PSA - Groundwater Remedy and Quarterly Sampling Plan - Oliver Industrial Park - Hull and Assoc.

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Mr. Chris Dressel July 25, 2016 SBI074.300.0001 Page 2 the December 2015 RWP, but issued interim approval to the City to conduct the limited soil excavations in Spring of 2016. As stated above, those excavations were completed by Hull and its subcontractor in May -June 2016. In telephone conversations between Hull and IDEM in June and July 2016, IDEM has verbally indicated that it will also issue interim approval to the City to implement the groundwater remedy during Summer 2016 pending final review and comment on the December 2015 RWP. Given the current status of the Site, the following additional activities are proposed: Task 1 Routine Groundwater Monitoring Task 1 a Pre -Remedy; 180 days, 365, 545, and 730 Days Post -Remedy As further explained in Task 3 below, Hull proposes to retain the services of Innovative Environmental Technologies Inc. (JET) to introduce a groundwater remedy into the subsurface that will stimulate the degradation of VOCs in groundwater beneath the Site. JET's scope involves reviewing certain groundwater data collected by Hull to establish a baseline and to evaluate the effectiveness of the remedy after it is initiated. Before the remedy is initiated, and 180 days, 365 days, 545 days, and 730 days following the remedy event, Hull will collect groundwater samples from monitoring wells in the vicinity of and downgradient from the PRB walls and analyze the samples for the following parameters: - Volatile organic compounds (VOCs) in accordance with U.S. EPA Method 8260; - Ethene, ethane, and methane in accordance with Method RSK 75; - Sulfate in accordance with U.S. EPA Method 300.0; and - Total and dissolved iron in accordance with U.S. EPA Method 6010. Groundwater samples during these events will be collected using low -flow methods. During low -flow sampling events, the following parameters will be monitored: - Groundwater elevation; - Dissolved oxygen; - Oxidation-reduction potential; - Specific conductivity; - pH; and - Temperature. Groundwater samples will be collected from monitoring wells MW-1S (shallow screened depth), MW-11 (intermediate screened depth), MW-1 D (deep screened depth), PMW-1 1, MW-135, MW-145, MW-165, MW-171, MW-17D, HMW-19, MW-20S/D, MW-21 S/D, MW-22S/D, MW-23S/D, MW-24, MW-25S/D, MW-26S/D, MW-27S/D, MW-28S/D, MW-29S/D, and MW-305/D and submitted to the laboratory for VOC analysis using U.S. EPA Method 8260. This cost estimate also includes costs for laboratory analyses on samples collected from replacement monitoring wells installed as part of Task 2 below. To save some cost, this cost estimate assumes that samples from only 32 of the aforementioned monitoring wells will be analyzed for the additional parameters requested by IET (ethane, ethene, methane, sulfate, and total/dissolved iron). As noted in Task 2 below, we will attempt to negotiate with IDEM a reduced number of replacement monitoring wells (and therefore groundwater samples that must be analyzed) to save costs for the City wherever possible. Duplicate samples will be collected at randomly selected monitoring well locations. Field/equipment blanks will also be collected and submitted along with a trip blank for analysis as part of QA/QC of field procedures. Purge and decontamination waters will be collected and stored in U.S. DOT -approved 55- gallon drums. Costs to remove, transport, and dispose of up to twenty 55-gallon drums of containerized groundwater (which is presumed to be non -hazardous) are included in this task.