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Ivy Tower Phase 11 February 27, 2012 Page 2 of 7 Such concerns stem from the identified location of a former UST system along Building 113, the potential presence of additional undocumented UST systems, undocumented spills and /or releases, and the absence of any documentation regarding historical disposal practices. In addition we note that for other areas immediately adjacent to the subject site, abandoned features such as cisterns (32,000 gallons) and historically impacted soils, have been unearthed, and are therefore potentially present on the subject site. We note that such historical uses (automotive manufacture) may have involved the use of underground storage tanks for purposes of fueling, storage of solvents (lacquer thinner), and /or storage of heating oils, etc. During the reconnaissance, signage along the south - central exterior wall of Building 113 was identified as reading "Safety First, Absolutely No Gas Pumped While Your Motor Is Running ". In the immediate area of the signage, Wightman Petrie noted a grassy area among a series of small concrete drives that would be consistent with that of a former fueling area. There was no existing fuel fill ports or dispenser units that would indicate that the systems remained in the ground; however there was no documentation that the systems had been removed, the condition the system(s) were in at the time of removal, or if any environmental sampling had been performed as verification that the UST system(s) had not resulted in environmental impact. As such, the area of this presumed former UST system constitutes a Recognized Environmental Condition for which additional site investigation is warranted. Although the incidental release of oils associated with the transfer of oils and lubricants as a part of ongoing manufacturing activities are regarded as an environmental concern for which preventive measures should be taken (i.e., secondary containment, application of oil -dri and use of catch basins); such incidental spills and /or releases of oils to the concrete flooring of the subject site buildings are unlikely to result in significant environmental impacts to the subject site as a whole, based on the methods of construction (i.e., 12" -16" thickness of the concrete floors, ceilings and brick curtain walls of 12" thickness, etc.), minimal presence of floor drains, and floor drains being connected to the municipal sewer system. Furthermore, materials that are currently being warehoused at the facility were not identified as having any "release condition ". Wightman Petrie did not observe any outside storage or use of petroleum products or hazardous substances. The presence of subsurface impacts to the subject site as a result of historical manufacturing operations in close proximity to the subject site have been documented by prior investigation of those specific sites (groundwater plume migration). In most instances, review of the data by the Indiana Brownfields Program identified the level of remedial action necessary to minimize potential exposure pathways and allow for property re- development and re -use. Such actions have typically involved the removal of up to 24" of cover soils that were deemed as having been directly impacted by prior manufacturing (i.e., hot spot excavations), and /or an attachment of an Environmental Restrictive Covenant to the property deed. Such Environmental Restrictive Covenant generally prohibits the use of groundwater, prohibits agricultural use of the land, and prevents development of the property for residential uses. However, the potential for on -site migration of contaminants from off -site sources are noted as a Recognized Environmental Condition. Additional Recognized Environmental Conditions were identified with respect to the presence of PCB - laden di- electric fluids within larger industrial transformer units on the first level of Building 84 (transformers appropriately labeled), as well as the presence of asbestos - containing materials and lead - based and /or lead- containing paint. However, we note that the aforementioned PCB contaminated transformers, as well as the asbestos - containing materials and lead -based paint are to be addressed as part of any proposed re- development of the subject site, having been previously identified and quantified as additional services concurrent with the Phase I effort (submitted under separate cover). Based on the aforementioned Recognized Environmental Conditions being identified with respect to historical uses at the subject site and the potential for migration of contaminants from near -by, off -site sources; Wightman Petrie has been requested to submit a proposal for conducting a Phase II Environmental Site Assessment for the subject site.