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Hydrocarbons-Gasoline Range Organics (TPH-GRO), BTEX and MTBE in accordance with RISC guidelines. Based upon the results, all of which were below the laboratory detection limits, which were at or below the RISC Residential Default Closure Limits (RDCLs) for the constituents analyzed. Based upon these factors, IDEM concluded that no further response actions were deemed necessary, based on information known to IDEM at the time of the determination. Summary Evaluation — Based upon our review of the limitations identified by the GPR Survey, the documentation that the former UST systems were located along the western side of the former building and the location for sampling established primarily along the eastern and southern portions of the subject site; JPR believes that there is a potential that historical UST systems and/or other service station related equipment/operations has a potential for impacting soils beneath the former gasoline service station structure. It also seems that the presence of only 1,000-gallon and 750-gallon UST systems as part of a historical gasoline service station is somewhat unusual. Such operations typically involve tanks that are 5,000-gallons to 10,000-gallons in size. Furthermore we note that the area of the former UST systems was built over with the western addition to the automotive reconditioning center in 1974, and the absence of any documentation regarding the closure of any of the UST systems removed from the site, only the accounts of Mr. Bryant for the 1,000-, 750- and 500-gallon systems. Regarding the previous Phase II, there were very limited number of soil borings placed within the footprint of the former service station (SB-2 and potentially SB-7), where it is likely that floor drains, waste oil tanks and hydraulic lifts may very well have been present. Furthermore, with groundwater flow in the area of the site being predominately westward, there are no soil borings that have been installed to the west of the building, or for that matter on either of the parcels not directly associated with the former service station operations (north and west). As such the potential for on-site migration of contaminants from off-site sources to the east and north have not been evaluated relative to the subject site. Such facilities include the former Hi-Speed Car Wash (former fueling center with two UST systems removed, no documentation of closure available), former dry cleaning operations, etc. JPR also notes that current IDEM policy calls for the analysis of Volatile Organic Compounds (VOCs), Lead, Lead Scavengers and Naphthalenes. This expanded analysis versus that of TPH-GRO (no longer used by IDEM) and BTEX, allows for a more comprehensive assessment of potential impacts stemming from the possible historical use of solvents, lead in gasoline, cleaning and degreasing agents, etc. PROPOSED SCOPE OF SERVICES In response to the aforementioned environmental concerns, and in an effort to determine the extent to which, if any, potential impacts to the subsurface environmental have occurred; Jones Petrie Rafinski would propose a Phase II Environmental Site Assessment involving the collection and analysis of soil and groundwater samples to be used in the evaluation of such potential environmental impacts. It should be noted that such scope of work has been prepared prior to the completion of the Phase I Environmental Site Assessment, as commissioned by the City of South Bend Department of Community Investment, and is based primarily on a review of existing documentation, review of the environmental database search and Sanborn Fire Insurance Maps for the subject property. It should also be noted that Jones Petrie Rafinski has been somewhat limited in terms of our ability to conduct a thorough reconnaissance of the subject property based upon snow accumulations for the South Bend area during the month of January and February. Some modification to our concerns and/or recommendations relative to the proposed scope of services for Phase II Environmental Assessment may be appropriate following the site reconnaissance. 4