Public Meeting. Proposed Municipal Setting Designation. PSC Plano Campus MSD. PSC Plano Campus 2300 West Plano Parkway VCP No ~71.

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1 Public Meeting Proposed Municipal Setting Designation City Council November 13 & December 11, 2017 Messiah Lutheran Church November 14, 2017 PSC Plano Campus 2300 West Plano Parkway VCP No ~71.2 Acres PSC Plano Campus MSD Agenda: Introductions Project Background Regulatory Process MSD Background & Purpose MSD Process Overview Questions [ 2] 1

2 Introductions Agenda: Applicant Representatives: o Debra Baker (Counsel) o Sarah Gibson (Dell on behalf of MSD Applicant) City of Plano o Caleb Thornhill, P.E. (City Engineer) o Paige Mims (City Attorney) Modern Geosciences (Third Party Review) o Kenneth S. Tramm, PhD, PG, CHMM [ 3] Introductions Consultant to City (Qualifications): Kenneth S. Tramm, PhD, PG, CHMM o Bachelors in Bioenvironmental Sciences Texas A&M o Masters and Doctorate in Environmental Science and Engineering University of Texas at Arlington o Author of Environmental Due Diligence: A Professional Handbook o Licensed Professional Geoscientist in Texas o Certified Hazardous Materials Manager o Serve on Technical Advisory Boards at both Texas A&M and UTA o Over 20 years of experience evaluating environmental risk and developing remediation strategies (>2,500 projects) o Adjunct professor for UTA in Civil Engineering Department o Founded an engineering firm focused on assessing and addressing environmental issues in air, soil, groundwater, and other media. o No prior work experience with either the City of Plano or the MSD Applicant [ 4] 2

3 Project Background Location: 2300 West Plano Parkway Southern boundary of Plano Size: ~71.2 Acres Property Property Use: Data Center/Offices [ 5] Project Background Timeline: Atlantic Richfield Company (ARCO) facility o 1987 Soil investigation at Building S o 1988 Additional soil borings to delineate impact o monitor wells installed to evaluate groundwater; 3 UST systems removed by ARCO (location presented later) o Impacted groundwater confirmed (flow to west) 2000 Current PSC/Dell (Office Complex) o Phase I ESA efforts (no sampling) to confirm suspect source areas (USTs, WMUs, etc.) o 2011 Evaluate prior impacted area (waste drum storage area at Building S) and Buildings Q, R (Drum storage, Sumps, Chemical Storage) and other waste management units (WMUs), & USTs Buildings Q, R, & S were demolished in ~2005 and appear to be primary source area concerns [ 6] 3

4 Project Background Timeline: o 2012 Site enters the Texas Voluntary Cleanup Program (VCP) o 2012 to current Additional Investigation Installation of additional soil borings/wells (~65) to delineate impact to soil and groundwater, evaluate WMUs/USTs; 11 compounds in groundwater above default Residential Assessment Levels (assumes gw is used for drinking) Drinking Water Survey Report (2012; no impacted wells); Groundwater Classification (up to 4 shallow units, some interconnectivity from 0 50 below grade minimal water availability); Depth to water: >15 Soil and groundwater impact delineation complete except for efforts to further refine shape of PCLE Zone (refine final boundary within larger area). [ 7] Project Background Timeline: o 2016 MSD Application submitted to the City of Plano (Oct.) o 2017 City Efforts: March 2017 Revised MSD Application submitted; August 8, 2017 Public Meeting August 14, 2017 Public Hearing (tabled to address questions) October 18, 2017 Modern Geosciences engaged to perform third party review of MSD Application and prepare this summary presentation/answer questions. Multiple other reports also requested and reviewed for this presentation. [ 8] 4

Key Questions: Is source investigation sufficient to evaluate risk? Is lithologic understanding sufficient to evaluate risk? Is groundwater understanding sufficient to evaluate risk?

5 Key Questions: Is source investigation sufficient to evaluate risk? Is lithologic understanding sufficient to evaluate risk? Is groundwater understanding sufficient to evaluate risk? Is release in a regulatory program with TCEQ oversight and pursuing closure? Is there a threat of impact to neighboring residential properties to north? Soil? Groundwater? Soilgas? Drinking water sources? Surface water? Is there a threat to other properties? Would the MSD aid the property in completing closure obligations and ensure future use of property is protective to human health and the environment? [ 9] USTs: A Former 1,000G Diesel (minor impact to soil) B Former 1,000G Diesel C Two 40,000G Diesel D Suspected Former UST E Former 6,000G Benzene Gasoline Not Shown (SWC of Site) All other USTs no impact > PST Action Levels Soil Investigation Results: UST/Source Summary B Former Building R Former Building R C Former Building Q Former Building Q A D Former Building S Former Building S [ 10 ] 5

6 Soil Data Summary Soil Investigation Results: Benzene Reference: September 29, 2017 VCP No Status Letter [ 11 ] Soil Investigation Results: Benzene PCE Reference: September 29, 2017 VCP No Status Letter [ 12 ] 6

7 Soil Investigation Results: Benzene PCE TCE Reference: September 29, 2017 VCP No Status Letter [ 13 ] Soil Investigation Results: Benzene PCE TCE Reference: September 29, 2017 VCP No Status Letter [ 14 ] 7

8 Soil Investigation Results: Benzene PCE TCE 1,2 cdce Reference: September 29, 2017 VCP No Status Letter [ 15 ] Soil Investigation Results: Benzene PCE TCE 1,2 cdce Vinyl Chloride Reference: September 29, 2017 VCP No Status Letter [ 16 ] 8

Key Questions: Is source investigation sufficient to evaluate risk? Yes. Buildings, sumps, USTs, WMUs and surrounding areas evaluated. All soil impact >RALs defined on site.

9 Key Questions: Is source investigation sufficient to evaluate risk? Yes. Buildings, sumps, USTs, WMUs and surrounding areas evaluated. All soil impact >RALs defined on site. South of Bldg R Primary source Is lithologic understanding sufficient to evaluate risk? Yes. Soils types limit migration (high attenuation) laterally/vertically, low hydraulic conductivity (limited migration potential). ~0 5/20 below grade: Clay, Silty Clay ~20+ Limestone (less weathered with depth) [ 17 ] Groundwater Investigation Results: Groundwater Flow Direction? Shallow impact typically follows topographic gradient (high to low) Expected: SW and WSW near releases; ESE on eastern quarter Primary Release cvocs Well is <RAL for all COCs [ 18 ] 9

weathered limestone, but generally consistent with topographic gradient Up to 2 other isolated GWBUs

10 Groundwater Investigation Results: What they found? GWBU 1 consistent with topographic gradient SW to SSW (arrows at right) GWBU 2 has isolated movement in weathered limestone, but generally consistent with topographic gradient Up to 2 other isolated GWBUs described within 0 50 Well is <RAL for all COCs [ 19 ] Groundwater Investigation Results: Additional gw samples <RAL or ND (in Sept 2017 data set) Well is <RAL for all COCs [ 20 ] 10

11 Groundwater Investigation Results: 1,1,2 TCA* (* COC <RAL in most recent data) [ 21 ] Groundwater Investigation Results: 1,1,2 TCA* 1,2 DCA* (* COC <RAL in most recent data) [ 22 ] 11

12 Groundwater Investigation Results: 1,1,2 TCA* 1,2 DCA* 1,2 cdce (* COC <RAL in most recent data) [ 23 ] Groundwater Investigation Results: 1,1,2 TCA* 1,2 DCA* 1,2 cdce Arsenic* (* COC <RAL in most recent data) [ 24 ] 12

Benzene Chloroform* (* COC <RAL in most recent data) [

13 Groundwater Investigation Results: 1,1,2 TCA* 1,2 DCA* 1,2 cdce Arsenic* Benzene [ 25 ] Groundwater Investigation Results: 1,1,2 TCA* 1,2 DCA* 1,2 cdce Arsenic* Benzene Chloroform* (* COC <RAL in most recent data) [ 26 ] 13

14 Groundwater Investigation Results: 1,1,2 TCA* 1,2 DCA* 1,2 cdce Arsenic* Benzene Chloroform* PCE [ 27 ] Groundwater Investigation Results: 1,1,2 TCA 1,2 DCA 1,2 cdce Arsenic Benzene Chloroform PCE TCE [ 28 ] 14

Groundwater Investigation Results: 1,1,2 TCA* 1,2 DCA* 1,2 cdce Arsenic* Benzene Chloroform* PCE TCE Vinyl Chloride [ 29 ] Key Questions: Is groundwater understanding sufficient to evaluate risk? Yes.

15 Groundwater Investigation Results: 1,1,2 TCA* 1,2 DCA* 1,2 cdce Arsenic* Benzene Chloroform* PCE TCE Vinyl Chloride [ 29 ] Key Questions: Is groundwater understanding sufficient to evaluate risk? Yes. Groundwater flow consistent with topographic gradient: W, SW gradient Impact to GWBUs suggest interconnectivity across all (0 50 below grade) and impact has little migration laterally Defined on site with some southern exceptions (e.g., 1,1 DCE extends to roadway > RALs expected) But not extending across George Bush Is release in a regulatory program with TCEQ oversight and pursuing closure? Yes. Entered VCP in 2011 with investigation results presented in multiple reports. Discussed site data with TCEQ PM; Agrees that MSD is a suitable solution since Affected Property well defined and in area where groundwater conditions unlikely to support potable use. [ 30 ] 15

Key Questions: Is there a threat of impact to neighboring residential properties to north? Soil? Groundwater? Soilgas? Drinking water sources? Surface Water?

16 Key Questions: Is there a threat of impact to neighboring residential properties to north? Soil? Groundwater? Soilgas? Drinking water sources? Surface Water? [ 31 ] Risk Evaluation: Soil & Groundwater PCLE Zones well defined Soil: South of Bldg R All below grade Groundwater: Flow to SW Aquitard Below All Conc. <1 mg/l >15 below grade Soil PCLE Zone Groundwater PCLE Zone [ 32 ] 16

17 Risk Evaluation EXAMPLE: Soilgas Vapor Intrusion Concerns? GW < RAL Soil <RAL Soilgas? d Lateral distance (d): Reference: ASTM E ASTM 1 : >Petroleum 30 >Chlorinated/NAPL Critical distance is the lineal distance in any direction between the nearest edge of the contaminated plume and the nearest TP boundary. Contaminated Plume is a plume in which concentrations of COCs are known to be present in the soil or groundwater or both at concentrations exceeding levels that generally would be the subject of an enforcement action if brought to the attention of appropriate governmental agencies (ASTM E ) [ 33 ] Risk Evaluation: Soilgas Vapor Intrusion Concerns? ASTM VEC Criteria = 100 No off site receptors <250 Lack of lateral plume extent after >20 years of migration suggests off site VICs are unlikely Reference: ASTM E [ 34 ] 17

Geology MSD Site 700 525 350 175 0 175 350 525 AMSL Austin Chalk Clay and Limestone (Aquitard) Eagle Ford Shale, Limestone & Clay (Aquitard) Woodbine Group Woodbine Sand, Sandstone, & Clay (Minor

18 Geology MSD Site AMSL Austin Chalk Clay and Limestone (Aquitard) Eagle Ford Shale, Limestone & Clay (Aquitard) Woodbine Group Woodbine Sand, Sandstone, & Clay (Minor Aquifer) Washita & Fredericksburg Grps Buda/Grayson Limestone Main Street Limestone Goodland Limestone (Aquitard) Shallow Groundwater From ~15 bgs to ~40 bgs Not considered a usable groundwater resource Aquitard Units Shale, Limestone & Clay First Major Aquifer Paluxy (1,200 + feet) Generalization based on TWDB 1982 and DGS 1965 [ 35 ] Drinking Water Sources NTMWD Water Sources (Lakes): Lavon Lake Lake Texoma East Fork Reuse Project Shallow groundwater not utilized as drinking water resource Source: North Texas Municipal Water District, 2017 [ 36 ] 18

19 Key Questions: Is there a threat of impact to neighboring residential properties to north? o Soil? No. Limited to on site only, below improved surfaces o Groundwater? No. Limited extent mostly on site, some extending to adjacent highway. Flow is away from residential area. o Soilgas? No. Limited extent of impact and radius has no receptor concerns. o Drinking water sources? No. Sources are area lakes with no threat of impact at > 3,000 away. No wells noted in ½ mile of affected property during 2012 DWSR. o Surface water? No. Limited extent does not threaten nearest downgradient feature (Prairie Creek; >1,000 from affected property) Other Neighboring Properties? Southern Adjacent Property Owners (e.g., NTTA, Custer) have been notified, but no potential receptors (impacted land is below highway). [ 37 ] Regulatory Process Applicable Regulations: Petroleum Storage Tank Rules (30 TAC 334) o Applies to all USTs o Five (5) UST systems evaluated with only one having slight impact. None related to concerns being addressed by MSD. Texas Risk Reduction Program Rules (30 TAC 350) o Applies to all other releases at the Site. Specifically the chlorinated VOCs (e.g., PCE, 1,1 DCE) driving the closure effort. o TRRP program utilizes Risk Based Corrective Action, but begins with default exposure assumptions and pre published values for a wide range of COCs. [ 38 ] 19

TRRP Protective Concentration Levels To Air ( Air Soil Inh V ) Ecological PCLs Not Depicted Drinking Water ( GW GW Ing ) To Air ( Air GW Inh V ) Skin/Ingestion ( Tot Soil Comb ) Includes: Growing

Would the MSD aid the property in completing closure obligations and ensure future use of property is protective to human health and the environment? Yes.

20 TRRP Protective Concentration Levels To Air ( Air Soil Inh V ) Ecological PCLs Not Depicted Drinking Water ( GW GW Ing ) To Air ( Air GW Inh V ) Skin/Ingestion ( Tot Soil Comb ) Includes: Growing Vegetables Dermal Contact Ingestion of Soil Inhalation of Soil To Drinking Water ( GW Soil Ing ) Impacted Soil To Air ( Air GW Soil Inh V ) Impacted Groundwater = Pathway removed by an MSD [ 39 ] Would the MSD aid the property in completing closure obligations and ensure future use of property is protective to human health and the environment? Yes. MSD Applicant currently waiting on MSD to be in place so this assumption (removal of the groundwater ingestion pathway) can be utilized and allow representation current property conditions (when it has the MSD ordinance in place) in an Affected Property Assessment Report. [ 40 ] 20

21 MSD Background Timeline: 2003: House Bill 3152 passed (THSC: Subchapter W) Purpose: Allow removal of groundwater ingestion pathway : TCEQ Certification process formalized o Prohibit by law the potable use of actual or potentially contaminated groundwater; and o Allow risk based corrective action standards to reflect actual human health concerns 2005: City of Dallas passes 1st MSD 2017: Over 350 Certified in Texas 1 to limit the scope of or eliminate the need for investigation of or response actions addressing contaminant impacts to groundwater that has been restricted from use as potable water by ordinance or restrictive covenant. [ 41 ] What an MSD Can Do Remove groundwater ingestion based risk factors under state rules; Allow adjustment to investigation and cleanup goals; Reduce cost, time and uncertainty to obtain regulatory closure; and Resolve groundwater issues that may otherwise never qualify for regulatory closure and stall redevelopment. [ 42 ] 21

22 What an MSD Cannot Do Eliminate all assessment and cleanup requirements. All other pathway criteria is evaluated as part of closure pathway Guarantee more lenient assessment and cleanup requirements [ 43 ] MSD Process City Must Pass Ordinance in Support & Restricts GW use on the MSD designated property Notification to: o All Registered Drinking Water Wells 5 miles o All Municipalities ½ mile (Richardson) o All Water Utility Districts 5 miles TCEQ must then review, and if administratively complete, certify before is can be used to complete closure. [ 44 ] 22

23 QUESTIONS AND ANSWERS 23

Data Source: TCEQ Updated Evaluation for the North-Central Texas Trinity and Woodbine Aquifers, Priority Groundwater Management Study Area

Data Source: TCEQ Updated Evaluation for the North-Central Texas Trinity and Woodbine Aquifers, Priority Groundwater Management Study Area City of Dallas Groundwater Management & Municipal Setting Designation (MSD) Program AWMA Meeting March 23, 2010 1 Summary Groundwater management in Dallas Municipal Setting Designation Program Groundwater