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Mr. Chris Dressel SB1072.400.0002 January 27, 2014 Page 2 In September 2012, following further discussions with IDEM, Hull submitted a Comprehensive Environmental Summary Report for the Site that summarized all environmental assessment work completed at the Site to date. The summary report acknowledged that additional off -Site assessment of groundwater would be necessary and presented a general path forward for that additional assessment. While the direction of the future remedial approach for groundwater is yet to be determined, it currently appears that the main driver for the remedial approach will center upon ensuring that the groundwater to indoor air exposure pathway for both existing and future structures is incomplete for both on- and off -Site receptors. Minor historical detections of COCs in soils in isolated areas across the Site may require additional assessment and /or handling during future unspecified redevelopment activities, but are not expected to materially impact the overall remedial strategy for the Site. In April 2013, IDEM responded with comments to the Comprehensive Environmental Summary Report. The City and Hull have engaged in verbal and electronic mail correspondence with IDEM on the path forward, but have not yet fully and formally responded to IDEM'VP RVWHFHn\NYrNft FRrrespondence. In general terms, IDEM, the City, and Hull agree that additional on- and off -Site assessment activities to evaluate the vertical and horizontal distribution of VOCs in groundwater are necessary prior to the submittal of a RWP. However, the extent to which those assessment activities are necessary has not been resolved, as discussed below. This current proposal presents, on a time and materials, not -to- exceed basis, a scope of work and costs to implement steps that will likely be necessary to complete additional assessment activities, prepare an amended RWP, and, once approved by IDEM, implement the RWP to ultimately receive from IDEM a Covenant Not to Sue pursuant to the VRP. This current proposal also incorporates tasks required to evaluate any potential vapor intrusion issues on- and off -Site. The following additional activities are proposed: Task 1 Prepare Various IDEM VRP Documents A Sampling and Analysis Plan (SAP) detailing the locations, sampling methods, and laboratory analyses proposed for the next stages of on- and off -Site soil and groundwater sampling must be prepared and approved by IDEM. The SAP will explain field activities that will be completed in Tasks 3 and 4 as described below. IDEM has also requested that an updated Health and Safety Plan (HASP) and n uality Assurance Project Plan (n APP) be submitted for their review and approval. Hull proposes to submit revised versions of the existing SAP and existing n APP firMRr ,D(0 'V FRnV- G+D\Jyn, Y" I ROw wLW/Dn updated HASP prior to the initiation of field activities. This task includes communication with the IDEM regarding next steps for additional assessment activities at the Site, strategic discussions to efficiently further guide the Site through the IDEM VRP, and meetings with the City to discuss approaches for evaluating any potential vapor intrusion issues at on- and off -Site properties as necessary. Task 2 Coordinate Evaluation of Any Potential Vapor Intrusion Issues Hull proposes to coordinate efforts with the City, the IDEM, and other interested parties to evaluate any potential completeness of the groundwater to indoor air exposure pathway that may exist on- or off -Site. Hull assumes that our coordination efforts will entail attendance at meetings, written and telephone correspondence, and communication with IDEM as deemed appropriate. Hull proposes a comprehensive scope of work to evaluate whether any potentially complete exposure pathway may exist at current or future on- or off -Site structures.