George s Used Equipment Removal Action Report Laboratory analytical results were compared to the cleanup objectives outlined in the previously approve

Transcription

1 July 10, 2015 Ed Olson MPCA 520 Lafayette Avenue North St. Paul, MN RE: George s Used Equipment Response Action Report UMore Park OU2 and OU3 Rosemount, MN Bay West Proposal J Dear Mr. Olson: Bay West LLC (Bay West) is pleased to submit this report documenting the completion of the June 2015 response action and associated supplemental investigation activities action at the George s Used Equipment (GUE) Operable Unit (OU) 2 and OU3 in the University of Minnesota (U of M) UMore Park, in Rosemount, Minnesota (the Site; Figure 1). This report presents the scope of work, results of the supplemental investigation and response action, and recommendations for the Site. 1.0 Introduction Excavation activities completed at the Site by Bay West in September 2014 revealed polychlorinated biphenyl (PCB) concentrations in soil exceeding 50 milligrams per kilogram (mg/kg) east of the former GUE building pad (Building 716A) in sample location 716A-SS37 and in a previous sample collected at 716A-SS13. The presence of elevated PCBs in this portion of the Site suggested that additional soil delineation, both vertically and horizontally, was warranted. At the request of the U of M, on October 14, 2014, Bay West completed delineation of the extent and magnitude of PCB contamination in soil at the Site to be removed pursuant to the previously approved Response Action Plan (RAP) for the Site. Based on analytical results for sidewall and bottom samples collected from the September 2014 excavation at the Site, Bay West completed 18 soil borings (SP-01 through SP-18) to 4 feet below ground surface (bgs), with soil samples collected at intervals of 0-2 feet and 2-4 feet for laboratory analysis of PCBs. Laboratory analytical results were compared to the cleanup objectives outlined in the previously approved RAP. Total PCB concentrations from 3 of the 18 samples from the 0-2 foot interval were greater than the cleanup criteria of 1 mg/kg for the 10-inch cover material. There were no total PCBs detected at concentrations exceeding 1 mg/kg in the soil samples analyzed in the 2-4 foot interval. Results of the supplemental investigation are further detailed in the November 14, 2014, Supplemental Investigation Report. On December 1-5, 2014, based on the results of the October 14, 2014, supplemental investigation, Bay West completed the excavation of 2, tons of soil at the Site. Bay West collected confirmation sidewall soil samples from the 0-2 feet intervals every 35 lineal feet. Page 1 UMP020801

2 George s Used Equipment Removal Action Report Laboratory analytical results were compared to the cleanup objectives outlined in the previously approved RAP. Based on the laboratory results, the excavation area was delineated and complete to the east, west and south; however, the northeast corner sidewall samples of the excavation had PCB concentrations of 27 mg/kg at 716A-SS51 and 110 mg/kg at 716A-SS52. Sample locations 716A-SS51 and 716A-SS52 are located in the former driveway/approach area of the Site. Based on these analytical results, Bay West recommended completing additional investigation activities to evaluate the magnitude and extent of the PCB contamination in this area. This report presents the results of the additional investigation and documents the response action implemented to mitigate PCB contamination at the Site in accordance with the requirements of the Record of Decision (ROD). 2.0 Additional Investigation and Removal Action Scope of Work Bay West conducted the following scope of work: Amended the current Health and Safety Plan, as required by Occupational Safety and Health Administration (OSHA); Conducted a utility meet with public utility locators for each field event to verify if the proposed soil boring and excavation locations were acceptable; Advanced 20 soil borings using a hand auger for the purpose of soil sample collection (Figure 2). Two composite soil samples were collected from each soil boring from the ground surface to 10 inches bgs, and 10 inches to 24 inches bgs in each soil boring location; Submitted 31 soil samples and two duplicate soil samples for laboratory analysis of PCBs; Based on additional investigation results, areas with PCB concentrations greater than 10 mg/kg were excavated (Figure 2) as required in the ROD. A total of 26 tons of excavated soil was transported to Vonco II Landfill in Becker, Minnesota, for disposal; Backfilled excavated areas with a minimum of 12 inches of virgin sand in 6-inch lifts; and Transported and placed an additional 15 inches of virgin sand to cover the area where PCBs were detected between 1 and 10 mg/kg. The entire area where soils were excavated was covered with 3 inches of top soil, and the area was planted with a native seed mix. Further details regarding the additional investigation and response action are discussed below in Section 3.0 and Section 4.0, respectively. 3.0 Additional Investigation Activities and Results On April 27, April 28, and May 15, 2015, Bay West conducted additional investigations to determine the extent and magnitude of PCB contamination in the vicinity of soil samples SS-51 and SS-52. Using a hand auger, Bay West advanced 20 soil borings (SS-57 through SS-76; Figure 2) and collected two composite soil samples from each soil boring: the first composite sample from the ground surface to 10 inches bgs and the second from 10 inches to 24 inches bgs. Bay West submitted 31 soil samples and 2 duplicate soil samples to Legend Technical Services for analysis of PCBs. Laboratory analytical results were compared to the cleanup objectives in the ROD. Nine of the 15 samples analyzed from the 0 to 10 inch bgs interval had total PCB concentrations less than 1 mg/kg. Four samples had PCB concentrations between 1 and 10 mg/kg. One sample analyzed Page 2 UMP020802

3 George s Used Equipment Removal Action Report from the 0 to 10 inch bgs interval had a total PCB concentration between 10 and 50 mg/kg (SS-67, 10.9 mg/kg), and one sample analyzed from the 0 to 10 inch bgs interval had a total PCB concentration greater than 50 mg/kg (SS-61, 89.8 mg/kg). Complete laboratory analytical results from these samples are presented in Table 1, and laboratory analytical reports are included in Appendix A. Sample locations are shown on Figure 2. Field notes are included in Appendix B. Based on the additional investigation findings described above, the response actions recommended in the 2015 Supplemental Investigation/Removal Action Work Plan (Approved Work Plan) approved by the MPCA on June 5, 2015, were implemented. 4.0 Response Actions On June 15 through 19, 2015, Bay West excavated soil in the vicinity of soil samples SS-51, SS-52, SS-61, SS-62 and SS-67, where PCB concentrations exceeded 10 mg/kg. After the removal of the impacted soil, a protective cover was placed in areas with PCB concentrations greater than 1 mg/kg and less than 10 mg/kg in the upper 10 inches of soil. The following details the excavation activities conducted at the Site: Removed brush and debris from proposed excavation area; Excavated 26 tons of PCB contaminated soil in the areas of SS-51 and SS-67 identified in Figure 2 with PCB concentrations greater than 10 mg/kg, but less than 50 mg/kg. The PCB contaminated soil was transported to Vonco II landfill in Becker, Minnesota, for disposal. Weigh tickets from the Vonco II landfill are included in Appendix C; Excavated and containerized soil with PCB concentrations greater than 50 mg/kg. Approximately one cubic yard of soil per location at SS-51, SS-52, and SS-61 was removed to a depth of 1 foot bgs as shown on Figure 2. The University is managing the soil as a bulk PCB waste under 40 Code of Federal Regulation (CFR) The drums are being processed under the University of Minnesota s Resource Conservation and Recovery Act (RCRA) Part B permit until they are shipped to a permitted hazardous waste disposal facility under Section 3004 of the RCRA regulations. These drums are scheduled for pickup during the week of July 13, We will submit documentation of the proper disposal of this material to MPCA as soon as it becomes available; Per the Approved Work Plan, bottom and sidewall confirmation samples were not collected, as the proposed excavation bottom and sidewalls have been sufficiently characterized with the laboratory analytical data from the 0-2 foot interval in the previous investigations. PCB concentrations in all samples collected from the 2-4 foot interval had PCB concentrations less than 10 mg/kg; The excavation areas were backfilled with clean fill material in 6-inch lifts and compacted. To comply with the requirement in the ROD that no soils in the 0-10 inch interval at the Site are greater than 1 mg/kg of PCBs, approximately 348 cubic yards (487 tons) of virgin sand from the Aggregate Industries pit on the UMore property were transported to the Site, and a 1-foot layer of fill material was placed on the area outlined in Figure 2. Additionally, 3 inches of top soil (382 tons or approximately 318 cubic yards) was placed on top of the sand and seeded to prevent erosion; A barrier of mulch and wood chips was placed on the concrete pad to prevent erosion of the cover material. Sand overlain by topsoil was graded away from the concrete area with 12 inches of soil and 3 inches of top soil to provide for slope stability. The area was seeded with a native plant mix (Minnesota Department of Transportation [MnDOT] Seed Page 3 UMP020803

4 George s Used Equipment Removal Action Report Mix Native Construction) immediately following placement of the topsoil and watered, as necessary, to allow grass to grow in the newly seeded area; and A parking barrier of logs was permanently placed on the northeast approach to limit access to the Site after the cover material has been placed. Existing orange snow fence and signage were removed from the Site following completion of backfilling activities. A photo log of excavation and fill activities is included in Appendix D. Field notes from removal action activities are included in Appendix B. 5.0 Recommendation In accordance with the ROD, PCB contaminated soil exceeding 10 mg/kg has been removed from the Site and the direct contact exposure pathway of PCB contaminated soil greater than 1 mg/kg and less than 10 mg/kg has been eliminated with the placement of 15 inches of sand and soil cover. Based on the results of previous investigations and remedial actions conducted at the Site, the response actions are considered complete. Thank you for the opportunity to submit this Response Action Report. If you have any additional questions or concerns on this report, please contact Bill Lazarz using the contact information provided below. Sincerely, Paul Raymaker, PG William Lazarz Geologist Environmental Services Group Manager (651) (651) praymaker@baywest.com williaml@baywest.com Page 4 UMP020804

5 George s Used Equipment Removal Action Report Tables Page 1 UMP020805

6 UMP020806

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8 George s Used Equipment Removal Action Report Figures UMP020808

9 UMP Y:\Clients\UNIVERSITY_OF_MINNESOTA\Georges_Used_Equipment\140488\MapDocs\J FIG 1 Site Location Map.mxd

10 UMP Y:\Clients\UNIVERSITY_OF_MINNESOTA\Georges_Used_Equipment\140488\MapDocs\J FIG 2 Site Map.mxd

11 George s Used Equipment Removal Action Report Appendix A Laboratory Reports UMP020811

12 88 Empire Drive St Paul, MN Tel: Fax: May 08, 2015 Mr. Bill Lazarz Bay West 5 Empire Drive St. Paul, MN Work Order Number: RE: Analytical Services Enclosed are the results of analyses for samples received by the laboratory on 04/28/15. If you have any questions concerning this report, please feel free to contact me. Results are not blank corrected unless noted within the report. Additionally, all QC results meet requirements unless noted. All samples will be retained by, unless consumed in the analysis, at ambient conditions for 30 days from the date of this report and then discarded unless other arrangements are made. All samples were received in acceptable condition unless otherwise noted. All test results and QC meet requirements of the 2003 NELAC standard. MDH (NELAP) Accreditation # Prepared by, LEGEND TECHNICAL SERVICES, INC Bach Pham Client Manager II bpham@legend-group.com The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. UMP020812

13 88 Empire Drive St Paul, MN Tel: Fax: Bay West Project: Analytical Services 5 Empire Drive Project Number: J Georges Used Equipment Work Order #: St. Paul, MN Project Manager: Mr. Bill Lazarz Date Reported: 05/08/15 ANALYTICAL REPORT FOR SAMPLES Sample ID Laboratory ID Matrix Date Sampled Date Received SS-61 (24'') Soil 04/28/15 12:28 04/28/15 13:25 SS-62 (24'') Soil 04/28/15 12:26 04/28/15 13:25 SS-63 (24'') Soil 04/28/15 12:24 04/28/15 13:25 SS-64 (24'') Soil 04/28/15 12:22 04/28/15 13:25 SS-67 (24'') Soil 04/28/15 12:16 04/28/15 13:25 SS-68 (24'') Soil 04/28/15 12:14 04/28/15 13:25 SS-69 (24'') Soil 04/28/15 12:12 04/28/15 13:25 SS-70 (24'') Soil 04/28/15 12:10 04/28/15 13:25 SS-71 (24'') Soil 04/28/15 12:08 04/28/15 13:25 SS-72 (24'') Soil 04/28/15 12:04 04/28/15 13:25 SS-73 (24'') Soil 04/28/15 12:02 04/28/15 13:25 SS-74 (24'') Soil 04/28/15 12:00 04/28/15 13:25 SS-BW72 (24'') Soil 04/28/15 12:06 04/28/15 13:25 Shipping Container Information Default Cooler Temperature ( C): 0.7 Received on ice: Yes Temperature blank was present Received on ice pack: No Received on melt water: No Ambient: No Acceptable (IH/ISO only): No Custody seals: No Case Narrative: The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 2 of 12 UMP020813

14 88 Empire Drive St Paul, MN Tel: Fax: Bay West Project: Analytical Services 5 Empire Drive Project Number: J Georges Used Equipment Work Order #: St. Paul, MN Project Manager: Mr. Bill Lazarz Date Reported: 05/08/15 PCB 8082A Analyte Result RL MDL Units Dilution Batch Prepared Analyzed Method Notes SS-61 (24'') ( ) Soil Sampled: 04/28/15 12:28 Received: 04/28/15 13:25 Aroclor 1016 < mg/kg dry 1 B5D /30/15 05/02/15 EPA 8082A Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 Aroclor 1242 < mg/kg dry 1 Aroclor 1248 < mg/kg dry 1 Aroclor 1254 < mg/kg dry 1 Aroclor 1260 < mg/kg dry 1 Surrogate: Decachlorobiphenyl % Surrogate: Tetrachloro-meta-xylene % SS-62 (24'') ( ) Soil Sampled: 04/28/15 12:26 Received: 04/28/15 13:25 Aroclor 1016 < mg/kg dry 1 B5D /30/15 05/05/15 EPA 8082A Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 Aroclor 1242 < mg/kg dry 1 Aroclor 1248 < mg/kg dry 1 Aroclor 1254 < mg/kg dry 1 Aroclor 1260 < mg/kg dry 1 Surrogate: Decachlorobiphenyl % Surrogate: Tetrachloro-meta-xylene % SS-63 (24'') ( ) Soil Sampled: 04/28/15 12:24 Received: 04/28/15 13:25 Aroclor 1016 < mg/kg dry 1 B5D /30/15 05/05/15 EPA 8082A Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 Aroclor 1242 < mg/kg dry 1 Aroclor 1248 < mg/kg dry 1 Aroclor 1254 < mg/kg dry 1 Aroclor mg/kg dry 1 Surrogate: Decachlorobiphenyl % Surrogate: Tetrachloro-meta-xylene % SS-64 (24'') ( ) Soil Sampled: 04/28/15 12:22 Received: 04/28/15 13:25 Aroclor 1016 < mg/kg dry 1 B5D /30/15 05/06/15 EPA 8082A Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 Aroclor 1242 < mg/kg dry 1 Aroclor 1248 < mg/kg dry 1 Aroclor 1254 < mg/kg dry 1 Aroclor 1260 < mg/kg dry 1 Surrogate: Decachlorobiphenyl % The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 3 of 12 UMP020814

15 88 Empire Drive St Paul, MN Tel: Fax: Bay West 5 Empire Drive Project: Project Number: Analytical Services J Georges Used Equipment Work Order #: St. Paul, MN Project Manager: Mr. Bill Lazarz Date Reported: 05/08/15 PCB 8082A Analyte Result RL MDL Units Dilution Batch Prepared Analyzed Method Notes SS-64 (24'') ( ) Soil Sampled: 04/28/15 12:22 Received: 04/28/15 13:25 Surrogate: Tetrachloro-meta-xylene % SS-67 (24'') ( ) Soil Sampled: 04/28/15 12:16 Received: 04/28/15 13:25 B5D /30/15 05/06/15 EPA 8082A Aroclor 1016 < mg/kg dry 1 B5D /30/15 05/06/15 EPA 8082A Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 Aroclor 1242 < mg/kg dry 1 Aroclor mg/kg dry 10 05/06/15 Aroclor 1254 < mg/kg dry 1 05/06/15 Aroclor mg/kg dry 1 M1, R2 Surrogate: Decachlorobiphenyl % Surrogate: Tetrachloro-meta-xylene % SS-68 (24'') ( ) Soil Sampled: 04/28/15 12:14 Received: 04/28/15 13:25 Aroclor 1016 < mg/kg dry 1 B5D /30/15 05/06/15 EPA 8082A Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 Aroclor 1242 < mg/kg dry 1 Aroclor 1248 < mg/kg dry 1 Aroclor 1254 < mg/kg dry 1 Aroclor 1260 < mg/kg dry 1 Surrogate: Decachlorobiphenyl % Surrogate: Tetrachloro-meta-xylene % SS-69 (24'') ( ) Soil Sampled: 04/28/15 12:12 Received: 04/28/15 13:25 Aroclor 1016 < mg/kg dry 1 B5D /30/15 05/06/15 EPA 8082A Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 Aroclor 1242 < mg/kg dry 1 Aroclor 1248 < mg/kg dry 1 Aroclor 1254 < mg/kg dry 1 Aroclor mg/kg dry 2 05/06/15 Surrogate: Decachlorobiphenyl % Surrogate: Tetrachloro-meta-xylene % SS-70 (24'') ( ) Soil Sampled: 04/28/15 12:10 Received: 04/28/15 13:25 05/06/15 Aroclor 1016 < mg/kg dry 1 B5D /30/15 05/02/15 EPA 8082A Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 Aroclor 1242 < mg/kg dry 1 Aroclor mg/kg dry 2 05/02/15 Aroclor 1254 < mg/kg dry 1 05/02/15 The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 4 of 12 UMP020815

16 88 Empire Drive St Paul, MN Tel: Fax: Bay West 5 Empire Drive Project: Project Number: Analytical Services J Georges Used Equipment Work Order #: St. Paul, MN Project Manager: Mr. Bill Lazarz Date Reported: 05/08/15 PCB 8082A Analyte Result RL MDL Units Dilution Batch Prepared Analyzed Method Notes SS-70 (24'') ( ) Soil Sampled: 04/28/15 12:10 Received: 04/28/15 13:25 Aroclor mg/kg dry 2 B5D /30/15 05/02/15 EPA 8082A Surrogate: Decachlorobiphenyl Surrogate: Tetrachloro-meta-xylene % % SS-71 (24'') ( ) Soil Sampled: 04/28/15 12:08 Received: 04/28/15 13:25 05/02/15 Aroclor 1016 < mg/kg dry 1 B5D3003 Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 04/30/15 05/02/15 EPA 8082A Aroclor 1242 < mg/kg dry 1 Aroclor mg/kg dry 5 05/07/15 Aroclor 1254 < mg/kg dry 1 05/02/15 Aroclor mg/kg dry 5 05/07/15 Surrogate: Decachlorobiphenyl % 05/02/15 Surrogate: Tetrachloro-meta-xylene % SS-72 (24'') ( ) Soil Sampled: 04/28/15 12:04 Received: 04/28/15 13:25 Aroclor 1016 < mg/kg dry 1 B5D3003 Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 04/30/15 05/06/15 EPA 8082A Aroclor 1242 < mg/kg dry 1 Aroclor mg/kg dry 1 05/07/15 Aroclor 1254 < mg/kg dry 1 05/06/15 Aroclor mg/kg dry 1 Surrogate: Decachlorobiphenyl % Surrogate: Tetrachloro-meta-xylene % SS-73 (24'') ( ) Soil Sampled: 04/28/15 12:02 Received: 04/28/15 13:25 Aroclor 1016 < mg/kg dry 1 B5D /30/15 05/06/15 EPA 8082A Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 Aroclor 1242 < mg/kg dry 1 Aroclor mg/kg dry 1 05/07/15 Aroclor 1254 < mg/kg dry 1 05/06/15 Aroclor mg/kg dry 2 05/07/15 Surrogate: Decachlorobiphenyl % 05/06/15 Surrogate: Tetrachloro-meta-xylene % SS-74 (24'') ( ) Soil Sampled: 04/28/15 12:00 Received: 04/28/15 13:25 Aroclor 1016 < mg/kg dry 1 B5D3003 Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 Aroclor 1242 < mg/kg dry 1 04/30/15 05/06/15 EPA 8082A The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 5 of 12 UMP020816

17 88 Empire Drive St Paul, MN Tel: Fax: Bay West 5 Empire Drive Project: Project Number: Analytical Services J Georges Used Equipment Work Order #: St. Paul, MN Project Manager: Mr. Bill Lazarz Date Reported: 05/08/15 PCB 8082A Analyte Result RL MDL Units Dilution Batch Prepared Analyzed Method Notes SS-74 (24'') ( ) Soil Sampled: 04/28/15 12:00 Received: 04/28/15 13:25 Aroclor 1248 < mg/kg dry 1 B5D /30/15 05/07/15 EPA 8082A Aroclor 1254 < mg/kg dry 1 05/06/15 Aroclor mg/kg dry 1 Surrogate: Decachlorobiphenyl % Surrogate: Tetrachloro-meta-xylene % SS-BW72 (24'') ( ) Soil Sampled: 04/28/15 12:06 Received: 04/28/15 13:25 Aroclor 1016 < mg/kg dry 1 B5D /30/15 05/06/15 EPA 8082A Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 Aroclor 1242 < mg/kg dry 1 Aroclor mg/kg dry 1 05/07/15 Aroclor 1254 < mg/kg dry 1 05/06/15 Aroclor mg/kg dry 1 Surrogate: Decachlorobiphenyl Surrogate: Tetrachloro-meta-xylene % % The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 6 of 12 UMP020817

18 88 Empire Drive St Paul, MN Tel: Fax: Bay West 5 Empire Drive Project: Project Number: Analytical Services J Georges Used Equipment Work Order #: St. Paul, MN Project Manager: Mr. Bill Lazarz Date Reported: 05/08/15 PERCENT SOLIDS Analyte Result RL MDL Units Dilution Batch Prepared Analyzed Method Notes SS-61 (24'') ( ) Soil Sampled: 04/28/15 12:28 Received: 04/28/15 13:25 % Solids 89 % 1 SS-62 (24'') ( ) Soil Sampled: 04/28/15 12:26 Received: 04/28/15 13:25 % Solids 92 % 1 SS-63 (24'') ( ) Soil Sampled: 04/28/15 12:24 Received: 04/28/15 13:25 % Solids 87 % 1 SS-64 (24'') ( ) Soil Sampled: 04/28/15 12:22 Received: 04/28/15 13:25 % Solids 90 % 1 SS-67 (24'') ( ) Soil Sampled: 04/28/15 12:16 Received: 04/28/15 13:25 % Solids 90 % 1 SS-68 (24'') ( ) Soil Sampled: 04/28/15 12:14 Received: 04/28/15 13:25 % Solids 87 % 1 SS-69 (24'') ( ) Soil Sampled: 04/28/15 12:12 Received: 04/28/15 13:25 % Solids 87 % 1 SS-70 (24'') ( ) Soil Sampled: 04/28/15 12:10 Received: 04/28/15 13:25 % Solids 90 % 1 SS-71 (24'') ( ) Soil Sampled: 04/28/15 12:08 Received: 04/28/15 13:25 % Solids 74 % 1 SS-72 (24'') ( ) Soil Sampled: 04/28/15 12:04 Received: 04/28/15 13:25 % Solids 90 % 1 SS-73 (24'') ( ) Soil Sampled: 04/28/15 12:02 Received: 04/28/15 13:25 % Solids 88 % 1 SS-74 (24'') ( ) Soil Sampled: 04/28/15 12:00 Received: 04/28/15 13:25 % Solids 90 % 1 SS-BW72 (24'') ( ) Soil Sampled: 04/28/15 12:06 Received: 04/28/15 13:25 B5D /30/15 04/30/15 B5D /30/15 04/30/15 B5D /30/15 04/30/15 B5D /30/15 04/30/15 B5D /30/15 04/30/15 B5D /30/15 04/30/15 B5D /30/15 04/30/15 B5D /30/15 04/30/15 B5D /30/15 04/30/15 B5D /30/15 04/30/15 B5D /30/15 04/30/15 B5D /30/15 04/30/15 % calculation % calculation % calculation % calculation % calculation % calculation % calculation % calculation % calculation % calculation % calculation % calculation % Solids 89 % 1 B5D /30/15 04/30/15 % calculation The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 7 of 12 UMP020818

19 88 Empire Drive St Paul, MN Tel: Fax: Bay West 5 Empire Drive Project: Project Number: Analytical Services J Georges Used Equipment Work Order #: St. Paul, MN Project Manager: Mr. Bill Lazarz Date Reported: 05/08/15 Analyte Batch B5D EPA 3545 ASE Extraction PCB 8082A - Quality Control Spike Result RL MDL Units Level Source Result %REC %REC Limits Blank (B5D3003-BLK1) Prepared: 04/30/15 Analyzed: 05/01/15 Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 < < < < < < mg/kg wet mg/kg wet mg/kg wet mg/kg wet mg/kg wet mg/kg wet < mg/kg wet Surrogate: Decachlorobiphenyl mg/kg wet Surrogate: Tetrachloro-meta-xylene mg/kg wet LCS (B5D3003-BS1) Prepared: 04/30/15 Analyzed: 05/01/15 Aroclor mg/kg wet Surrogate: Decachlorobiphenyl mg/kg wet Surrogate: Tetrachloro-meta-xylene mg/kg wet Matrix Spike (B5D3003-MS1) Source: Prepared: 04/30/15 Analyzed: 05/06/15 Aroclor mg/kg dry M1 Surrogate: Decachlorobiphenyl mg/kg dry Surrogate: Tetrachloro-meta-xylene mg/kg dry Matrix Spike Dup (B5D3003-MSD1) Source: Prepared: 04/30/15 Analyzed: 05/06/15 Aroclor mg/kg dry R2 Surrogate: Decachlorobiphenyl mg/kg dry Surrogate: Tetrachloro-meta-xylene mg/kg dry %RPD %RPD Limit Notes The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 8 of 12 UMP020819

20 88 Empire Drive St Paul, MN Tel: Fax: Bay West 5 Empire Drive Project: Project Number: Analytical Services J Georges Used Equipment Work Order #: St. Paul, MN Project Manager: Mr. Bill Lazarz Date Reported: 05/08/15 PERCENT SOLIDS - Quality Control Analyte Batch B5D General Preparation Spike Result RL MDL Units Level Source Result %REC Duplicate (B5D3011-DUP1) Source: Prepared & Analyzed: 04/30/15 %REC Limits % Solids 82.0 % %RPD %RPD Limit Notes Duplicate (B5D3011-DUP2) Source: Prepared & Analyzed: 04/30/15 % Solids 90.0 % Duplicate (B5D3011-DUP3) Source: Prepared & Analyzed: 04/30/15 % Solids 89.0 % The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 9 of 12 UMP020820

21 88 Empire Drive St Paul, MN Tel: Fax: Bay West Project: Analytical Services 5 Empire Drive Project Number: J Georges Used Equipment Work Order #: St. Paul, MN Project Manager: Mr. Bill Lazarz Date Reported: 05/08/15 Notes and Definitions R2 M1 < dry NA MDL RL RPD LCS MS RPD/RSD exceeded the laboratory acceptance limit. See case narrative. Matrix spike recovery was high, the associated blank spike recovery was acceptable. Less than value listed Sample results reported on a dry weight basis Not applicable. The %RPD is not calculated from values less than the reporting limit. Method Detection Limit Reporting Limit Relative Percent Difference Laboratory Control Spike = Blank Spike (BS) = Laboratory Fortified Blank (LFB) Matrix Spike = Laboratory Fortified Matrix (LFM) The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 10 of 12 UMP020821

22 88 Empire Drive St Paul, MN Tel: Fax: The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 11 of 12 UMP020822

23 88 Empire Drive St Paul, MN Tel: Fax: The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 12 of 12 UMP020823

24 88 Empire Drive St Paul, MN Tel: Fax: May 18, 2015 REVISION Mr. Bill Lazarz Bay West 5 Empire Drive St. Paul, MN Work Order Number: RE: Analytical Services This is a revised report. The details of the revision are listed in the case narrative on the following page. Enclosed are the results of analyses for samples received by the laboratory on 04/27/15. If you have any questions concerning this report, please feel free to contact me. Results are not blank corrected unless noted within the report. Additionally, all QC results meet requirements unless noted. All samples will be retained by, unless consumed in the analysis, at ambient conditions for 30 days from the date of this report and then discarded unless other arrangements are made. All samples were received in acceptable condition unless otherwise noted. All test results and QC meet requirements of the 2003 NELAC standard. MDH (NELAC) Certification # Prepared by, LEGEND TECHNICAL SERVICES, INC Kevyn Kalland Client Manager I kkalland@legend-group.com The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. UMP020824

25 88 Empire Drive St Paul, MN Tel: Fax: Bay West Project: Analytical Services 5 Empire Drive Project Number: J Georges Used Equipment Work Order #: St. Paul, MN Project Manager: Mr. Bill Lazarz Date Reported: 05/18/15 ANALYTICAL REPORT FOR SAMPLES Sample ID Laboratory ID Matrix Date Sampled Date Received SS-57 (10'') Soil 04/27/15 15:00 04/27/15 16:50 SS-58 (10'') Soil 04/27/15 15:02 04/27/15 16:50 SS-59 (10'') Soil 04/27/15 15:04 04/27/15 16:50 SS-60 (10'') Soil 04/27/15 15:06 04/27/15 16:50 SS-61 (10'') Soil 04/27/15 15:08 04/27/15 16:50 SS-62 (10'') Soil 04/27/15 15:10 04/27/15 16:50 SS-63 (10'') Soil 04/27/15 15:12 04/27/15 16:50 SS-64 (10'') Soil 04/27/15 15:14 04/27/15 16:50 SS-65 (10'') Soil 04/27/15 15:16 04/27/15 16:50 SS-66 (10'') Soil 04/27/15 15:18 04/27/15 16:50 SS-67 (10'') Soil 04/27/15 15:20 04/27/15 16:50 SS-68 (10'') Soil 04/27/15 15:22 04/27/15 16:50 SS-69 (10'') Soil 04/27/15 15:24 04/27/15 16:50 SS-70 (10'') Soil 04/27/15 15:26 04/27/15 16:50 SS-71 (10'') Soil 04/27/15 15:28 04/27/15 16:50 SS-72 (10'') Soil 04/27/15 15:30 04/27/15 16:50 SS-73 (10'') Soil 04/27/15 15:32 04/27/15 16:50 SS-74 (10'') Soil 04/27/15 15:34 04/27/15 16:50 SS-BW74 (10'') Soil 04/27/15 15:36 04/27/15 16:50 Shipping Container Information Default Cooler Temperature ( C): 1.0 Received on ice: Yes Temperature blank was present Received on ice pack: No Received on melt water: No Ambient: No Acceptable (IH/ISO only): No Custody seals: No Case Narrative: MS/MSD %RPDs was outside laboratory limits for Aroclor 1260 in the batch B5E1201. The MS/MSD source sample was SS-57 (10). All target analytes were within limits in the LCS. Per the client's request, this report was revised May 18, 2015 to include 8082A PCB analysis results for samples SS-57 (10), SS-58 (10), and SS-66 (10). This report supersedes the report dated May 11, The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 2 of 15 UMP020825

26 88 Empire Drive St Paul, MN Tel: Fax: Bay West Project: Analytical Services 5 Empire Drive Project Number: J Georges Used Equipment Work Order #: St. Paul, MN Project Manager: Mr. Bill Lazarz Date Reported: 05/18/15 PCB 8082A Analyte Result RL MDL Units Dilution Batch Prepared Analyzed Method Notes SS-57 (10'') ( ) Soil Sampled: 04/27/15 15:00 Received: 04/27/15 16:50 Aroclor 1016 < mg/kg dry 1 B5E /12/15 05/14/15 EPA 8082A Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 Aroclor 1242 < mg/kg dry 1 Aroclor 1248 < mg/kg dry 1 Aroclor 1254 < mg/kg dry 1 Aroclor mg/kg dry 1 M2, R2 Surrogate: Decachlorobiphenyl % Surrogate: Tetrachloro-meta-xylene % SS-58 (10'') ( ) Soil Sampled: 04/27/15 15:02 Received: 04/27/15 16:50 Aroclor 1016 < mg/kg dry 1 B5E /12/15 05/14/15 EPA 8082A Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 Aroclor 1242 < mg/kg dry 1 Aroclor 1248 < mg/kg dry 1 Aroclor 1254 < mg/kg dry 1 Aroclor 1260 < mg/kg dry 1 Surrogate: Decachlorobiphenyl % Surrogate: Tetrachloro-meta-xylene % SS-61 (10'') ( ) Soil Sampled: 04/27/15 15:08 Received: 04/27/15 16:50 Aroclor 1016 < mg/kg dry 1 B5D /29/15 04/30/15 EPA 8082A Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 Aroclor 1242 < mg/kg dry 1 Aroclor mg/kg dry 2 05/06/15 Aroclor 1254 < mg/kg dry 1 04/30/15 Aroclor mg/kg dry /02/15 Surrogate: Decachlorobiphenyl % Surrogate: Tetrachloro-meta-xylene % SS-62 (10'') ( ) Soil Sampled: 04/27/15 15:10 Received: 04/27/15 16:50 04/30/15 Aroclor 1016 < mg/kg dry 1 B5D /29/15 04/30/15 EPA 8082A Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 Aroclor 1242 < mg/kg dry 1 Aroclor 1248 < mg/kg dry 1 Aroclor 1254 < mg/kg dry 1 05/06/15 04/30/15 Aroclor mg/kg dry 10 05/05/15 M3 Surrogate: Decachlorobiphenyl % 04/30/15 The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 3 of 15 UMP020826

27 88 Empire Drive St Paul, MN Tel: Fax: Bay West 5 Empire Drive Project: Project Number: Analytical Services J Georges Used Equipment Work Order #: St. Paul, MN Project Manager: Mr. Bill Lazarz Date Reported: 05/18/15 PCB 8082A Analyte Result RL MDL Units Dilution Batch Prepared Analyzed Method Notes SS-62 (10'') ( ) Soil Sampled: 04/27/15 15:10 Received: 04/27/15 16:50 Surrogate: Tetrachloro-meta-xylene % SS-63 (10'') ( ) Soil Sampled: 04/27/15 15:12 Received: 04/27/15 16:50 B5D /29/15 04/30/15 EPA 8082A Aroclor 1016 < mg/kg dry 1 B5D /29/15 05/05/15 EPA 8082A Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 Aroclor 1242 < mg/kg dry 1 Aroclor 1248 < mg/kg dry 1 Aroclor 1254 < mg/kg dry 1 Aroclor mg/kg dry 1 Surrogate: Decachlorobiphenyl % Surrogate: Tetrachloro-meta-xylene % SS-64 (10'') ( ) Soil Sampled: 04/27/15 15:14 Received: 04/27/15 16:50 Aroclor 1016 < mg/kg dry 1 B5D /29/15 05/01/15 EPA 8082A Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 Aroclor 1242 < mg/kg dry 1 Aroclor 1248 < mg/kg dry 1 Aroclor 1254 < mg/kg dry 1 Aroclor mg/kg dry 1 Surrogate: Decachlorobiphenyl % Surrogate: Tetrachloro-meta-xylene % SS-66 (10'') ( ) Soil Sampled: 04/27/15 15:18 Received: 04/27/15 16:50 Aroclor 1016 < mg/kg dry 1 B5E /12/15 05/14/15 EPA 8082A Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 Aroclor 1242 < mg/kg dry 1 Aroclor 1248 < mg/kg dry 1 Aroclor 1254 < mg/kg dry 1 Aroclor 1260 < mg/kg dry 1 Surrogate: Decachlorobiphenyl % Surrogate: Tetrachloro-meta-xylene % SS-67 (10'') ( ) Soil Sampled: 04/27/15 15:20 Received: 04/27/15 16:50 Aroclor 1016 < mg/kg dry 1 B5D /29/15 05/01/15 EPA 8082A Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 Aroclor 1242 < mg/kg dry 1 Aroclor mg/kg dry 10 05/06/15 Aroclor 1254 < mg/kg dry 1 05/01/15 The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 4 of 15 UMP020827

28 88 Empire Drive St Paul, MN Tel: Fax: Bay West 5 Empire Drive Project: Project Number: Analytical Services J Georges Used Equipment Work Order #: St. Paul, MN Project Manager: Mr. Bill Lazarz Date Reported: 05/18/15 PCB 8082A Analyte Result RL MDL Units Dilution Batch Prepared Analyzed Method Notes SS-67 (10'') ( ) Soil Sampled: 04/27/15 15:20 Received: 04/27/15 16:50 Aroclor mg/kg dry 5 B5D /29/15 05/06/15 EPA 8082A Surrogate: Decachlorobiphenyl Surrogate: Tetrachloro-meta-xylene % % SS-68 (10'') ( ) Soil Sampled: 04/27/15 15:22 Received: 04/27/15 16:50 05/01/15 Aroclor 1016 < mg/kg dry 1 B5D2902 Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 04/29/15 05/06/15 EPA 8082A Aroclor 1242 < mg/kg dry 1 Aroclor 1248 < mg/kg dry 1 05/06/15 Aroclor 1254 < mg/kg dry 1 05/06/15 Aroclor mg/kg dry 1 Surrogate: Decachlorobiphenyl % Surrogate: Tetrachloro-meta-xylene % SS-69 (10'') ( ) Soil Sampled: 04/27/15 15:24 Received: 04/27/15 16:50 Aroclor 1016 < mg/kg dry 1 B5D2902 Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 04/29/15 05/01/15 EPA 8082A Aroclor 1242 < mg/kg dry 1 Aroclor 1248 < mg/kg dry 1 Aroclor 1254 < mg/kg dry 1 Aroclor mg/kg dry 1 Surrogate: Decachlorobiphenyl % Surrogate: Tetrachloro-meta-xylene % SS-70 (10'') ( ) Soil Sampled: 04/27/15 15:26 Received: 04/27/15 16:50 Aroclor 1016 < mg/kg dry 1 B5D /29/15 05/01/15 EPA 8082A Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 Aroclor 1242 < mg/kg dry 1 Aroclor mg/kg dry 2 05/02/15 Aroclor 1254 < mg/kg dry 1 05/01/15 Aroclor mg/kg dry 1 Surrogate: Decachlorobiphenyl % Surrogate: Tetrachloro-meta-xylene % SS-71 (10'') ( ) Soil Sampled: 04/27/15 15:28 Received: 04/27/15 16:50 Aroclor 1016 < mg/kg dry 1 B5D2902 Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 Aroclor 1242 < mg/kg dry 1 04/29/15 05/01/15 EPA 8082A The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 5 of 15 UMP020828

29 88 Empire Drive St Paul, MN Tel: Fax: Bay West 5 Empire Drive Project: Project Number: Analytical Services J Georges Used Equipment Work Order #: St. Paul, MN Project Manager: Mr. Bill Lazarz Date Reported: 05/18/15 PCB 8082A Analyte Result RL MDL Units Dilution Batch Prepared Analyzed Method Notes SS-71 (10'') ( ) Soil Sampled: 04/27/15 15:28 Received: 04/27/15 16:50 Aroclor mg/kg dry 1 B5D /29/15 05/02/15 EPA 8082A Aroclor 1254 < mg/kg dry 1 05/01/15 Aroclor mg/kg dry 1 Surrogate: Decachlorobiphenyl % Surrogate: Tetrachloro-meta-xylene % SS-72 (10'') ( ) Soil Sampled: 04/27/15 15:30 Received: 04/27/15 16:50 Aroclor 1016 < mg/kg dry 1 B5D /29/15 05/06/15 EPA 8082A Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 Aroclor 1242 < mg/kg dry 1 Aroclor 1248 < mg/kg dry 1 Aroclor 1254 < mg/kg dry 1 Aroclor 1260 < mg/kg dry 1 05/06/15 05/06/15 Surrogate: Decachlorobiphenyl % Surrogate: Tetrachloro-meta-xylene % SS-73 (10'') ( ) Soil Sampled: 04/27/15 15:32 Received: 04/27/15 16:50 Aroclor 1016 < mg/kg dry 1 B5D /29/15 05/01/15 EPA 8082A Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 Aroclor 1242 < mg/kg dry 1 Aroclor 1248 < mg/kg dry 1 Aroclor 1254 < mg/kg dry 1 05/06/15 05/01/15 Aroclor mg/kg dry 1 Surrogate: Decachlorobiphenyl % Surrogate: Tetrachloro-meta-xylene % SS-74 (10'') ( ) Soil Sampled: 04/27/15 15:34 Received: 04/27/15 16:50 Aroclor 1016 < mg/kg dry 1 B5D /29/15 05/01/15 EPA 8082A Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 Aroclor 1242 < mg/kg dry 1 Aroclor mg/kg dry 1 05/06/15 Aroclor 1254 < mg/kg dry 1 05/01/15 Aroclor mg/kg dry 2 05/06/15 Surrogate: Decachlorobiphenyl % Surrogate: Tetrachloro-meta-xylene % SS-BW74 (10'') ( ) Soil Sampled: 04/27/15 15:36 Received: 04/27/15 16:50 05/01/15 Aroclor 1016 < mg/kg dry 1 B5D /29/15 05/01/15 EPA 8082A Aroclor 1221 < mg/kg dry 1 The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 6 of 15 UMP020829

30 88 Empire Drive St Paul, MN Tel: Fax: Bay West 5 Empire Drive Project: Project Number: Analytical Services J Georges Used Equipment Work Order #: St. Paul, MN Project Manager: Mr. Bill Lazarz Date Reported: 05/18/15 PCB 8082A Analyte Result RL MDL Units Dilution Batch Prepared Analyzed Method Notes SS-BW74 (10'') ( ) Soil Sampled: 04/27/15 15:36 Received: 04/27/15 16:50 Aroclor 1232 < mg/kg dry 1 B5D2902 Aroclor 1242 < mg/kg dry 1 04/29/15 05/01/15 EPA 8082A Aroclor mg/kg dry 1 05/06/15 Aroclor 1254 < mg/kg dry 1 05/01/15 Aroclor mg/kg dry 2 05/06/15 Surrogate: Decachlorobiphenyl % 05/01/15 Surrogate: Tetrachloro-meta-xylene % The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 7 of 15 UMP020830

31 88 Empire Drive St Paul, MN Tel: Fax: Bay West 5 Empire Drive Project: Project Number: Analytical Services J Georges Used Equipment Work Order #: St. Paul, MN Project Manager: Mr. Bill Lazarz Date Reported: 05/18/15 PERCENT SOLIDS Analyte Result RL MDL Units Dilution Batch Prepared Analyzed Method Notes SS-57 (10'') ( ) Soil Sampled: 04/27/15 15:00 Received: 04/27/15 16:50 % Solids 93 % 1 SS-58 (10'') ( ) Soil Sampled: 04/27/15 15:02 Received: 04/27/15 16:50 % Solids 88 % 1 SS-59 (10'') ( ) Soil Sampled: 04/27/15 15:04 Received: 04/27/15 16:50 % Solids 85 % 1 SS-60 (10'') ( ) Soil Sampled: 04/27/15 15:06 Received: 04/27/15 16:50 % Solids 95 % 1 SS-61 (10'') ( ) Soil Sampled: 04/27/15 15:08 Received: 04/27/15 16:50 % Solids 89 % 1 SS-62 (10'') ( ) Soil Sampled: 04/27/15 15:10 Received: 04/27/15 16:50 % Solids 93 % 1 SS-63 (10'') ( ) Soil Sampled: 04/27/15 15:12 Received: 04/27/15 16:50 % Solids 91 % 1 SS-64 (10'') ( ) Soil Sampled: 04/27/15 15:14 Received: 04/27/15 16:50 % Solids 92 % 1 SS-65 (10'') ( ) Soil Sampled: 04/27/15 15:16 Received: 04/27/15 16:50 % Solids 71 % 1 SS-66 (10'') ( ) Soil Sampled: 04/27/15 15:18 Received: 04/27/15 16:50 % Solids 88 % 1 SS-67 (10'') ( ) Soil Sampled: 04/27/15 15:20 Received: 04/27/15 16:50 % Solids 86 % 1 SS-68 (10'') ( ) Soil Sampled: 04/27/15 15:22 Received: 04/27/15 16:50 % Solids 88 % 1 SS-69 (10'') ( ) Soil Sampled: 04/27/15 15:24 Received: 04/27/15 16:50 % Solids 85 % 1 SS-70 (10'') ( ) Soil Sampled: 04/27/15 15:26 Received: 04/27/15 16:50 B5D /29/15 04/29/15 B5D /29/15 04/29/15 B5D /29/15 04/29/15 B5D /29/15 04/29/15 B5D /29/15 04/29/15 B5D /29/15 04/29/15 B5D /29/15 04/29/15 B5D /29/15 04/29/15 B5D /29/15 04/29/15 B5D /29/15 04/29/15 B5D /29/15 04/29/15 B5D /29/15 04/29/15 B5D /29/15 04/29/15 % calculation % calculation % calculation % calculation % calculation % calculation % calculation % calculation % calculation % calculation % calculation % calculation % calculation % Solids 87 % 1 B5D /29/15 04/29/15 % calculation The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 8 of 15 UMP020831

32 88 Empire Drive St Paul, MN Tel: Fax: Bay West 5 Empire Drive Project: Project Number: Analytical Services J Georges Used Equipment Work Order #: St. Paul, MN Project Manager: Mr. Bill Lazarz Date Reported: 05/18/15 PERCENT SOLIDS Analyte Result RL MDL Units Dilution Batch Prepared Analyzed Method Notes SS-71 (10'') ( ) Soil Sampled: 04/27/15 15:28 Received: 04/27/15 16:50 % Solids 87 % 1 SS-72 (10'') ( ) Soil Sampled: 04/27/15 15:30 Received: 04/27/15 16:50 % Solids 89 % 1 SS-73 (10'') ( ) Soil Sampled: 04/27/15 15:32 Received: 04/27/15 16:50 % Solids 88 % 1 SS-74 (10'') ( ) Soil Sampled: 04/27/15 15:34 Received: 04/27/15 16:50 % Solids 89 % 1 SS-BW74 (10'') ( ) Soil Sampled: 04/27/15 15:36 Received: 04/27/15 16:50 B5D /29/15 04/29/15 B5D /29/15 04/29/15 B5D /29/15 04/29/15 B5D /29/15 04/29/15 % calculation % calculation % calculation % calculation % Solids 88 % 1 B5D /29/15 04/29/15 % calculation The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 9 of 15 UMP020832

33 88 Empire Drive St Paul, MN Tel: Fax: Bay West 5 Empire Drive Project: Project Number: Analytical Services J Georges Used Equipment Work Order #: St. Paul, MN Project Manager: Mr. Bill Lazarz Date Reported: 05/18/15 Analyte Batch B5D EPA 3545 ASE Extraction PCB 8082A - Quality Control Spike Result RL MDL Units Level Source Result %REC %REC Limits Blank (B5D2902-BLK1) Prepared: 04/29/15 Analyzed: 04/30/15 Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 < < < < < < mg/kg wet mg/kg wet mg/kg wet mg/kg wet mg/kg wet mg/kg wet < mg/kg wet Surrogate: Decachlorobiphenyl mg/kg wet Surrogate: Tetrachloro-meta-xylene mg/kg wet LCS (B5D2902-BS1) Prepared: 04/29/15 Analyzed: 04/30/15 Aroclor mg/kg wet Surrogate: Decachlorobiphenyl mg/kg wet Surrogate: Tetrachloro-meta-xylene mg/kg wet Matrix Spike (B5D2902-MS1) Source: Prepared: 04/29/15 Analyzed: 05/01/15 Aroclor mg/kg dry NR M3 Surrogate: Decachlorobiphenyl mg/kg dry Surrogate: Tetrachloro-meta-xylene mg/kg dry Matrix Spike Dup (B5D2902-MSD1) Source: Prepared: 04/29/15 Analyzed: 05/01/15 Aroclor mg/kg dry NR M3 Surrogate: Decachlorobiphenyl mg/kg dry Surrogate: Tetrachloro-meta-xylene mg/kg dry Batch B5E EPA 3550B Blank (B5E1201-BLK1) Prepared: 05/12/15 Analyzed: 05/13/15 Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 < < < < < < mg/kg wet mg/kg wet mg/kg wet mg/kg wet mg/kg wet mg/kg wet < mg/kg wet Surrogate: Decachlorobiphenyl mg/kg wet Surrogate: Tetrachloro-meta-xylene mg/kg wet LCS (B5E1201-BS1) Prepared: 05/12/15 Analyzed: 05/13/15 Aroclor mg/kg wet Surrogate: Decachlorobiphenyl mg/kg wet Surrogate: Tetrachloro-meta-xylene mg/kg wet %RPD %RPD Limit Notes The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 10 of 15 UMP020833

34 88 Empire Drive St Paul, MN Tel: Fax: Bay West 5 Empire Drive Project: Project Number: Analytical Services J Georges Used Equipment Work Order #: St. Paul, MN Project Manager: Mr. Bill Lazarz Date Reported: 05/18/15 Analyte Batch B5E EPA 3550B PCB 8082A - Quality Control Spike Result RL MDL Units Level Source Result %REC %REC Limits Matrix Spike (B5E1201-MS1) Source: Prepared: 05/12/15 Analyzed: 05/15/15 Aroclor mg/kg dry Surrogate: Decachlorobiphenyl mg/kg dry Surrogate: Tetrachloro-meta-xylene mg/kg dry Matrix Spike Dup (B5E1201-MSD1) Source: Prepared: 05/12/15 Analyzed: 05/15/15 Aroclor mg/kg dry M2, R2 Surrogate: Decachlorobiphenyl mg/kg dry Surrogate: Tetrachloro-meta-xylene mg/kg dry %RPD %RPD Limit Notes The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 11 of 15 UMP020834

35 88 Empire Drive St Paul, MN Tel: Fax: Bay West 5 Empire Drive Project: Project Number: Analytical Services J Georges Used Equipment Work Order #: St. Paul, MN Project Manager: Mr. Bill Lazarz Date Reported: 05/18/15 PERCENT SOLIDS - Quality Control Analyte Batch B5D General Preparation Spike Result RL MDL Units Level Source Result %REC Duplicate (B5D2911-DUP1) Source: Prepared & Analyzed: 04/29/15 %REC Limits % Solids 90.0 % %RPD %RPD Limit Notes Duplicate (B5D2911-DUP2) Source: Prepared & Analyzed: 04/29/15 % Solids 88.0 % Duplicate (B5D2911-DUP3) Source: Prepared & Analyzed: 04/29/15 % Solids 89.0 % The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 12 of 15 UMP020835

36 88 Empire Drive St Paul, MN Tel: Fax: Bay West Project: Analytical Services 5 Empire Drive Project Number: J Georges Used Equipment Work Order #: St. Paul, MN Project Manager: Mr. Bill Lazarz Date Reported: 05/18/15 R2 M3 M2 < dry NA MDL RL RPD LCS MS Notes and Definitions RPD/RSD exceeded the laboratory acceptance limit. See case narrative. The spike recovery value is unusable since the analyte concentration in the sample is disproportionate to the spike level. The associated blank spike recovery was acceptable. Matrix spike recovery was low, the associated blank spike recovery was acceptable. Less than value listed Sample results reported on a dry weight basis Not applicable. The %RPD is not calculated from values less than the reporting limit. Method Detection Limit Reporting Limit Relative Percent Difference Laboratory Control Spike = Blank Spike (BS) = Laboratory Fortified Blank (LFB) Matrix Spike = Laboratory Fortified Matrix (LFM) The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 13 of 15 UMP020836

37 88 Empire Drive St Paul, MN Tel: Fax: The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 14 of 15 UMP020837

38 88 Empire Drive St Paul, MN Tel: Fax: The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 15 of 15 UMP020838

39 88 Empire Drive St Paul, MN Tel: Fax: May 28, 2015 Mr. Bill Lazarz Bay West 5 Empire Drive St. Paul, MN Work Order Number: RE: Analytical Services Enclosed are the results of analyses for samples received by the laboratory on 05/15/15. If you have any questions concerning this report, please feel free to contact me. Results are not blank corrected unless noted within the report. Additionally, all QC results meet requirements unless noted. All samples will be retained by, unless consumed in the analysis, at ambient conditions for 30 days from the date of this report and then discarded unless other arrangements are made. All samples were received in acceptable condition unless otherwise noted. All test results and QC meet requirements of the 2003 NELAC standard. MDH (NELAP) Accreditation # Prepared by, LEGEND TECHNICAL SERVICES, INC Kevyn Kalland Client Manager I kkalland@legend-group.com The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. UMP020839

40 88 Empire Drive St Paul, MN Tel: Fax: Bay West Project: Analytical Services 5 Empire Drive Project Number: J Georges Used Equipment Work Order #: St. Paul, MN Project Manager: Mr. Bill Lazarz Date Reported: 05/28/15 ANALYTICAL REPORT FOR SAMPLES Sample ID Laboratory ID Matrix Date Sampled Date Received SS-75 (10'') Soil 05/15/15 12:40 05/15/15 14:05 SS-75 (24'') Soil 05/15/15 12:45 05/15/15 14:05 SS-76 (10'') Soil 05/15/15 12:55 05/15/15 14:05 SS-76 (24'') Soil 05/15/15 13:00 05/15/15 14:05 Shipping Container Information Default Cooler Temperature ( C): 1.7 Received on ice: Yes Temperature blank was present Received on ice pack: No Received on melt water: No Ambient: No Acceptable (IH/ISO only): No Custody seals: No Case Narrative: The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 2 of 9 UMP020840

41 88 Empire Drive St Paul, MN Tel: Fax: Bay West Project: Analytical Services 5 Empire Drive Project Number: J Georges Used Equipment Work Order #: St. Paul, MN Project Manager: Mr. Bill Lazarz Date Reported: 05/28/15 PCB 8082A Analyte Result RL MDL Units Dilution Batch Prepared Analyzed Method Notes SS-75 (10'') ( ) Soil Sampled: 05/15/15 12:40 Received: 05/15/15 14:05 Aroclor 1016 < mg/kg dry 1 B5E /19/15 05/24/15 EPA 8082A Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 Aroclor 1242 < mg/kg dry 1 Aroclor 1248 < mg/kg dry 1 Aroclor 1254 < mg/kg dry 1 Aroclor mg/kg dry 2 05/28/15 Surrogate: Decachlorobiphenyl % Surrogate: Tetrachloro-meta-xylene % SS-75 (24'') ( ) Soil Sampled: 05/15/15 12:45 Received: 05/15/15 14:05 05/24/15 Aroclor 1016 < mg/kg dry 1 B5E /19/15 05/24/15 EPA 8082A Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 Aroclor 1242 < mg/kg dry 1 Aroclor 1248 < mg/kg dry 1 Aroclor 1254 < mg/kg dry 1 Aroclor mg/kg dry 1 Surrogate: Decachlorobiphenyl % Surrogate: Tetrachloro-meta-xylene % SS-76 (10'') ( ) Soil Sampled: 05/15/15 12:55 Received: 05/15/15 14:05 Aroclor 1016 < mg/kg dry 1 B5E /19/15 05/24/15 EPA 8082A Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 Aroclor 1242 < mg/kg dry 1 Aroclor 1248 < mg/kg dry 1 Aroclor 1254 < mg/kg dry 1 Aroclor mg/kg dry 1 Surrogate: Decachlorobiphenyl % Surrogate: Tetrachloro-meta-xylene % SS-76 (24'') ( ) Soil Sampled: 05/15/15 13:00 Received: 05/15/15 14:05 Aroclor 1016 < mg/kg dry 1 B5E /19/15 05/24/15 EPA 8082A Aroclor 1221 < mg/kg dry 1 Aroclor 1232 < mg/kg dry 1 Aroclor 1242 < mg/kg dry 1 Aroclor 1248 < mg/kg dry 1 Aroclor 1254 < mg/kg dry 1 Aroclor 1260 < mg/kg dry 1 Surrogate: Decachlorobiphenyl % The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 3 of 9 UMP020841

42 88 Empire Drive St Paul, MN Tel: Fax: Bay West 5 Empire Drive Project: Project Number: Analytical Services J Georges Used Equipment Work Order #: St. Paul, MN Project Manager: Mr. Bill Lazarz Date Reported: 05/28/15 PCB 8082A Analyte Result RL MDL Units Dilution Batch Prepared Analyzed Method Notes SS-76 (24'') ( ) Soil Sampled: 05/15/15 13:00 Received: 05/15/15 14:05 Surrogate: Tetrachloro-meta-xylene % B5E /19/15 05/24/15 EPA 8082A The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 4 of 9 UMP020842

43 88 Empire Drive St Paul, MN Tel: Fax: Bay West 5 Empire Drive Project: Project Number: Analytical Services J Georges Used Equipment Work Order #: St. Paul, MN Project Manager: Mr. Bill Lazarz Date Reported: 05/28/15 PERCENT SOLIDS Analyte Result RL MDL Units Dilution Batch Prepared Analyzed Method Notes SS-75 (10'') ( ) Soil Sampled: 05/15/15 12:40 Received: 05/15/15 14:05 % Solids 87 % 1 SS-75 (24'') ( ) Soil Sampled: 05/15/15 12:45 Received: 05/15/15 14:05 % Solids 90 % 1 SS-76 (10'') ( ) Soil Sampled: 05/15/15 12:55 Received: 05/15/15 14:05 % Solids 83 % 1 SS-76 (24'') ( ) Soil Sampled: 05/15/15 13:00 Received: 05/15/15 14:05 B5E /22/15 05/22/15 B5E /22/15 05/22/15 B5E /22/15 05/22/15 % calculation % calculation % calculation % Solids 82 % 1 B5E /22/15 05/22/15 % calculation The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 5 of 9 UMP020843

44 88 Empire Drive St Paul, MN Tel: Fax: Bay West 5 Empire Drive Project: Project Number: Analytical Services J Georges Used Equipment Work Order #: St. Paul, MN Project Manager: Mr. Bill Lazarz Date Reported: 05/28/15 PCB 8082A - Quality Control Analyte Batch B5E EPA 3545 ASE Extraction Spike Result RL MDL Units Level Source Result %REC %REC Limits Blank (B5E1901-BLK1) Prepared: 05/19/15 Analyzed: 05/24/15 Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 < < < < < < mg/kg wet mg/kg wet mg/kg wet mg/kg wet mg/kg wet mg/kg wet < mg/kg wet Surrogate: Decachlorobiphenyl mg/kg wet Surrogate: Tetrachloro-meta-xylene mg/kg wet LCS (B5E1901-BS1) Prepared: 05/19/15 Analyzed: 05/24/15 Aroclor mg/kg wet Surrogate: Decachlorobiphenyl mg/kg wet Surrogate: Tetrachloro-meta-xylene mg/kg wet Matrix Spike (B5E1901-MS1) Source: Prepared: 05/19/15 Analyzed: 05/24/15 Aroclor mg/kg dry < Surrogate: Decachlorobiphenyl mg/kg dry Surrogate: Tetrachloro-meta-xylene mg/kg dry Matrix Spike Dup (B5E1901-MSD1) Source: Prepared: 05/19/15 Analyzed: 05/24/15 Aroclor mg/kg dry < Surrogate: Decachlorobiphenyl mg/kg dry Surrogate: Tetrachloro-meta-xylene mg/kg dry %RPD %RPD Limit Notes The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 6 of 9 UMP020844

45 88 Empire Drive St Paul, MN Tel: Fax: Bay West 5 Empire Drive Project: Project Number: Analytical Services J Georges Used Equipment Work Order #: St. Paul, MN Project Manager: Mr. Bill Lazarz Date Reported: 05/28/15 PERCENT SOLIDS - Quality Control Analyte Batch B5E General Preparation Spike Result RL MDL Units Level Source Result %REC Duplicate (B5E2207-DUP1) Source: Prepared & Analyzed: 05/22/15 %REC Limits % Solids 74.0 % %RPD %RPD Limit Notes Duplicate (B5E2207-DUP2) Source: Prepared & Analyzed: 05/22/15 % Solids 70.0 % The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 7 of 9 UMP020845

46 88 Empire Drive St Paul, MN Tel: Fax: Bay West Project: Analytical Services 5 Empire Drive Project Number: J Georges Used Equipment Work Order #: St. Paul, MN Project Manager: Mr. Bill Lazarz Date Reported: 05/28/15 Notes and Definitions < dry NA MDL RL RPD LCS MS Less than value listed Sample results reported on a dry weight basis Not applicable. The %RPD is not calculated from values less than the reporting limit. Method Detection Limit Reporting Limit Relative Percent Difference Laboratory Control Spike = Blank Spike (BS) = Laboratory Fortified Blank (LFB) Matrix Spike = Laboratory Fortified Matrix (LFM) The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 8 of 9 UMP020846

47 88 Empire Drive St Paul, MN Tel: Fax: The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 9 of 9 UMP020847

48 George s Used Equipment Removal Action Report Appendix B Field Notes UMP020848

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50 UMP020850

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52 Bay West LLC 651/ Empire Drive FAX 651/ St. Paul, Minnesota DAILY DIARY To be completed by Crew Leader Job Name Job No. UMore/Georges Used Equipment J Project Manager Bay West Crew Bill L Craig, Preston Personnel on Site (Client, Visitors, Bay West staff other than listed above) Date 6/15-6/19 _1 of 1 Detailed description of work performed: 6/15/15 Loaded up necessary equipment and went to site, Went through Health and Safety plan and tailgate meeting. Checked out equipment to make sure there was not any major damage. Removed brush and debris that was on grid SS-51 and SS-67 samples. Located the grids and marked them out. Started digging soil to stockpile for load out the following day. 6/16/15 Health and safety tail gate meeting completed. First truck showed up with a load of sand, placed it on the area that will not be excavated. Two additional trucks showed up and they were both loaded with the SS-51 and SS-67 grid area. Trucks were given a manifest to go to Vonco in Becker, MN. Began to load the SS-51 and SS-62 into drums based on the map grids. 12 drums were loaded, spoke to PM that the grids still need some additional soil to be removed, will bring additional drums the following day. First driver continued to run sand from the Umore pit, and two additional trucks began to run loads. Brought in 14 end dumps with sand. Then began to stock pile black dirt from the same pit, a total of 13 loads was brought in. Began to place three inches of black dirt on the west side of the previously excavated area in between loads. All orange fencing and stakes were removed from the site and wrapped up. Total loads were: Sand=14 Black Dirt=13 Due to the potential for severe weather overnight and into the morning poly was used to cover the black dirt as it would turn to mud if not covered and be difficult to do finishing work. 6/17/15 Picked up grass seed from Ramy turf in the morning, MNDOT native construction Arrived on-site and held health and safety tail gate meeting. Uncovered the black dirt pile and began to run sand. Checked the boundaries with GPS to verify. Began to build UMP020852

53 our 12 sand cap, also filled in the excavated areas and include 12 of sand on-top of that. 4 more drums were needed to excavate the remaining soil in SS-51 and SS-62. Drums were all moved onto the pad and labeled with PCB and Hazardous waste labels. Drums were then covered with poly. Additional black dirt was also brought in. total loads included: Sand=6 Black Dirt=4 The black dirt was covered in case there was additional rain overnight. 6/18/15 Went to look for waddles for erosion control in the morning, bought a roll of erosion control matting for the peak. Started getting sand right away in the morning. Arrived on-site and held health and safety tail gate meeting. Janet arrived on-site and discussed the parking barrier and erosion control onto the pad. We discussed using the trees cut down in the beginning of the site as a parking barrier and using the mulch to help control erosion onto the concrete pad, she agreed on the plan, also discussed this with the PM. Continued to get the area shaped and to final grade. Seeded the bermed areas. 6/19/14 Arrived on-site and had health and safety tail gate meeting. Completed seeding the entire excavated area and used dozer to track the seed in, birds had been eating the seed. Used a one roll of erosion control matting (8 x112.5). Covered the front entrance to the site and also the slope that was on the NE side of concrete pad. Used the mulch to create an erosion control barrier to help in the same area. Equipment was fueled up and site was buttoned up. Contacted PM so equipment could be called for pick up. Craig mobilized to a spill call and Preston went back to the shop to unload equipment and toolwatch. Waste Generated: Change in Conditions (if any): Sample Summary: Samples Taken: r Yes r No No. of Samples COC #: Sample Destination: Size and Type of Sample: Signature Date 6/23/15 PROJECT MANAGER/FILE DOCS#9287 UMP020853

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55 George s Used Equipment Removal Action Report Appendix C Weigh Tickets UMP020855

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