Activities during Reporting Period Activities completed during January, February, and March 2009 are summarized below.

Transcription

1 May 5, 2009 Mr. Ed Jones Washington State Department of Ecology Northwest Regional Office th Avenue SE Bellevue, Washington Re: Progress Report January through March 2009, Seattle, Washington Agreed Order No. DE 5296 Project No A-02 Dear Ed: This progress report summarizes activities conducted on the project for the period January through March This work is being completed per the referenced Agreed Order between and the Department of Ecology (Ecology). Activities during Reporting Period Activities completed during January, February, and March 2009 are summarized below. Remedial Investigation The following RI activities were completed during this reporting period: Submittal of Draft Phase I RI Field Program Results memorandum. This memorandum presented the proposed locations and completion intervals of the Phase II monitoring wells. Ecology provided comments on the proposed well locations in a letter dated February 24, Aspect Consulting, LLC (Aspect) met with Ecology on March 13, 2009 to resolve issues and finalize well locations and completion intervals. Submittal of Proposed Groundwater Monitoring for 1,4-Dioxane and Select Metals memorandum. In the memorandum, Art Brass proposed the additional analysis of dissolved copper, nickel, and zinc to the March 2009 groundwater sampling event for 19 water table interval wells, 8 shallow interval wells, and 9 intermediate interval wells. In an dated March 17, 2009, Ecology approved the proposed modification to the groundwater monitoring program with a request for some additional analyses. At Ecology s request, samples collected from water table monitoring wells MW-1 through MW-6 were to be analyzed for arsenic, barium, cadmium, lead, mercury, manganese, silver, and cyanide. Installation of Phase II monitoring wells: well clusters at MW-16, MW-17, MW-18, and MW-19. Well locations are provided in Figure 1 and well completion logs in Appendix A. 401 Second Avenue S, Suite 201 Seattle, WA Tel: (206) Fax: (206) a limited liability company

2 Washington State Department of Ecology May 5, 2009 Project No A-02 Groundwater monitoring was completed between March 23 and 30, Water level measurements are provided in Table 1. Figures 2, 3, and 4 depict groundwater contours for the water table, shallow, and intermediate intervals, respectively. Data from March 2009 are in the process of being validated by EcoChem, Inc. Validated data will be reported to Ecology in the next progress report. Validation of December 2008 groundwater data by EcoChem, Inc has been completed. Lab certificates and the EcoChem validation report are provided in Appendix B. Validated results are presented in Tables 2 and 3. Figures 5 through 9 depict groundwater concentrations of COCs. For monitoring well locations, the December value is presented in Figures 5 through 9. Previous results from groundwater grab samples are also presented on the figures. If multiple grab samples were collected within a given sampling interval, the highest reported value for that interval is depicted on the figure. Interim Action Measures The following activities were completed during this reporting period: Performance monitoring of the AS/SVE system in accordance with the draft Operation and Maintenance Plan, including: Monthly monitoring of air sparging and soil vapor extraction system operating parameters, including air flow rate, pressure, vacuum, and VOC/TCE concentration at each SVE well, vapor sump, trench, and off-gas treatment system; Monthly monitoring of pressure at soil vapor monitoring points using a micromanometer; Monitoring of TCE concentrations at soil vapor monitoring points around 220 Findlay and at points exhibiting positive pressure, using low-level detector tubes; Quarterly air sampling for VOCs by EPA Method TO-15 laboratory analysis from the treatment system influent and effluent; and Quarterly groundwater sampling for field parameters, water levels, and VOCs by EPA Method 8260B at 18 1 monitoring wells, in March Installation of a second sub-slab vapor monitoring point, 220F-SS2, inside the 220 Findlay building on February 10, Conducted indoor air sampling for VOCs by EPA Method TO-15 laboratory analysis inside the 220 Findlay building on February 12, The purpose of the sampling event was to observe impacts to indoor air quality while operating the adjacent air sparge system at maximum capacity. Air sparge wells 20, 21, 23, and 25 were temporarily turned on (3, 4, 9, and 10 remained off) and flows to operating air sparge 1 The 18 wells monitored to evaluate remediation performance are a subset of the 36 wells monitored at the site in March Page 2

3 Washington State Department of Ecology May 5, 2009 Project No A-02 wells were maximized at approximately 3 cubic feet per minute (cfm), for the period of February 6 to February 12, As part of the sampling event, vapor pressures and TCE concentrations were monitored at soil vapor monitoring points. Air sparge flow rates were returned to pre-sampling levels following the event. Submittal of the final Construction and Startup Report to Ecology on February 20, The air sparge system was turned off on March 13, 2009, approximately one week before quarterly groundwater sampling, so that groundwater sampling was not affected by active air sparging. The air sparge system will not be turned on until completion of AS/SVE system modifications, anticipated in April, due to vapor migration monitoring results inside the 220 Findlay building. Installation of wells for AS/SVE system modifications. Soil vapor extraction wells 3A, 4A, 5A, 6, 7, and air sparge well 28 were installed on March 17th and 18th, In accordance with the draft Operation and Maintenance Plan, this progress report includes interim performance monitoring data, comparison of the effectiveness of the interim measures with design goals, and recommendations to improve system effectiveness, where appropriate. Interim Performance Monitoring Data Monthly monitoring data for the interim action is summarized in Tables 4 through 14. Data from September 2008 through October 2008 reflects startup and optimization of the system, and is discussed in the final Construction and Startup Report submitted to Ecology on February 20, From October 2008 through March 2009, the system was operated without significant adjustment, with the exception of temporarily increasing air sparging flow rates for the indoor air sampling event inside the 220 Findlay building, and turning off the air sparging system on March 13, 2009 through the end of this reporting period to allow groundwater sampling and installation of the expanded system. Performance Observations and Effectiveness of Interim Action SVE Flowrate and Vacuum Soil vapor extraction flow rates and vacuums remained unchanged from those established during system startup and optimization. The minor variations in these parameters can be attributed to normal fluctuations in the system. In general, flow and vacuum at SVE-E is throttled back slightly to increase flow from other locations. SVE flows and vacuums are summarized in Tables 4 and 5, respectively. AS Flowrate and Pressure Air sparge flow rates and pressures remained largely unchanged from those established during system startup and optimization. In general, air sparge wells 3, 4, 9, 10, 20, 21, 23, and 25 remained off as a result of vapor migration monitoring and limited effectiveness of the SVE system in those areas. The remaining operating air sparge wells were maintained at approximately 1.5 cfm. Exceptions to this rule are AS-12 and AS-15. AS-12 experienced a buildup of pressure and reduction in flow in March, which may be attributable to fouling of the well screen. AS-15 has experienced difficulty maintaining flow in between monthly monitoring events; during each event, flow Page 3

4 Washington State Department of Ecology May 5, 2009 Project No A-02 was adjusted to 1.5 cfm but had dropped to 0 cfm by the next event. AS flows and pressures are summarized in Tables 6 and 7, respectively. AS/SVE Balance The design minimum ratio for SVE to AS flow rates in each area of the facility was 3:1 in areas around (red, yellow, and blue zones) and 10:1 around the 220 Findlay building (green zone). These ratios, summarized in Table 8, were met or exceeded in each monitoring event. TCE Removal Individual VOC/TCE concentrations at each SVE well, vapor sump, and trench have gradually showed a decline since the end of startup and optimization of the system. Individual concentrations are summarized in Table 9. The rate of mass removal of TCE by the treatment system has also decreased since startup and optimization. At the end of startup, 1.5 ppmv TCE was being removed by the system. From November 2008 through March 2009, the concentration of TCE removed has averaged approximately 0.5 ppmv. Mass removal has averaged approximately 3 pounds of TCE per month since the end of October TCE mass removal is summarized in Table 10. GAC Treatment Effectiveness The GAC units are effectively removing TCE from the vapor stream. From November 2008 through March 2009, 0.5 ppmv was entering the lead unit and TCE was not detected in the effluent until March 2009 (as measured with a detector tube with a ppmv detection limit). In March 2009, measurable concentrations of VOCs were detected in the effluent. Subsequent quarterly air sampling for VOCs by EPA Method TO-15 laboratory analysis from the treatment system influent and effluent indicated there was no TCE detected in the effluent vapor stream. However, trans- and cis-dce were detected in the effluent vapor stream, which may explain the VOCs being detected in the effluent during monthly monitoring using detection tubes. Modifications to the monitoring program to address DCE interference are discussed in Recommendations for System Improvement, below. The presence of trans- and cis-dce does not increase the CCEF calculation for the SVE stream, so the performance criteria for GAC changeout were not recalculated. Influent and effluent TCE concentrations measured on a monthly basis using detection tubes are summarized in Table 10, quarterly results using SUMMA canisters are summarized in Table 11. SVE Condensate No measurable condensation has been collected during the operation of the treatment system. Evidence of condensation in the SVE piping was noted in the final Construction and Startup Report; however, system performance has not been affected, so corrective actions have not been implemented. Collection of condensate is summarized in Table 10. Vapor Migration Monitoring Soil vapor pressures and TCE concentrations remained similar to those recorded at the end of system startup and optimization, with the exception of the results following indoor air sampling inside the 220 Findlay building (discussed below). In general, MW-12 continued to exhibit Page 4

5 Washington State Department of Ecology May 5, 2009 Project No A-02 positive pressure and the original sub-slab monitoring point inside the 220 Findlay building, 220F-SS1, failed to show that the SVE system was creating a vacuum beneath the slab. Vapor pressure and TCE concentrations from vapor migration monitoring are summarized in Tables 12 and 13, respectively. Groundwater Monitoring Groundwater monitoring results are detailed in the Remedial Investigation section. A figure showing the change in TCE concentrations at monitoring wells in the treatment area is attached (Figure 10). In general, the interim action is having a positive effect by reducing groundwater TCE concentrations in all monitoring wells. In areas of consistently-operating air sparging wells (i.e., beneath the Art Brass facility), TCE concentrations were reduced from 75 percent (at MW-3) to 95 percent (at MW-4). Downgradient of the active air sparging area, concentration reductions ranged from 15 percent (at MW-8) to 58 percent (at MW-7). Expansion of the AS/SVE system to allow increased sparging downgradient of the Art Brass facility was begun in March 2009 in accordance with the Construction and Startup Report. Dissolved oxygen and oxidation-reduction potential (Eh) parameters are summarized in Table 14. A slight increase in dissolved oxygen was noted in MW-1, MW-4, MW-5, and MW-7 and a slight increase in oxidation-reduction potential was noted in all of the treatment area wells. The expected effect of these conditions on the groundwater includes lower dissolved concentrations of metals (iron and manganese) that are more soluble under reducing conditions, a potential increase in the aerobic degradation of vinyl chloride, and a potential decrease in the anaerobic degradation of TCE to cis-dce. Effects of air sparging on geochemical conditions will be evaluated in more detail in the next performance evaluation report, when data for redox-sensitive metals and monitored natural attenuation parameters will be available both before and after system operation began. Results of Indoor Air Sampling at 220 Findlay On February 12, 2009 indoor air samples were collected inside the 220 Findlay building to observe impacts to indoor air quality while operating the adjacent air sparge system at maximum capacity. The results of the sampling event are as follows: The maximum achievable flow rate, evenly distributed among operating AS wells, was approximately 3 cfm. Positive pressure was observed in both sub-slab monitoring points inside the building (Table 12). TCE concentrations in both sub-slab monitoring points inside the building increased as compared to baseline. Air sampling results for 220 Findlay are summarized in Table 15. TCE concentrations increased in indoor air as compared to baseline. Indoor air sampling results are summarized in Table 15. Page 5

6 Washington State Department of Ecology May 5, 2009 Project No A-02 Pressure and TCE concentrations increased as compared to baseline in a number of soil vapor monitoring points (Tables 12 and 13). These results indicate that the existing SVE system is not able to mitigate the effects of the AS system on indoor air quality at 220 Findlay when actively sparging around the building. Expansion of the SVE system, as described in the final Construction and Startup Report may address this issue; if not, a vapor mitigation system will be installed inside the 220 Findlay building. Recommendations for System Improvement Overall, the interim action is having a positive effect by reducing groundwater TCE concentrations in the groundwater in the source area. Performance of the system may be improved if all AS wells can be operated and if flowrates are increased. In order to increase the sparging, impacts to indoor air quality at 220 Findlay must be mitigated by expanding the existing SVE system or providing a separate vapor mitigation system for the 220 Findlay building. Recommended actions to improve the treatment system include: Complete the modifications to the AS/SVE system recommended in the final Construction and Startup Report. Conduct startup and optimization of the modified AS/SVE system and reevaluate the effectiveness of the system in capturing air sparging vapors. If negative pressures are not maintained beneath the 220 Findlay building while operating the expanded system, turn off air sparging in this area, verify that pressures beneath the building and surrounding vapor points are not positive, and install a subslab mitigation system at 220 Findlay. Inspect AS-12 and AS-15 after re-starting the modified AS/SVE system and redevelop if necessary to increase flow at these wells. Perform monthly sampling of GAC effluent concentrations using SUMMA canisters submitted for TO-15 analysis, to evaluate breakthrough of TCE. Vapor Intrusion The following activities were completed during this reporting period: Submitted letter to Ecology (dated March 13, 2009) regarding plans to address vapor intrusion (VI) issues. Location 10 (218½ S Findlay St) Evaluation of December 2008 monitoring results indicated that VI is a potential concern. Mailed access request letter to property owner on March 13, Locations (5602, 5606, & nd Ave S) Evaluation of December 2008 monitoring results indicated that VI is a potential concern. There is a new, apparently commercial building at 5602 that is currently unfinished and unoccupied. Following review of information provided by Ecology on PSC s Tier 3 sampling at these 3 addresses in 2005, Aspect concluded that indoor air at 5606 and 5610 need not be resampled at this time. Ecology concurred, and recommended that they be tentatively Page 6

7 Washington State Department of Ecology May 5, 2009 Project No A-02 scheduled for indoor air sampling in December 2010, with re-evaluation of groundwater concentrations as that date approaches. Locations 17 and 19 (222 S Orcas St and 214 S Findlay St) Evaluation of December 2008 monitoring results indicated that VI is a potential concern. Mailed access request letters to property owners on March 13, Received signed access agreements from property owners. Location 11 (305, 307, & 317 S Lucile St) Evaluation of December 2008 monitoring results indicated that VI is a potential concern. Aspect confirmed that the buildings at 307 and 317 are unoccupied, and the occupied trailer at 317 is on wheels (no soil vapor pathway). Mailed 305 access request letter to property owner on March 24, Property owner says he has spoken with the tenant and has decided (with tenant s concurrence) not to grant access for sampling. Evaluated March groundwater monitoring results with respect to VI considerations, in accordance with the requirements of the Groundwater Monitoring Plan and using the revised IPIMALs. Evaluation results do not indicate the need for additional Tier 3 assessments (beyond those previously triggered by the December 2008 results, as noted above). The completed evaluation worksheets are attached as Appendix C in the order in which the corresponding buildings are listed in Table 5 of the Groundwater Monitoring Plan. Groundwater Monitoring The second round of RI quarterly groundwater monitoring was completed (described above). Groundwater monitoring was completed between March 23 and 30, Water level measurements are provided in Table 1. Figures 2, 3, and 4 depict groundwater contours for the water table, shallow, and intermediate intervals, respectively. Chemical data from the monitoring event are currently in the process of being validated by EcoChem, Inc. Public Communications The project website was updated with an electronic copy of the previous progress report. No other public communications were completed during this period. Anticipated Work in the Upcoming Quarter Work anticipated to be performed during the next progress reporting period (April through July 2009) is summarized below. Remedial Investigation The following RI activities are anticipated to be performed during the next reporting period: Completion of the third round of quarterly groundwater monitoring. We anticipate completing this work in June Validation of March 2009 groundwater data by EcoChem, Inc. Validated data will be reported to Ecology in the next progress report. Page 7

8 Washington State Department of Ecology May 5, 2009 Project No A-02 Submittal of validated metals results from the March 2009 monitoring round to Ecology in June, prior to the next progress report. In that submittal, Art Brass will propose future groundwater monitoring for metals. Completion of groundwater grab sampling as a follow on to historical research outlined in Section 10.6 of the RI Work Plan. Interim Action Measures The following interim measure activities are anticipated to be performed during the next reporting period: Complete construction of the recommended modifications to the AS/SVE system, including a mitigation system at 220 Findlay if necessary based on monitoring data. Submission of the final Operation and Maintenance Plan, including as-built information for the modified AS/SVE system, after startup and optimization is complete. Performance monitoring of the AS/SVE system in accordance with the draft Operation and Maintenance Plan and the recommendations provided above, including: Monthly monitoring of air sparging and soil vapor extraction system operating parameters, including air flow rate, pressure, vacuum, and VOC/TCE concentrations at each SVE well, vapor sump, trench, and off-gas treatment system. System monitoring will be conducted weekly for at least two weeks after the AS/SVE system modifications are completed to evaluate and optimize the modified system; Monthly monitoring of pressure at soil vapor monitoring points using a micromanometer; Monitoring of TCE concentrations at soil vapor monitoring points around 220 Findlay and at points exhibiting positive pressure, using low-level detector tubes; Evaluation and possible maintenance of wells AS-12 and AS-15, to improve air flows; Monthly air sampling for VOCs by EPA Method TO-15 laboratory analysis from the treatment system effluent; Quarterly air sampling for VOCs by EPA Method TO-15 laboratory analysis from the treatment system influent; and Quarterly groundwater sampling for field parameters, water levels, and VOCs by EPA Method 8260B at 18 monitoring wells, in June Vapor Intrusion We anticipate conducting the following VI activities during the next reporting period: Page 8

9 Washington State Department of Ecology May 5, 2009 Project No A-02 Submit follow-up access request letter for Location 10. If signed access agreement is obtained, proceed with building inspection and location-specific Tier 3 SAP development. Proceed with building inspections and Tier 3 SAP development at Locations 17 and 19. Submit a letter to Ecology delineating a draft process for depressurization system shutdown at Locations A2 through A9. Address Ecology comments and proceed with the shutdown process. After the depressurization system shutdown process is approved, revise the VI Assessment Work Plan, VI IM&M Work Plan, and Groundwater Monitoring Plan to reflect recent changes. Groundwater Monitoring The third round of RI quarterly groundwater monitoring will be completed (described above). Public Communications No public communications are anticipated in the next quarter. The next progress report, which will summarize activities completed from April through June, will be submitted on or before August 7, If you have any questions or comments regarding this report or the project, please call at your earliest convenience. Sincerely, Aspect consulting, LLC Doug Hillman, LHG Principal Hydrogeologist dhillman@aspectconsulting.com Page 9

10 Washington State Department of Ecology May 5, 2009 Project No A-02 Attachments: Table 1 Water Level Measurements Table 2 Validated December 2008 Groundwater Quality Data Monitoring Well Results Table 3 Validated December 2008 Groundwater Quality Data Groundwater Grab Samples Table 4 SVE System Parameters - Flow Rate Table 5 SVE System Parameters - Vacuum Table 6 AS System Parameters - Flow Rate Table 7 AS System Parameters - Pressure Table 8 AS:SVE Flow Ratio Table 9 SVE System Parameters - TCE Concentrations Table 10 TCE Mass Removal and Condensate Monitoring Table 11 Quarterly Off-Gas Monitoring Using SUMMA Canisters Table 12 Soil Vapor Migration Monitoring - Pressure Table 13 Soil Vapor Migration Monitoring - TCE Concentration Table 14 Comparison of Dissolved Oxygen and Oxidation-Reduction Potential Table Findlay Air Sampling Results Figure 1 Exploration Location Map Figure 2 Groundwater Contour Map, Water Table Interval March 2009 Figure 3 Groundwater Contour Map, Shallow Interval March 2009 Figure 4 Groundwater Contour Map, Intermediate Interval March 2009 Figure 5 Tetrachloroethene (PCE) Occurrence in Groundwater through December 2008 Results Figure 6 Trichloroethene (TCE) Occurrence in Groundwater through December 2008 Results Figure 7 Cis-1,2-Dichloroethene (DCE) Occurrence in Groundwater through December 2008 Results Figure 8 Vinyl Chloride Occurrence in Groundwater through December 2008 Results Figure 9 1,4-Dioxane Occurrence in Groundwater through December 2008 Results Figure 10 TCE Concentrations in Source Area Monitoring Wells Appendix A Boring Logs Appendix B EcoChem Validation Report and Laboratory Certificates of Analyses for December 2008 Data Appendix C VI Evaluation Worksheets using March 2009 Groundwater Monitoring Results cc: Mike Merryfield,, Inc. William Joyce, Salter Joyce Ziker Tong Li, Groundwater Solutions with link to electronic copy on project website: Janet Knox, Pacific Groundwater Group Peter Jewett, Farallon Consulting Bill Carroll, Arrow Environmental Bill Beck, PSC V:\ \Progress Reports\2009 Q1\ABP Progress Report_Jan-Mar09.doc Page 10

11 Table 1 - Water Level Measurements Well ID Date of Installation PMW-1 6/24/2006 MW-1 MW-2 MW-3 MW-4 MW-5 10/5/ /5/ /5/ /5/2005 6/24/2006 MW-6 6/24/2006 MW-6-30 MW-7 MW-8 3/11/2008 3/18/2008 5/8/2007 in in in in Top of Casing Ground Level Measurement Date 10/18/ /29/ /30-8/1/ /15/08 flowing /16-12/18/08 flowing /23/ /23-3/30/ Well ID Date of Installation in in in in in in 11/17/2008 3/18/2008 5/9/2007 5/9/2007 3/11/2008 3/17/2008 3/18/2008 3/17/ /3/2008 in in in in in in in in Top of Casing Ground Level Measurement Date 10/18/ /29/ /30-8/1/ /15/ /16-12/18/ /23/ /23-3/30/ Well ID Date of Installation 3/18/2009 3/16/2009 in in in 3/21/2009 3/21/2009 in in in 3/17/2009 3/17/2009 3/18/2009 3/18/2009 in in in Top of Casing Ground Level Measurement Date 10/18/ /29/ /30-8/1/ /15/ /16-12/18/ /23/ /23-3/30/ Well ID Date of Installation MW /12/2008 MW-16 MW MW /16/2009 PSC-CG in MW-8-70 PSC-CG in MW-9 PSC-CG-138-WT 3/7/2002 in MW-10 MW PSC-CG /7/2002 in MW-11 MW PSC-CG /7/2002 in Top of Casing Ground Level Measurement Date 10/18/ /29/ /30-8/1/ /15/ /16-12/18/ /23/ /23-3/30/ Notes For the December 2008 groundwater monitoring event, the air sparging component of the remediation system was on. This has influenced some of the water levels in wells located within or near the facility. 1 Based on data available from surrounding water table wells, the water level measured at PZ-1 appears anomalous. The piezometer will be redeveloped and water levels will be reassessed during the May area-wide water level measurement event. MW PZ-1 3/17/2009 PSC-CG in MW-12 MW MW MW PSC-CG-142-WT 3/13/2002 in MW-13 PSC-CG /13/2002 in MW-14 AB-CG /18/2008 in MW-15 MW in in in PSC-CG-143-WT in PSC-CG in Aspect Consulting 5/5/09 V:\ \Progress Reports\2009 Q1\Tables1-3 Table 1 Page 1 of 1

12 Table 2 - Validated December 2008 Groundwater Quality Data - Monitoring Well Results Chemical Name Water Table Interval Groundwater Cleanup Level Shallow & Intermediate Interval Groundwater Cleanup Level MW-01 12/18/08 MW-02 12/18/08 MW-03 12/17/08 MW-04 12/17/08 MW-05 12/17/08 Metals Dissolved Chromium in ug/l U 1 U 1 U 1 U 5 U 0.5 U Dissolved Copper in ug/l Dissolved Nickel in ug/l , , Dissolved Zinc in ug/l U Total Chromium in ug/l U 1 U 1 U U Total Copper in ug/l Total Nickel in ug/l , , Total Zinc in ug/l Volatile Organic Compounds 1,1,1-Trichloroethane in ug/l U 1 U 1 U 1 U 1 U 0.2 U 0.2 U 1 U 1 U 1 U 1 U 1 U 0.2 U 1 U 0.2 U 1,1-Dichloroethane in ug/l U U U U 1,1-Dichloroethene in ug/l U 1 U 1 U 1 U 1 U 0.2 U U 1 U U 1 U 0.2 U U 1,2-Dichloroethane (EDC) in ug/l U 1 U 1 U 1 U 1 U 0.2 U 1 1 U 1 U 1 U U 1 U 0.2 U Chloroethane in ug/l U 1 U 1 U 1 U 1 U 0.2 U 0.2 U 1 U 1 U 1 U 1 U 1 U 0.2 U 1 U 0.2 U cis-1,2-dichloroethene in ug/l U U U Tetrachloroethene (PCE) in ug/l U 1 U 1 U 1 U 1 U 0.2 U 0.2 U 1 U 1 U 1 U 1 U 1 U 0.2 U 1 U 0.2 U trans-1,2-dichloroethene in ug/l , U U 1 U 0.2 U U U 1 U 0.2 U U Trichloroethene (TCE) in ug/l , U , U U Vinyl chloride in ug/l U 1 U 1 U 1 U 1 U 0.2 U U U 1 U 0.2 U Total Chlorinated Ethenes in ug/l ND ND 3.56 ND Semivolatiles 1,4-Dioxane in ug/l U 2 U 2 U U U 2 U MW-06 12/18/08 MW /18/08 MW /18/08 MW-07 12/17/08 MW-08 12/16/08 MW /16/08 MW /16/08 MW /16/08 MW-09 12/17/08 MW-10 12/17/08 Aspect Consulting 5/5/09 V:\ \Progress Reports\2009 Q1\Tables1-3 Table 2 Page 1 of 2

13 Table 2 - Validated December 2008 Groundwater Quality Data - Monitoring Well Results Chemical Name Water Table Interval Groundwater Cleanup Level Shallow & Intermediate Interval Groundwater Cleanup Level Metals Dissolved Chromium in ug/l Dissolved Copper in ug/l Dissolved Nickel in ug/l Dissolved Zinc in ug/l Total Chromium in ug/l Total Copper in ug/l Total Nickel in ug/l Total Zinc in ug/l Volatile Organic Compounds 1,1,1-Trichloroethane in ug/l ,1-Dichloroethane in ug/l ,1-Dichloroethene in ug/l ,2-Dichloroethane (EDC) in ug/l Chloroethane in ug/l cis-1,2-dichloroethene in ug/l Tetrachloroethene (PCE) in ug/l trans-1,2-dichloroethene in ug/l ,400 Trichloroethene (TCE) in ug/l Vinyl chloride in ug/l Total Chlorinated Ethenes in ug/l Semivolatiles 1,4-Dioxane in ug/l MW-11 12/18/08 MW /18/08 MW-12 12/17/08 MW-13 12/17/08 MW-14 12/17/08 MW-15 12/17/08 PMW-01 12/18/08 PSC-CG /16/08 PSC-CG-138- WT 12/16/08 PSC-CG /16/08 PSC-CG /16/08 PSC-CG-142- WT 12/16/08 PSC-CG /16/08 AB-CG /17/ U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 1 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U U U U 0.2 U 0.2 U 0.2 U U 0.2 U U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U U 0.2 U 0.2 U 0.2 U 1 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U U 0.2 U 0.2 U 0.2 U 1 U 0.2 U 0.2 U 0.2 U U 0.2 U 0.2 U U 0.2 U U U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 1 U 0.2 U U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U U 0.2 U U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U U U U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U U 0.2 U 0.2 U 0.2 U 1 U 0.2 U 0.2 U 0.2 U U 0.2 U 0.2 U ND ND 0.01 ND ND ND 2 U U 2 U 39 2 U 2 U 2 U PSC-CG-143- WT 12/16/08 Notes Concentrations in bold and shaded cells indicate value exceed designated cleanup level. The Water Table Interval is from 0 to 20 feet below ground surface (bgs). The Shallow Interval is from 20 to 40 feet bgs and the Intermediate Interval is 40 feet bgs and below. Groundwater grab samples from SPO borings were not sampled for metals. J - Analyte was positively identified. The reported result is an estimate. U - Analyte was not detected at or above the reported result. Aspect Consulting 5/5/09 V:\ \Progress Reports\2009 Q1\Tables1-3 Table 2 Page 2 of 2

14 Table 3 - Validated December 2008 Groundwater Quality Data - Groundwater Grab Samples Chemical Name Water Table Interval Groundwater Cleanup Level Shallow & Intermediate Interval Groundwater Cleanup Level SPO-15 (9-12) 12/01/08 SPO-15 (19-22) 12/01/08 SPO-15 (25-28) 12/01/08 SPO-15 (31-34) 12/01/08 SPO-15 (37-40) 12/01/08 Volatile Organic Compounds 1,1,1-Trichloroethane in ug/l U 0.2 U 0.6 U 0.6 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 1,1-Dichloroethane in ug/l U 0.2 U 0.2 U ,1-Dichloroethene in ug/l U U 0.6 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U U 1,2-Dichloroethane (EDC) in ug/l U 0.2 U U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U U Chloroethane in ug/l U 0.2 U 0.6 U U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U cis-1,2-dichloroethene in ug/l U 0.2 U 0.2 U U Tetrachloroethene (PCE) in ug/l U 0.2 U 0.6 U 0.6 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U trans-1,2-dichloroethene in ug/l , U 0.6 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U U Trichloroethene (TCE) in ug/l U 0.2 U U 0.2 U Vinyl chloride in ug/l U U 0.2 U 0.2 U Total Chlorinated Ethenes in ug/l Semivolatiles 1,4-Dioxane in ug/l U SPO-15 (43-46) 12/01/08 SPO-15 (55-58) 12/01/08 SPO-15 (61-64) 12/01/08 SPO-15 (67-70) 12/01/08 SPO-16 (13-16) 12/04/08 SPO-16 (19-22) 12/04/08 SPO-16 (25-28) 12/04/08 SPO-16 (31-34) 12/04/08 SPO-16 (37-40) 12/04/08 Chemical Name Water Table Interval Groundwater Cleanup Level Shallow & Intermediate Interval Groundwater Cleanup Level SPO-16 (43-46) 12/04/08 SPO-16 (61-64) 12/04/08 SPO-16 (67-70) 12/04/08 SPO-17 (9-12) 12/03/08 Volatile Organic Compounds 1,1,1-Trichloroethane in ug/l U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 1 U 0.2 U 0.2 U 0.2 U 1,1-Dichloroethane in ug/l U 0.2 U 0.2 U 0.2 U U 1,1-Dichloroethene in ug/l U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U U 0.2 U 1,2-Dichloroethane (EDC) in ug/l U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U U 0.2 U Chloroethane in ug/l U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U U 0.2 U 0.2 U 0.2 U cis-1,2-dichloroethene in ug/l U 0.2 U U U 0.2 U Tetrachloroethene (PCE) in ug/l U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 1 U 0.2 U 0.2 U 0.2 U trans-1,2-dichloroethene in ug/l , U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U U 0.2 U 0.2 U 0.2 U Trichloroethene (TCE) in ug/l U 0.2 U U 0.2 U , Vinyl chloride in ug/l U 0.2 U 0.2 U 0.2 U 0.2 U Total Chlorinated Ethenes in ug/l ND ND 0.03 ND Semivolatiles 1,4-Dioxane in ug/l SPO-17 (19-22) 12/03/08 SPO-17 (31-34) 12/03/08 SPO-17 (37-40) 12/03/08 SPO-17 (43-46) 12/03/08 SPO-17 (49-52) 12/03/08 SPO-17 (55-58) 12/03/08 SPO-17 (63-66) 12/03/08 SPO-17 (71-74) 12/03/08 Aspect Consulting 5/5/09 V:\ \Progress Reports\2009 Q1\Tables1-3 Table 3 Page 1 of 2

15 Table 3 - Validated December 2008 Groundwater Quality Data - Groundwater Grab Samples Chemical Name Water Table Interval Groundwater Cleanup Level Shallow & Intermediate Interval Groundwater Cleanup Level Volatile Organic Compounds 1,1,1-Trichloroethane in ug/l ,1-Dichloroethane in ug/l ,1-Dichloroethene in ug/l ,2-Dichloroethane (EDC) in ug/l Chloroethane in ug/l cis-1,2-dichloroethene in ug/l Tetrachloroethene (PCE) in ug/l trans-1,2-dichloroethene in ug/l ,400 Trichloroethene (TCE) in ug/l Vinyl chloride in ug/l Total Chlorinated Ethenes in ug/l Semivolatiles 1,4-Dioxane in ug/l SPO-18 (9-12) 12/05/08 SPO-18 (19-22) 12/05/08 SPO-18 (31-34) 12/05/08 SPO-18 (37-40) 12/05/08 SPO-18 (43-46) 12/05/08 SPO-18 (49-52) 12/05/08 SPO-18 (55-58) 12/05/08 SPO-18 (63-66) 12/05/ U 0.2 U 0.2 U 0.2 U 0.2 U 1 U 1 U 1 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U U 0.2 U 0.2 U U 0.2 U U 1 U 0.2 U 0.2 U U 0.2 U 0.2 U 0.2 U U 1 U 1 U 0.2 U 0.2 U U 0.2 U 0.2 U U 1 U 1 U 1 U 0.2 U 0.2 U U 0.2 U U 0.2 U U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 1 U 1 U 1 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U U 1 U 0.2 U 0.2 U U 0.2 U 0.2 U 460 3,600 2,300 1,800 11, U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U U 0.2 U ND ND ND SPO-18 (71-74) 12/05/08 SPO-19 (9-12) 12/02/08 SPO-19 (19-22) 12/02/08 SPO-19 (31-34) 12/02/08 SPO-19 (37-40) 12/02/08 Chemical Name Water Table Interval Groundwater Cleanup Level Shallow & Intermediate Interval Groundwater Cleanup Level Volatile Organic Compounds 1,1,1-Trichloroethane in ug/l ,1-Dichloroethane in ug/l ,1-Dichloroethene in ug/l ,2-Dichloroethane (EDC) in ug/l Chloroethane in ug/l cis-1,2-dichloroethene in ug/l Tetrachloroethene (PCE) in ug/l trans-1,2-dichloroethene in ug/l ,400 Trichloroethene (TCE) in ug/l Vinyl chloride in ug/l Total Chlorinated Ethenes in ug/l Semivolatiles 1,4-Dioxane in ug/l SPO-19 (43-46) 12/02/08 SPO-19 (49-52) 12/02/08 SPO-19 (55-58) 12/02/08 SPO-19 (63-66) 12/02/08 SPO-19 (71-74) 12/02/08 SPO-20 (9-12) 12/01/08 SPO-20 (19-22) 12/01/08 SPO-20 (31-34) 12/01/ U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U U U 0.2 U 0.2 U U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U U 0.2 U U 0.2 U ND ND ND SPO-20 (37-40) 12/01/08 SPO-20 (43-46) 12/01/08 SPO-20 (49-52) 12/01/08 SPO-20 (55-58) 12/02/08 SPO-20 (63-66) 12/02/08 SPO-20 (71-74) 12/02/08 Aspect Consulting 5/5/09 V:\ \Progress Reports\2009 Q1\Tables1-3 Table 3 Page 2 of 2

16 Table 4 - SVE System Parameters - Flow Rate SVE Flow Rate (cfm) SVE-1 SVE-2 MW-1 MW-2 SVE-A SVE-B Red Total MW-4 SVE-C SVE-D Yellow Total MW-3 MW-5 SVE-E SVE-F Blue Total SVE-G MW-7 Green Total Combined - Stack 9/4/ /5/ /8/ /9/ /10/ /11/ /19/ /25/ /2/ /31/2008 NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA /5/ NA NA 13 2 NA NA NA NA 5 NA /9/ /5/ /6/ Notes: (1) SVE system startup on 9/4/2008 (2) AS system startup on 9/15/2008 (3) NA - SVE flows could not be measured on 10/31 due to heavy rain and condensate affecting hot-wire anemometer (4) Combined air flow rate is calculated using the vacuum recorded before the blower and the blower curve Aspect Consulting LLC 5/5/09 V:\ \Progress Reports\2009 Q1\Tables4-9 Table 4 Page 1 of 1

17 Table 5 - SVE System Parameters - Vacuum SVE Vacuum (inches water column) MW-1 MW-2 SVE-1 SVE-2 SVE-A SVE-B MW-4 SVE-C SVE-D MW-3 MW-5 Average Before KO Tank Before Blower 9/4/ /5/ /8/ /9/ /10/ /11/ /19/ /25/ /2/ /31/ /5/ /9/ /5/ /6/ SVE-E SVE-F MW-7 SVE-G Notes: (1) SVE system startup on 9/4/2008 (2) AS system startup on 9/15/2008 Aspect Consulting LLC 5/5/09 V:\ \Progress Reports\2009 Q1\Tables4-9 Table 5 Page 1 of 1

18 Table 6 - AS System Parameters - Flow Rate AS Flow Rate (cfm) AS-1 AS-2 AS-3 AS-4 AS-5 AS-6 AS-7 AS-8 AS-27 Red Total AS-9 AS-10 AS-11 AS-12 AS-13 AS-14 Yellow Total AS-15 AS-16 AS-17 AS-18 AS-19 AS-22 AS-24 AS-26 Blue Total AS-20 AS-21 AS-23 AS-25 Green Total After Compressor Cycle /4/ /5/ /8/ /9/ /10/ /11/ /19/ /25/ off off off off /2/ off off off off off off off off /31/ off off off off off off off off /5/ off off off off off off off off 0 4 1/9/ off off off off off off off off 0 8 2/5/ off off off off off off off off 0 6 3/6/ off off off off off off off off 0 6 Notes: (1) SVE system startup on 9/4/2008 (2) AS system startup on 9/15/2008 (3) For the period of February 6 to February 12, 2009 air sparge wells 20, 21, 23, and 25 were turned on and flows to operating air sparge wells were maximized at approximately 3 cfm as part of the indoor air sampling at 220 Findlay (4) AS-15 has experienced difficulty maintaining flow in between monthly monitoring events from January to March; during each event, flow was adjusted to 1.5 cfm but dropped to 0 cfm by the next event Aspect Consulting LLC 5/5/09 V:\ \Progress Reports\2009 Q1\Tables4-9 Table 6 Page 1 of 1

19 Table 7 - AS System Parameters - Pressure AS Pressure (inches water column) AS-1 AS-2 AS-3 AS-4 AS-5 AS-6 AS-7 AS-8 AS-27 AS-9 AS-10 AS-11 AS-12 AS-13 After Compressor Cycle /4/ /5/ /8/ /9/ /10/ /11/ /19/2008 NR 9.5 NR NR NR 10 NR 11 NR NR NR NR NR NR NR NR NR NR NR 11 NR NR NR NR NR 23 9/25/ off off off off /2/ off off off off off off off off /31/ off off off off off off off off /5/ off off off off off off off off 24 1/9/ off off off off off off off off 24 2/5/ off off off off off off off off 20 3/6/ off off off off off off off off 21 AS-14 AS-15 AS-16 AS-17 AS-18 AS-19 AS-22 AS-24 AS-26 AS-20 AS-21 AS-23 AS-25 Notes: (1) SVE system startup on 9/4/2008 (2) AS system startup on 9/15/2008 (3) NR - The AS pressures were only recorded for Cycle 4 on 9/19. Aspect Consulting LLC 5/5/09 V:\ \Progress Reports\2009 Q1\Tables4-9 Table 7 Page 1 of 1

20 Table 8 - AS:SVE Flow Ratio Cycle 1 Flow Ratios Cycle 2 Flow Ratios Yellow Blue Green Yellow Blue Green Red AS:SVE AS:SVE AS:SVE AS:SVE Red AS:SVE AS:SVE AS:SVE AS:SVE 9/4/2008 0% 0% 0% 0% 0% 0% 0% 0% 9/5/2008 0% 0% 0% 0% 0% 0% 0% 0% 9/8/2008 0% 0% 0% 0% 0% 0% 0% 0% 9/9/2008 0% 0% 0% 0% 0% 0% 0% 0% 9/10/2008 0% 0% 0% 0% 0% 0% 0% 0% 9/11/2008 0% 0% 0% 0% 0% 0% 0% 0% 9/19/2008 3% 3% 3% 3% 3% 3% 3% 3% 9/25/2008 3% 4% 5% 2% 1% 2% 5% 2% 10/2/2008 5% 7% 8% 0% 3% 4% 8% 0% 10/31/2008 NA NA NA NA NA NA NA NA 12/5/2008 NA NA NA NA NA NA NA NA 1/9/2009 2% 1% 1% 0% 1% 1% 3% 0% 2/5/2009 3% 2% 1% 0% 2% 1% 2% 0% 3/6/2009 2% 2% 2% 0% 1% 0% 3% 0% Cycle 3 Flow Ratios Cycle 4 Flow Ratios Yellow Blue Green Yellow Blue Green Red AS:SVE AS:SVE AS:SVE AS:SVE Red AS:SVE AS:SVE AS:SVE AS:SVE 9/4/2008 0% 0% 0% 0% 0% 0% 0% 0% 9/5/2008 0% 0% 0% 0% 0% 0% 0% 0% 9/8/2008 0% 0% 0% 0% 0% 0% 0% 0% 9/9/2008 0% 0% 0% 0% 0% 0% 0% 0% 9/10/2008 0% 0% 0% 0% 0% 0% 0% 0% 9/11/2008 0% 0% 0% 0% 0% 0% 0% 0% 9/19/2008 3% 3% 3% 3% 4% 0% 3% 3% 9/25/2008 1% 2% 5% 2% 4% 0% 5% 2% 10/2/2008 3% 4% 8% 0% 8% 0% 8% 0% 10/31/2008 NA NA NA NA NA NA NA NA 12/5/2008 NA NA NA NA NA NA NA NA 1/9/2009 2% 1% 4% 0% 4% 0% 2% 0% 2/5/2009 1% 1% 2% 0% 5% 0% 2% 0% 3/6/2009 1% 1% 3% 0% 4% 0% 3% 0% Notes: (1) SVE system startup on 9/4/2008 (2) AS system startup on 9/15/2008 (3) NA - SVE flows could not be measured due to heavy rain and condensate affecting hot-wire anemometer. Aspect Consulting LLC 5/5/09 V:\ \Progress Reports\2009 Q1\Tables4-9 Table 8 Page 1 of 1

21 Table 9 - SVE System Parameters - TCE Concentrations SVE Concentration (ppm TCE) SVE-1 SVE-2 MW-1 MW-2 SVE-A SVE-B Red Flowweighted Average MW-4 SVE-C SVE-D Yellow Flowweighted Average MW-3 MW-5 SVE-E SVE-F Blue Flowweighted Average MW-7 SVE-G Green Flowweighted Average Combined - Before Treatment 9/4/ /5/ /8/ /9/ /10/ /11/ /19/ /25/ /2/ /31/ NA NA NA 1 1 NA /5/ /9/ /5/ /6/ Notes: (1) Values in italics indicated concentrations measured using PID corrected for TCE (assumes all vapors detected are TCE, correction factor = 0.54). (2) Values in bold indicate concentrations measured using TCE detection tubes. (3) SVE system startup on 9/4/2008 (4) AS system startup on 9/15/2008 (5) NA - SVE flows could not be measured on 10/31 due to heavy rain and condensate affecting hot-wire anemometer. Aspect Consulting LLC 5/5/09 V:\ \Progress Reports\2009 Q1\Tables4-9 Table 9 Page 1 of 1