, associated flow regulator, and poly

tubing assembly to connect the gas cylinder to the PID

• Photoionization Detector Calibration Record

Procedure

Calibration and verification of the PID is best completed at the job site, however

calibration in the office on the day of the work is acceptable.

1. Check the Calibration Record to determine if the appropriate lamp is installed. If

not, change the lamp.

2. Check the ceramic filter at the front of the instrument (if present) and the moisture

filter in the probe wand. If either filter is dirty, replace with new a filter. Check

for dirt in the probe, if it is dirty, clean it and dry it as well as possible.



3. Screw on the probe tip assembly.

4. Push the shorting plug into the back of the instrument and turn the instrument on.

5. Push the MODE/STORE button once. Push the "-" button 5 times to check that

the response factor is 0.65, change if necessary. Push the "-" bottom one more

time to check that the lamp setting (10.6 or 11.8) matches the calibration record,

change if necessary.

6. Push MODE/STORE twice.

7. Push the "-" button 4 times; Screen says "RESET TO CALIBRATE".

8. Push RESET.

9. Push the "-" button; Screen says "ZERO GAS, RESET WHEN READY".

10. Push RESET (make sure PID is in "zero" air).

11. When "Zeroed" screen says 'SPAN PPM = ONNN, "+" TO CONTINUE'.

CHECK calibration gas concentration (250 or 100), push RESET to change if

necessary.

12. Push (+); Screen says "SPAN GAS - RESET WHEN READY".

13. Attach the gas source to the probe with the poly tubing and completely open the

valve on the calibration gas; push RESET.

14. When the instrument has completed its automatic calibration the screen displays"RESET TO CALIBRATE".

15. Push MODE/STORE.

16. Calibration Verification. Close the valve on the calibration gas and check to make

sure the instrument reading returns to 0. With the gas source attached to the PID

with the poly tubing, open the valve on the calibration gas and check to make sure

the instrument reading equals the calibration gas concentration multiplied by the

response factor (e.g., 100 ppm x 0.65 = 65 ppm). If the zero air or calibration gas

reading varies more the 2 ppm from the expected reading, repeat the calibration

starting at step 7.

17. Close the calibration gas valve and disconnect the gas source.


Peer Engineering, Inc., 2003 3 of 3

18. Record the date and time of the calibration or verification on the Calibration

Record sheet along with the test status.

19. If the calibration does not complete normally, or if the instrument will not produce

the expected reading during the calibration verification, note the failure and

attempted remedy on the Calibration Record. After attempting a remedy, repeat

the calibration from Step #1.

January 1, 2003 SOP 216


Standard Operating Procedure 221Soil Sampling - Hand Tools

Purpose

Use hand tools to collect soil samples near the ground surface for field screening andlaboratory analysis.

Safety Equipment

Wear a dedicated pair of nitrile gloves at each sample location to reduce the risk ofpotential cross-contamination between samples and to reduce the incidence of skincontact with the soil.

Required Equipment

• Measuring tape

• Metal shovel, hand spade, or post hole digger

• Rock hammer or pick (optional)

• Alconox, clean water, brush, and two 5-gallon buckets

• Note pad for field notes

Procedure

1. Ensure all field equipment is clean before starting.

2. Determine the appropriate location and identification prior to sampling. Use a tape measureto determine the distance (within 1 foot) from site landmarks. Identify the sample locationwith the letter "H" (or other specified identifier) followed by a number unique to the site.Begin with number 1 and sequentially assign numbers for all sample locations at the site.

3. If necessary, use a rock hammer or pick to loosen hard soil at the sample location.

4. Insert a metal shovel, spade, or post hole digger to the appropriate sampling depth at thedesignated location to obtain a representative soil sample. Withdraw the tool and soil.

5. Use a gloved hand to transfer the soil from near the tip of the tool directly into a samplecontainer as described in SOP 215 - Collecting Soil Samples for Laboratory Analysis.

6. Record the sample identifier, depth, and time of sample collection on the samplecontainer. Examples of properly labeled samples are: H-l (6") or H-2 (1-2'). Recordpertinent information about the sample location and sample content in the field notes.



7. Decontaminate the shovel or spade between sample locations using a brush in a detergentand water wash, followed by a clean water rinse. Discard gloves and use new gloves forthe next sample location.



Standard Operating Procedure 223Soil Sampling - Sampling Probe

Purpose

Use a sampling probe to collect soil samples for field screening and laboratory analysis.

Safety Equipment

• Steel-toed boots

• Ear plugs (recommended)

• Wear a dedicated pair of nitrile gloves for each sample to reduce the risk of potentialcross-contamination between samples and to reduce the incidence of skin contact withthe soil.

Required Equipment

• Measuring tape

• Sampling Probe Log forms

Procedure


2. Determine the appropriate sample location and identification prior to sampling. Use atape measure to determine the distance (within 1 foot) from site landmarks. Identify thesampling probe location with the letters "SP-" (or other specified identifier) followed bya number unique to that site. Begin with number 1 and sequentially assign numbers forall sampling probes advanced at the site.

3. Advance the probe to the desired sampling depth.

4. A sampling probe is driven into the soil by a hydraulic hammer and ram. The lengthand inside diameter of the sampler used is determined by the sampling depths orintervals desired. The standard sampler has a length of either two feet (1 inchdiameter) or four feet (2 inch diameter).

5. The probe operator will bring the sampler to the surface and remove the inner plastictube. Record the length (in feet) of sample recovery (length of soil column) in thetube.

6. Have the probe operator cut the tube open lengthwise for sample removal. Use agloved hand to transfer the soil from the tube directly into a sample container as



described in SOP 215 - Collecting Soil Samples for Laboratory Analysis. If there is asoil change within the tube, a sample should be taken of each stratum and note itslocation in your notes.

7. Record the sample identifier, depth, and time of sample collection on the samplecontainer. Examples of properly labeled samples are: SP-1 (6") or SP-2 (8-10').Record pertinent information about the sample location and write a description of thesoil samples recovered in Sampling Probe Log form using SOP 211 - SoilClassification.

8. The probe operator will decontaminate the sampler between samples to minimizecross contamination using a brush in a detergent and water wash, followed by a cleanwater rinse. A new plastic tube is used for each sample.

9. Discard gloves and use new gloves for the next sample interval.



Standard Operating Procedure 224Soil Sampling - Split Barrel Sampling

Purpose

Use a drill rig and split barrel (spoon) sampler to collect soil samples for field screeningand laboratory analysis.

Safety Equipment

• Hard hat

• Steel-toed boots

• Ear plugs (recommended)

• Wear a dedicated pair of nitrile gloves for each split spoon sample to reduce the risk ofpotential cross-contamination between samples and to reduce the incidence of skincontact with the soil.

Required Equipment

• Measuring tape

• Boring Log forms

Procedure


2. Determine the appropriate location and identification prior to sampling. Use a measuringtape to determine the distance (within 1 foot) from site landmarks. Identify the boringlocation with the letters "SB-" (or other specified identifier) followed by a number unique tothat site. Begin with number 1 and sequentially assign numbers for all soil boringsadvanced at the site.

3. Advance the boring to the desired sampling depth.

4. Bring the sampler to the surface and open. Record the length (in feet) of sample recoveryin the split-spoon, and write a description of the soil samples recovered in the Boring Logform as described in SOP 211 - Soil Classification.

5. Use a gloved hand to transfer the soil from the sampler directly into a sample container asdescribed in SOP 215 - Collecting Soil Samples for Laboratory Analysis. If there is asoil change within the sampler, a sample should be taken of each stratum and note itslocation in your notes.



6. Record the sample identifier, depth, and time of sample collection on the samplecontainer. Examples of properly identified samples are: SB-1 (6") or SB-2 (6-8'). Recordpertinent information about the sample location and sample content in the Boring Logform.

7. The drill rig operator will decontaminate the split barrel sampler between samples tominimize cross contamination using a brush in a detergent and water wash, followed by aclean water rinse.

8. Discard gloves and use new gloves for the next sample interval.




Soil Stockpile Sampling

Purpose

The purpose of a stockpile sample is to characterize the content of a potentially

contaminated soil stockpile.

Safety Equipment

• Wear nitrile gloves to reduce the incidence of skin contact with contaminated soil

and to reduce the risk of cross contamination.

• Consult the site-specific Health and Safety Plan for appropriate personal

protective equipment.

Required Equipment

• Soil cup(s)

• One-gallon scalable bag or stainless steel bowl and aluminum foil

• Note pad for field notes

• Wood stake or wire flag and permanent marker

• Laboratory sample containers and clean cooler with ice

Procedure

1. Determine the appropriate sample identification prior to sampling. Label a wood

stake or wire flag with the sample number and leave it in the pile; this will reducepotential confusion when it comes time to move the stockpile.

2. Determine the appropriate number of composite samples needed to adequately

define the stockpile and the number of equal volume samples (i.e., aliquots)

needed to make up each composite sample. This information as well as



information regarding required analysis should be written in the proposal or site-

specific work plan.

3. Try to select sample locations in a random fashion to collect an unbiased,

representative sample.

4. Scrape off the exposed surface or dig in a few inches to get a fresh surface to

sample.

5. Use a soil cup to measure an equal volume of soil for each aliquot location. If

volatile organic analyses are required be sure to get soil that has not been exposed

to the air. Mark each sample location on a map and/or mark each location with a

flag. If "surprising" analytical results are discovered this will aid in potential

segregation of more contaminated parts of the pile.

6. If only inorganic analyses are to be completed, place all aliquots into a gallon-

sized scalable bag. If semi-volatile or DRO analyses are required, place the

aliquots in a clean stainless steel bowl lined with aluminum foil. After all aliquots

have been placed into the bag or bowl, mix the soil. Proper and complete mixing

is essential when taking a composite sample; it will ensure that all aliquots are

represented equally in the final analysis.

7. Fill appropriately labeled laboratory sample containers with the composited soil

using a gloved hand as described in SOP 215 - Collecting Soil Samples for

Laboratory Analysis.



Standard Operating Procedure 610Sample Preservation

Purpose

Sample preservation techniques are intended to prevent substantial alteration of thechemical species present in the sample at the moment it was collected.

Required Equipment

• Clean cooler with temperature blank bottle

• Ice or frozen cold packs

• Sample containers with media

Procedure

1. Immediately after media collection, all sample containers will be placed in a clean coolerunder ice, to thermally preserve the samples. The cooler must also contain a temperatureblank bottle, also kept under the ice.

2. The sample containers will be kept in an environment that is between 0° and 4° Celsiusuntil the laboratory receives the samples. The sample custodian must ensure that someice remains in the cooler and that excess water from melted ice is drained.

3. In addition, chemical preservatives may be added to individual samples depending on theanalytical methods required. In general, the laboratory will supply pre-preserved samplecontainers for the project and only laboratory-grade preservatives will be used.




Chain of Custody Procedures

Purpose

The purpose of following chain of custody procedures is to maintain the quality of allsamples during collection, transportation, and storage prior to analysis. Chain of custodydocumentation serves three main purposes:

1. Communication of analytical instructions from Peer to the analytical laboratory.2. Permanent record of samples provided to the laboratory.

3. Documentation that samples were handled only by authorized personnel and were not

available for tampering prior to analysis.

Procedure

Field personnel will complete sample labels and chain of custody forms to be used fortracking samples.

Sample Container Labels

1. Each sample will be assigned a unique identification number that will be affixed to alabel on the sample container.

2. Additional information such as sampling location, date and time of collection, andperson who collected the sample will also be included on the sample labels.

3. Labeled sample containers, a temperature blank bottle, and ice will be included ineach cooler to be shipped to the laboratory.

Chain of Custody Form(s)

If multiple coolers are required to contain all samples from one sampling location, a

separate chain of custody form will be prepared for each cooler. At a minimum, thechain of custody form will include the following information:

• Client or project name, or unique identifier, if confidential

• Sample collector's name and signature

• Peer's mailing address and phone number

• Name of project manager or person who will receive data

• Analytical laboratory's name and city

October 27, 2003 SOP 620


• Description of each sample including

- Unique identifier and matrix (solid, aqueous, etc.)

- Date and time of collection

- Type of analysis required

• Temperature blank listed as a sample

• Dated and timed signatures of persons involved in chain of possession

• Date and method of shipment

Completion of Field Personnel Responsibility

Record all pertinent information about the samples on the field sampling forms or in thefield logbook. Upon completion of the chain of custody forms, field personnel will signthe chain of custody forms along with the date and time.

If the field personnel will transfer the custody of the samples to someone other than the

laboratory, affix a custody tape to the cooler to prevent the lid from opening. Write the

time, date, and initials on the custody tape.

Sample Custody

Each time the custody of a sample or group of samples is transferred, a signature, date,

and time will be entered onto the chain of custody form. A sample will be considered tobe in custody if it is in any one of the following states:

1. In actual physical possession

2. In view, after being in physical possession3. In physical possession and locked up so that no one can tamper with it

4. In a secured area such as a locked storage shed or locked vehicle, restricted to

authorized personnel

NOTE: While samples are in an individual's custody, they are to ensure that the

cooler containing the samples has ice or a frozen cold pack.

October 27, 2003 SOP 620

APPENDIX C

SOIL DISPOSITION FLOW CHART

APPENDIX D

FIELD METHODS AND PROCEDURES

PROPOSED STORM-WATER POND

OFFICE/WAREHOUSERD-10A -n ,nn ocE-W6.ee 60,300 SF

•O. IW MHRE- 843.82EX. dW)-

ZONING DISTR.CT nZONING DISTRICT 11

PROPOSED DEVELOPMENT PLAN

Engineering HIAWATHA BUSINESS CENTERFORMER LITE YARD PROPERTY


50 100

5253.53 RAD figures.DWG PROJECT #: 5253.53

APPENDIX CSOIL DISPOSITION FLOW CHARTHIAWATHA BUSINESS CENTER

Soil removed for development.

Soil within four feet of planneddevelopment grades.

Soil below four feet of planneddevelopment grades.

Excavate and stockpile withoutengineering controls. Does soilmeet geotechnical reuse criteria?

Reuse on-site asunrestricted fill.

Excavate, stockpile with engineeringcontrols, and"sample. Does soil meet

TCLP disposal criteria?

Dispose off-site as daily cover orindustrial waste per existing

analytical data.

Does soil meetenvironmental andgeotechnical reuse

criteria?

YES

Does soil meetunrestricted reuse

criteria?

Reuse on-site asunrestricted fill.

Stabilize and re-sample.Does soil meet TCLPdisposal requirement?

Dispose as industrialwaste.

Dispose as industrialwaste or daily cover.

Reuse on-site, below four feetof final development grade.

MONITORING WELL(TO BE ABANDONEDSPRING 2005)

PROPERTY BOUNDARY

ZONING DISTRICT 11

SITE DIAGRAM



0 50 100


NOTE: FIGURE MODIFIED FROMFIGURE 2 OF "FOCUSED FEASIBILITYSTUDY-SOIL", OCTOBER 3, 2003.

APPROXIMATESITE

BOUNDARY

/ ROLLINS OILCOMPANY

(2008 AND 2020EAST 28TH STREET)

/ FORMERBUILDING

(2000 EAST 28TH STREET)

FORMER OILWAREHOUSE

READE MANUFACTURING // BORAX FACILITY

FORMEDBUILDING(2100EASY8TH STREET)

East 28th Street

SCALE IN FEET

50 100

LEGEND

FORMER AST

V)(D

1oCN

Engineering

PROJECT* 5253.53

O)0)

iCN

HISTORICAL LAND USE

HIAWATHA BUSINESS CENTERFORMER LITE YARD PROPERTY


MARCH 2005

FIGURE

3

EGEND

RE-638.<5(4S' DIA. GRATE)OUTLET CONTROL STRUCTURE4' VERT. ORIFICE IE-635.0012' VERT. ORIFICE IE-836.55

HATCH INDICATESPROPOSEDEXCAVATION AREAS

MH-IIE-8J4.78(TAP INTO EXISTING STRUCTURE)

PROPOSED STORM-WATER POND

PROPERTY BOUNDARY

HYDRANTW/ 6' VALVE

ir-6' DIP

08UH-7RE-840.98

IE(S)-836.61IE(N4E)-835,89

HYDRANTW/ 8" VALVE

WP

OFFICE/WAREHOUSERD-10A cn nnn Cf-IE-836.68 60,300 SF5'-12" RCP O 0.25X

HYDRANT/ 6" VALVEia-e' rap

CBMH-16RIM-840.70E(W)-8M.85IE(N -8J6.+5

8-X8- TEE-' /S--22 1/2' BEND-/

East 28th Street.

SAN MHRE- BU.82EX. IE(W)- B30.40(TWN 10' rap)

ZONING DISTRICT 11

PROPOSED EXCAVATION AREAS



50 100


SED STORPOND

///////7777777777777777

EGEND PROPOSED SAMPLE LOCATIONS



MONIJORING WE(TO BE ABANDON

-$• SPRING OF 2005)

MONITORING WELL$-(TO BEABANDONEDSPRINfc 2005)

PROPERTY BOUNDARY

EAST 28TH ST. RIGHT-OF-WAY

East 28th Street

ZONING DISTRICT 11 ZONING DISTRICT 11

PERIMETER AIR MONITORINGLOCATIONSEGEND



* AIR MONITORING LOCATION50 100

5253.53 RAD figures.DWG

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