ITRCC No 8 Travel Plaza Site Assessment Study

DRAFT NO. 8 TRAVEL PLAZA (MM148)

SITE ASSESSMENT STUDY

PREPARED BY TROYER GROUP FOR THE INDIANA TOLL ROAD CONCESSION COMPANY, LLC MAY 2020

TRAVEL PLAZA NO. 8 SITE ASSESSMENT STUDY

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N 125 E SR 120

N 1235 E

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No. 8 Travel Plaza

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TRAVEL PLAZA NO. 8 SITE ASSESSMENT STUDY

Introduction Overview Project Location Maps Existing Conditions and Project Data Project Area Aerial Map Key Project Area Photos Existing Conditions Maps Site Development Summary Red Flad Investigation Quarterly Monitoring Reports Summary Site Assessment Summary Appendices A - INDOT Mini Scope B - NE Site – NFA Letter C - NE Site – Quarterly Monitoring Report Q1 2019 D - SW Site – ERC Termination – March 2016

CONTENTS

Appendix Appendix Appendix Appendix

TRAVEL PLAZA NO. 8 SITE ASSESSMENT STUDY

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MICHIGAN INDIANA

INDIANA TOLL ROAD

PROJECT LOCATION

FORMER TRAVEL PLAZA NO. 8 (MM148)

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PROJECT LOCATION STEUBEN COUNTY

INDIANA OHIO

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The former No.8 Travel Plaza near mile marker 148 is an approximately 46.69 acres parcel, situated on either side of the 80/90 Toll Road expressway, near the Town of Freemont, Indiana. The site is accessible from State Route 120 and split into northeast and southwest assessment areas. As a travel plaza, the site formerly housed public facilities including restrooms, dining, convenience stores, as well as gas station amenities and the site featured large paved areas, which remain.

N 1235 E

INTRODUCTION

OVERVIEW

The former Travel Plaza No.8 primarily features impervious surface, after the key amenities were demolished.

Building on previous studies prepared for the Indiana Finance Authority (IFA) regarding Indiana Department of Environmental Management (IDEM) Leaking Underground Storage Tank (LUST) report, this site assessment summary is specifically aimed at determining any future testing and laboratory requirements as well as Institutional Controls including use restrictions. The most recent LUST incident report filed in 2016 led to several quarterly monitoring reports. These noted that in early 2016, several large underground storage tanks and associated piping were removed from the site as well as the disposal of 3,304 tons of petroleum-impacted soil. We have reviewed the site and the recent remediation actions with the Indiana Brownfields Program. Additionally, we included several available context maps from the US Department of Agriculture’s Soil Survey, the available Steuben County GIS maps, and drone

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photography. This information supplements the monitoring reports, while helping understand the site’s role in the surrounding environmental and land-use ecosystem.

We understand that the Indiana Toll Road Concession Company (ITRCC) is interested in developing a Community Education Center with the potential for greenhouses and other public amenities for the former No.8 Travel Plaza. After reviewing the available information, this will be a compliant course of action, though as this plan moves forward, compliance with the Indiana Brownfields Program will be paramount.

TRAVEL PLAZA NO. 8 SITE ASSESSMENT STUDY

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EXISTING CONDITIONS + PROJECT DATA

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EXISTING CONDITIONS PHOTOS The following drone photographs were taken in early April to confirm existing conditions of the former travel plaza and the adjacent context.

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EXISTING CONDITIONS PHOTOS INDIANA TOLL ROAD

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The following drone photographs were taken in early April to confirm existing conditions of the former travel plaza and the adjacent context.

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TRAVEL PLAZA NO. 8 SITE ASSESSMENT STUDY

FORMER TRAVEL PLAZA NO. 8 PROPERTY LIMITS

TOWN OF FREMONT

CRANE MARSH

VISTULA PARK

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8 TRAVEL PLAZA NO. 8 SITE ASSESSMENT STUDY

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EXISTING CONDITIONS PHOTOS

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EXISTING CONDITIONS: PARCEL MAP

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EXISTING CONDITIONS: AREA MAP

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N There are 11 total parcels adjacent to the former Travel Plaza No. 8 site, with most zoned either A residential or GB general business based on the Town of Fremont zoning maps.

N Total Site Acreage: 46.69 acres Total Impervious Surface (Concrete) Area: • #1 Total Area (SE parcel) : 403,095 sq. ft. or 9.25 acres • #2 Total Area (NE parcel) : 407,215 sq. ft. or 9.35 acres

TRAVEL PLAZA NO. 8 SITE ASSESSMENT STUDY

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EXISTING CONDITIONS HYDROLOGY MAP

DRAIN TILE

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CRANE MARSH

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TRAVEL PLAZA NO. 8 SITE ASSESSMENT STUDY

EXISTING CONDITIONS SOILS MAP

N According to the US Department of Agriculture (USDA) Soil Survey, the site is primarily Ud—Udorthents or loamy soils.

Purdue University horticulture notes that loam is a mixture of soil that is ideal plant-growing medium as it holds moisture, but drains well, and provides sufficient air flow for plant root development. It is a combination soil, normally equal parts of clay, silt, and sand (by weight), which gives the benefits of each with few of the disadvantages.

Regional hydrology mapping provided by the Steuben County GIS website, shows several key features located around the former Travel Plaza No. 8, including the nearby Crane Marsh (pictured on the previous page) and a drain tile in the NE area of the campus, that connects to the surrounding drainage system. These systems will be important considerations if future development or demolition occurs as part of the site master plan.

The USDA Soil Survey included the following data as part of its initial report: • • • • • • • • • • • • • • • •

Elevation: 600 to 1,150 feet Mean annual precipitation: 34 to 40 inches Mean annual air temperature: 47 to 52 degrees F Frost-free period: 140 to 185 days Farmland classification: Not prime farmland Udorthents and similar soils: 100 percent Slope: 0 to 12 percent Depth to restrictive feature: More than 80 inches Natural drainage class: Moderately well drained Depth to water table: More than 80 inches Frequency of flooding: None Frequency of ponding: None Land capability classification (irrigated): None specified Land capability classification (nonirrigated): 8 Other vegetative classification: Trees/Timber (Woody Vegetation) Hydric soil rating: No

TRAVEL PLAZA NO. 8 SITE ASSESSMENT STUDY

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HISTORIC AERIAL PHOTOS

1999

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Present

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SITE DEVEOPMENT HISTORY From 1955 to October 2015, the site served as a Travel Plaza associated with the interstate I-80/90, referred to as the Indiana Toll Road. The travel plaza included a fueling station and main building that housed several restaurants, travel/ souvenir shops, and public restrooms. According to the Quarterly Monitoring Reports, the site does not appear to have been developed prior to the mid-1950s, which is when the Interstate Highway system was developed in the United States.

2010

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Numerous reports are available for the site via IDEM’s website.

Available documentation includes an Underground Storage Tank (UST) Closure Report (detailing the UST upgrade/piping replacement activities), an Initial Site Characterization Report, a Further Site Investigation Report, Corrective Action Plan, Quarterly Corrective Action Progress Reports, and a No Further Action Determination (NFA). The summaries of the Quarterly Monitoring Reports as well as the most recent NFA letter are provided in the Appendix to this report.

According to those available documents, the USTs currently located at the Site were installed in 1984. There have been no apparent UST closures at the Site. The USTs were upgraded and the piping was replaced in 2002. The USTs located at the site as well as associated infrastructure were previously removed (including contaminated soil) prior to the recent monitoring with the IFA and Indiana Brownfield Program.

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The graphic above, from the 2019 Q1 Monitoring Report (QMR) on IDEM Incident No. 201603519, shows the location of 11 monitoring wells situated on the Northeast portion of the Travel Plaza No. 8, along the Westbound I-80/90 Toll Road.

Three (3) shallow wells and eight (8) deep aquifer wells were utilized to track groundwater with “residential groundwater screening levels” clean-up criteria. This QMR was the last of eight (8) continuous quarterly sampling events.

NE - Site History Summary:

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As noted in the QMR, the product lines from the UST system was replaced in 2002. A significant volume of petroleumimpacted soil was also removed as part of the system upgrade in 2002. Petroleum impacted soil was removed in 2002 and transported off-site for disposal. A remediation system was operational at the site, but has been abandoned and partially removed. Quarterly groundwater monitoring activities from March 2015 identified dissolved-phase petroleum constituents in three (3) of the thirteen (13) permanent groundwater wells located on the Site. The wells have since been abandoned and the Site was assigned a No Further Action designation.

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The graphic above, from the 2019 Q2 Monitoring Report (QMR) on IDEM Incident No. 201603519 and 201603511, shows the location of 8 monitoring wells situated on the Southwest portion of the Travel Plaza No. 8, along the Eastbound I-80/90 Toll Road. Two (2) soil boring/temporary wells were also utilized to track groundwater with “residential groundwater screening levels” clean-up criteria. This QMR was the last of the continuous quarterly sampling events.

SW - Site History Summary:

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The Site is located on the south side of Interstate 80/90 and currently consists of large impervious surface area after much of the Travel Plaza infrastructure was removed.

A Site Plan and Boring Location Map (see above) identifies former Travel Plaza features identified during the UST closure activities on the site in March 2016. Following the closure of the UST systems located on the Site, the Site buildings and features were razed, access to the site was eliminated from eastbound I-80/90, and the Site has been left vacant.

Currently, there are no permanent structures or utilities, except buried electrical lines for lighting, located on the site.

Long term, re-wilding or phytoremediation through native vegetation is intended for both the northeast and southwest portions of the campus.

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TRAVEL PLAZA NO. 8 SITE ASSESSMENT STUDY

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SITE ASSESSMENT SUMMARY: At this time, no future testing and laboratory work is needed, such as a formal Comprehensive Environmental Response Phase I or Phase II. There is enough known about the existing conditions that more testing is not warranted. The northeast site has ceased monitoring and a No Further Action (NFA) letter was issued (refer to the appendix). The south site is still under monitoring, but it is anticipated to be completed soon, at which time an NFA letter will be issued. Each NFA letter will likely recommend the establish of Environmental Restrictive Covenants (ERCs) that will limit site development activities.

This is managed through the Office of Land Quality as part of IDEM.

Moving forward, the Indiana Brownfield Program will be an important stakeholder in the development of a site master plan. They are both a willing resource and helpful authority as site redevelopment plans are created, particularly in determining what special accommodations may be necessary as a direction of that plan is determined.

Indiana Brownfield Program representative importantly noted that the only major restriction upon site development will be to prohibit any residences. However, some excavation specifications may also be necessary such as capping the site with 2 ft. of clean fill or removing contaminated soil to be replace with clean fill. This would not be necessary site-wide, but only where site activities occur atop contamination zones.

The primary lingering concern is related to contaminated groundwater. The site is not serviced by a municipal water utility, and therefore must utilize a below-ground water wells for water service. If future site activities require on-site water, this may require installation of a new water well that is located away from the contaminated plumes and/or is dug to a depth below the contaminated groundwater.

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APPENDICIES

Appendix A - Quarterly Monitoring Summaries Appendix B - NE Site – NFA Letter Appendix C - SW Site – ERC Termination Letter – March 2016

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NE (Northeast) - Site History Timeline 2017 - Q2

Conclusion: Eleven (11) permanent groundwater monitoring wells were installed at the Site, three (3) screened within the shallow aquifer and eight (8) screened within the deep aquifer. Groundwater flow direction and gradient was determined for the shallow and deep aquifers using data collected during the April 2017 groundwater sampling event. The apparent direction of groundwater flow within the shallow aquifer is N43oW and the apparent direction of groundwater flow in the deep aquifer appears to be to the south. The April 2017 groundwater sampling event detected total lead in MW-7 and MW-9 had concentrations of 13.1 Îźg/L and 10.8 Îźg/L, respectively, which is below the Res TAP GWSL of 15 Îźg/L. MW-7 and MW-9 did not have detectable concentrations of dissolved lead above the laboratory reporting limit. The total lead concentrations are attributed to high turbidity in the newly installed wells.

Recommendations: IWM Consulting recommends that EDB (Method 8011), total lead, and dissolved lead be removed from future quarterly sampling events since there were exceedances of the laboratory reporting limits and/ or the RCG Res TAP GWSLs for EDB or dissolved lead.

IWM Consulting recommends that groundwater monitoring continue to be performed on a quarterly basis in order to determine if the identified groundwater analytes continue to maintain their current concentrations and/or plume dimensions.

IWM Consulting recommends that the eleven (11) permanent monitoring wells be sampled during the third quarter 2017 sampling event for VOCs and PAHs.

2017 - Q4

Conclusion: No free-phase, petroleum-related product was identified in any of the monitoring wells gauged and/ or sampled during the November 2017 groundwater sampling event. Development water from the well installations and purge water from the second and third quarter groundwater sampling events was containerized on-site in four (4) 55-gallon drums. The drummed water was transported off the Site for treatment and/or disposal in September 2017.

Recommendations: IWM Consulting recommends that groundwater monitoring continue to be performed for one (1) additional quarter in order to determine if the identified VOC and PAH contaminant plumes are reducing in size or maintaining their current configurations prior to requesting a No Further Action (NFA) status for this Site.

IWM Consulting recommends that the eleven (11) monitoring wells sampled during the fourth quarter 2017 sampling event be sampled for VOCs and PAHs during the next quarterly sampling event (first quarter 2018).

2018 - Q2

Conclusion: Free-phase, petroleum-related product (LNAPL) was identified in monitoring well MW-7 and gauged at approximately 0.02 feet in thickness during the February 2018 sampling event. Based on the measurable LNAPL, a vacuum tanker was used on May 14, 2018 to remove groundwater and/or product from MW-7. Following the water extraction event, no LNAPL was measured in MW-7. MW-7 was gauged at the time of the groundwater sampling for the 2nd quarter sampling event and was observed to have <0.01 feet of LNAPL with a strong diesel odor. MW-6 was also included in the water extraction event and had a slight decrease in the concentration of dissolvedphase benzene from February 2018 to May 2018, following the water sucking event. Water removed on May 14, 2018 from TRAVEL PLAZA NO. 8 SITE ASSESSMENT STUDY

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MW-6 and MW-7 was sucked into a vacuum truck and disposed of following the water sucking event.

No LNAPL was identified in any of the monitoring wells gauged and/or sampled during the May 20, 2018 groundwater sampling event, except for monitoring well MW-7. LNAPL was measured at <0.01 feet. Purge water from the monitoring wells was placed in a 55-gallon drum and left on the Site pending future characterization and disposal.

Recommendations: IWM Consulting recommends that groundwater monitoring continue to be performed during consecutive quarters in the deep aquifer wells (MW-1, MW-2, MW-3, MW-4, MW-5, MW-6, MW-7, and MW-8) in order to determine if the identified VOC and PAH contaminant plume will continue to increase/decrease in size or is maintaining its current configuration and to determine if the LNAPL identified in MW-7 is increasing/decreasing or maintaining its current thickness.

IWM Consulting recommends the placement of an absorbent sock in MW-7 following quarterly sampling events to try and remove the LNAPL. The absorbent sock will be removed approximately one (1) week prior to the sampling event in order measure the thickness of potential LNAPL. Based on the results of the water extraction event on May 14, 2018, future water removal events do not appear to be beneficial at this time.

IWM Consulting recommends that the eight (8) monitoring wells sampled during the second quarter 2018 sampling event be sampled for VOCs and PAHs during the next quarterly sampling event (third quarter 2018).

IWM Consulting further recommends that the shallow aquifer wells (MW-9, MW-10, and MW-11) be removed from future quarterly sampling events due to no VOCs or PAHs being detected in MW-9 or MW-11 and a steady benzene concentration (ranging between 5.1 and 8.2 Îźg/L) in MW-10 during the last four (4) consecutive quarterly sampling events.

2018 - Q4

Conclusion: The results of the quarterly sampling appear to indicate fluctuations in contaminant concentrations between sampling events. The fluctuations in contaminant concentrations are likely due to fluctuations in groundwater elevations and possible petroleum-impacted soil washing. The May 2018 groundwater extraction event from MW-6 and MW-7 does not appear to have significantly impacted the dissolvedphase groundwater concentrations beneath the site. Contaminant impacts within the shallow aquifer were consistent with historical findings and remained relatively minimal during the fourth quarter 2018.

No measurable free-phase, petroleum-related product was identified in any of the monitoring wells during the November 2018 sampling event. However, review of the November 2018 Water Parameter Monitoring Forms provided in Appendix B indicates that a slight sheen was observed on the groundwater from MW-7.

Recommendations: IWM Consulting recommends that groundwater monitoring continue for one (1) final consecutive quarter in the deep aquifer wells (MW-1, MW-2, MW-3, MW-4, MW-5, MW-6, MW-7, and MW-8) to determine if the identified VOC and PAH contaminant plume will continue to increase/decrease in size or is maintaining its current configuration and to determine if the LNAPL historically observed in MW-7 is increasing/decreasing or maintaining its current thickness.

IWM Consulting recommends that the shallow aquifer wells (MW-9, MW-10, and MW-11) be sampled for one (1) final quarterly sampling event. IWM Consulting further recommends that these shallow wells be abandoned following review of the first quarter 2019 analytical results due to the absence of VOC or PAH detections in MW-9 and MW-11 and a steady benzene concentration (ranging between 5.1 Îźg/L and 8.2 Îźg/L) in MW-10 during the previous six (6) consecutive quarterly sampling events.

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IWM Consulting recommends that the first quarter 2019 groundwater sampling event include QA/QC documentation for raw data in order to close the Site with an Environmental Restrictive Covenant (ERC).

IWM Consulting recommends that closure of LUST Incident No. 201603519 be pursued via utilization of an ERC restricting groundwater use following the eighth quarterly monitoring event at the Site (first quarter 2019), proposed for February 2019.

2019 - Q2

Conclusion:

(Present)

Results from the February 2019 groundwater sampling event indicate that the shallow aquifer, dissolvedphase benzene plume beneath the northwest portion of the Site and the deep aquifer dissolved-phase VOC and PAH constituent plume beneath the majority of the Site appear to have remained consistent with previous sampling events. Figure 3 and Figure 4 identify the apparent direction of groundwater flow within the shallow and deep groundwater aquifers beneath the Site, respectively, which are consistent with previous findings. The results of the quarterly sampling appear to indicate fluctuations in contaminant concentrations between sampling events. The fluctuations in contaminant concentrations are likely due to fluctuations in groundwater elevations and possible petroleum-impacted soil washing.

The May 2018 groundwater extraction event from MW-6 and MW-7 does not appear to have significantly impacted the dissolved-phase groundwater concentrations beneath the site. Contaminant impacts within the shallow aquifer were consistent with historical findings and remained relatively minimal during the first quarter 2019.

No measurable free-phase, petroleum-related product was identified in any of the monitoring wells during the November 2018 sampling event. Review of the February 2019 Water Parameter Monitoring Forms provided in Appendix B indicates that a slight sheen was observed on the groundwater from MW7; however, no contaminants were detected at concentrations exceeding during the first quarter 2019.

IWM Consulting performed trend analysis of impacted wells MW-1, MW-3, MW-4, MW-5, and MW6. These wells were chosen based on current and historical VOC and PAH concentrations above their respective RCG Res TAP GWSLs. Mann Kendall Trend Evaluations were utilized to illustrate and present the overall trend in each monitoring well over the duration of the quarterly sampling events. The majority of the graphs illustrated decreasing or stable concentration trends in multiple wells, although not statistically significant. Some graphs illustrated fluctuating concentrations, which could explain the non-apparent increasing concentration trend for some of the constituents. Therefore, naphthalene, 1-methylnaphthalene, and/or benzene concentrations were compared to groundwater elevations to evaluate if there was a corresponding relationship over time. Based on these graphs it can be determined that the fluctuation in the water table correlates with the fluctuation in contaminant concentrations.

Recommendations: IWM Consulting recommends that groundwater monitoring be discontinued based on the stable and/or attenuating VOC and PAH concentrations detected in the shallow and deep aquifers. Based on the trend analyses performed by IWM Consulting, it can be determined that VOC and PAH concentrations are either decreasing, remaining stable, or being influenced by fluctuations in the water table. The groundwater plume in each aquifer has continued to either reduce in size or maintain its current configuration.

IWM Consulting recommends that the Site be granted No Further Action (NFA) status following the recording of an Environmental Restrictive Covenant (ERC) restricting groundwater use on the property deed.

IWM Consulting recommends that the eleven (11) monitoring wells associated with Incident No. 201603519 be properly abandoned according to IDEM and Indiana Department of Natural Resources (IDNR) administrative code for well abandonment.

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SW (Southwest) - Site History Timeline 2017 - Q2

Conclusion: There are two (2) apparent groundwater aquifers located beneath the Site. Nine (9) permanent groundwater monitoring wells were installed at the Site, four (4) screened within the shallow aquifer and five (5) screened within the deep aquifer. Monitoring wells MW-1, MW-2, MW-7S, and MW-8 were screened within the shallow aquifer. Monitoring wells MW-3, MW-4, MW-5, MW-6, and MW-7D were screened within the deep aquifer.

Groundwater flow direction and gradient was determined for the shallow and deep aquifers using data collected during the April 2017 groundwater sampling event. The apparent direction of groundwater flow within the shallow aquifer is to the south-southeast and the apparent direction of groundwater flow in the deep aquifer appears to be to the south.

Recommendations: IWM Consulting recommends that additional Site investigation activities in the vicinities of shallow aquifer monitoring wells MW-1 and MW-7S be considered to further delineate soil and/or groundwater impacts on these portions of the Site. MW-1 is located in a downgradient direction on the south side of the Site, on a slope that makes drilling/well installation activities difficult.

IWM Consulting recommends that PAHs, total lead, and dissolved lead be removed from the sampling suite during future quarterly sampling events. The nine (9) permanent monitoring wells should continue to be sampled during the third quarter 2017 for VOCs and naphthalenes (1-methynaphthalene, 2-methylnaphthalene, and naphthalene).

IWM Consulting recommends that groundwater monitoring continue to be performed on a quarterly basis in order to determine if the identified shallow and deep aquifer groundwater analytes continue to maintain their current concentrations and/or plume dimensions.

2017 - Q4

Conclusion: No free-phase, petroleum-related product was identified in any of the monitoring wells gaugedand/ or sampled during the November 2017 groundwater sampling event.

Recommendations: IWM Consulting recommends that groundwater monitoring continue to be performed during consecutive quarters in order to determine if the identified VOC and naphthalene contaminant plumes are reducing in size or maintaining their current configurations.

IWM Consulting recommends that the nine (9) monitoring wells sampled during the fourth quarter 2017 sampling event be sampled for VOCs and naphthalenes during the next quarterly sampling event (first quarter 2018).

2018 - Q2

Conclusion: The results of the quarterly sampling appeared to indicate significant fluctuations in contaminant concentrations between sampling events. The fluctuations in contaminant concentrations are likely due to fluctuations in groundwater elevations and possible petroleum-impacted soil washing. The May 2018 groundwater extraction event from MW-1 and MW-7S does not appear to have impacted the dissolved-phase VOC and/or naphthalenes groundwater concentrations beneath the Site.

Recommendations: IWM Consulting recommends that groundwater monitoring continue to be performed during

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consecutive quarters in order to determine if the identified VOC and naphthalenes contaminant plumes are reducing in size or maintaining their current configurations.

2018 - Q4

Conclusion: The results of the quarterly sampling appear to indicate fluctuations in contaminant concentrations between sampling events. The fluctuations in contaminant concentrations are likely due to fluctuations in groundwater elevations and possible petroleum-impacted soil washing. The May 2018 groundwater extraction event from MW-1 and MW-7S does not appear to have significantly impacted the dissolvedphase VOC and/or naphthalenes groundwater concentrations beneath the Site.

Recommendations: IWM Consulting recommends that groundwater monitoring continue to be performed during consecutive quarters in order to determine if the identified VOC and naphthalenes contaminant plumes are reducing in size or maintaining their current configurations.

IWM Consulting recommends that no further water extraction events be performed due to the limited groundwater volume removed in May 2018 and the VOC and naphthalenes concentrations detected following the event.

IWM Consulting recommends that the nine (9) monitoring wells sampled during the fourth quarter 2018 sampling event be sampled for VOCs and naphthalenes during the next quarterly sampling event (first quarter 2019).

2019 - Q2

Conclusion:

(Present)

The results of the quarterly sampling appear to indicate fluctuations in contaminant concentrations between sampling events. The fluctuations in contaminant concentrations are likely due to fluctuations in groundwater elevations and possible petroleum-impacted soil washing. The results of the additional investigation activities downgradient of MW-1 and MW-2 indicate that no apparent VOC and/or PAH contaminants are migrating toward the wetland area south-southeast of the site.

Recommendations: IWM Consulting recommends that groundwater monitoring of the shallow aquifer wells (MW-1, MW2, MW-7S, and MW-8) continue to be performed during consecutive quarters in order to determine if the identified VOC and naphthalenes contaminant plumes are reducing in size or maintaining their current configurations.

IWM Consulting recommends that no further groundwater monitoring be performed on the deep aquifer wells (MW-3, MW-4, MW-5, MW-6, and MW-7D).

IWM Consulting does not recommend any additional investigation concerning the off-site migration of VOC and/or PAH constituents toward the wetland area located south-southeast of the Site.

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Appendix B - NE Site - NFA Letter

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Appendix C - SW Site – ERC Termination – March 2016

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