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Mr. Chris Dressel March 4,2014 Page 10 of 18 Task 2—Complete Phase I ESA (ASTME1527-05 and ASTME1527-13) Although a Phase I ESA is not required to receive all of the IBP Letters (though it is for some), lending institutions typically require one to be completed. Further, the last Phase I ESA completed for the site was in February 2012 and the current owner has occupied and conducted operations at the site since May 2013. In order to meet liability exemption requirements, applicants generally must meet certain conditions, a number of which can be satisfied through • The completion of a Phase I ESA. A workplan for the completion of the Phase I ESA has previously been outlined in the first phase of this project. This Phase I ESA would be completed in the name of the current property owner and lending institution. Both entities would be required to complete user questionnaires as described previously. Task 3—Complete Phase II Environmental Site Assessment/Site Investigation Generally, to obtain most IBP Letters, the applicant must be able to demonstrate that current levels of contaminants at the site substantially meet current remediation objectives, as established by IDEM under the Remediation Closure Guide. Based on a review of the background information of this site as described earlier(including Phase I ESA, dated February 22,2012,and a limited Phase II ESA, dated March 23, 2012, both completed by WPI) both soil and groundwater impacts are present at the site. Weaver Boos opines that this information is not sufficient to indicate that the site "substantially" meets current remediation objectives. As a result, a soil and groundwater site investigation (Phase II ESA), is proposed to supplement the earlier investigation completed in 2012. The Scope of Work for the Phase II ESA or Task 3 will be subdivided into the following: 1. Soil Probe and Groundwater Sampling 2. Analytical Work 3. Report Note, the results of an updated Phase I ESA (Task 2) may be different that those of the 2012 Phase I ESA, therefore requiring that the following Phase H ESA scope be modified should costs increase. Further, Weaver Boos understands that Hull & Associates, Inc. (Hull) is currently conducting a regional groundwater monitoring program including possible sampling and testing of groundwater at or near the site. Hull will be providing Weaver Boos will their test results of samples collected at or near the site. These results may be used to supplement or replace portions of our investigation and therefore possibly modify the following Phase II ESA. If so,