DOCUMENTATION OF DUE CARE COMPLIANCE REPORT

Transcription

1 DOCUMENTATION OF DUE CARE COMPLIANCE REPORT South University Avenue Ann Arbor, Michigan PM Project Number Prepared for: South University North East, LLC Telegraph Road, Suite 220 Bingham Farms, Michigan Prepared by: 4080 West Eleven Mile Road Berkley, Michigan 48072

2 Detroit 607 Shelby, Suite 650 Detroit, MI t: Berkley 4080 W. 11 Mile Road Berkley, MI t: Lansing 3340 Ranger Road Lansing, MI t: Grand Rapids th Street NW, Suite 301 Grand Rapids, MI t: October 14, 2016 Mr. Sean Havera South University - North East, LLC Telegraph Road, Suite 220 Bingham Farms, Michigan RE: Due Care Compliance Report for the Commercial Property Parcel ID: and Project No Dear Mr. Havera: Enclosed is a copy of the Documentation of Due Care Compliance prepared in accordance with Rule 1003(5) of Section 20107(a) of P.A. 451, as amended, and the Part 10 Rules by PM Environmental, Inc. (PM). If you have any questions regarding the information in this report, please contact us at PM ENVIRONMENTAL, INC. Andrea Galli Project Consultant Jennifer Ritchie, CPG Regional Site Investigation Manager Enclosure E N V I R O N M E N T A L & E N G I N E E R I N G S E R V I C E S N A T I O N W I D E W W W. P M E N V. C O M

3 Due Care Compliance Report for the Commercial Property PM Project No ; October 14, 2016 TABLE OF CONTENTS 1.0 INTRODUCTION Site Description and Background Intended Use of the Subject Property Summary of Previous Site Investigations Geology and Hydrogeology LOCATION OF CONTAMINATION MEDIA ON THE SUBJECT PROPERTY EXPOSURE PATHWAY EVALUATION PLAN FOR RESPONSE ACTIVITY EVALUATION AND DEMONSTRATION OF COMPLIANCE WITH SECTION 7A OBLIGATIONS Exacerbation (Section 7a(1)(a)) Due Care (Section 7a(1)(b)) Reasonable Precautions (Section 7a(1)(c)) Reasonable Cooperation, Assistance, and Access (Section 7a(1)(d)) Use Restriction Compliance (Section 7a(1)(e)) Effectiveness or Integrity of Use Restrictions (Section 7a(1)(f)) DUE CARE DOCUMENTATION... 7 FIGURES Figure 1: Figure 2: Figure 3: Figure 4: Property Vicinity Map Generalized Diagram of the Subject Property and Adjoining Properties Soil Boring/Soil Gas Sample Location Map with Soil Analytical Results Soil Boring/Soil Gas Sample Location Map with Soil Gas Analytical Results TABLES Table 1: Table 2: Soil Analytical Results Summary Volatile Organic Compounds and Polynuclear Aromatic Hydrocarbons Soil Gas Analytical Results Summary Volatile Organic Compounds APPENDICES Appendix A: Utility Notices Table of Contents Page i

4 Due Care Compliance Report for the Commercial Property PM Project No ; October 14, INTRODUCTION This Documentation of Due Care Compliance (DDCC) report was prepared on behalf of South University - North East, LLC for the Commercial Property (Parcel IDs: and ) located at South University Avenue, Ann Arbor, Washtenaw County, Michigan, in accordance with Rule 1003(5) of Section 20107a of Part 201 of the Natural Resources and Environmental Protection Act (NREPA), P.A. 451 of 1994 (Part 201), as amended. Part 201 requires that documentation be maintained demonstrating that the subject property is in compliance with Section 7a of Part 201, which must be made available to the Michigan Department of Environmental Quality (MDEQ) upon request. Section 7a of Part 201 imposes due care obligations on owners and operators of contaminated properties that are generally described as 1) prevent exacerbation; 2) mitigate unacceptable exposure and operate in a manner that protects the public health and safety; 3) take reasonable precautions against third party omissions; 4) reasonably cooperate with parties authorized to conduct response activities; 5) comply with land or resource use restrictions; and, 6) not impede any land or resource use restrictions. This report is representative of the current and intended use as outlined in Section 1.1 and 1.2. If changes to the property use, zoning, operations, and/or layout occur, re-evaluation of potential exposure pathways and associated amendments to this report may be required. 1.1 Site Description and Background The subject property consists of two parcels totaling 0.25 acres located on the north side of South University Avenue, east of Church Street and west of South Forest Avenue in Ann Arbor, Michigan (Figure 1). The subject property is developed with a single story 3,300 square foot multi-tenant building with two tenant spaces located in the southwestern portion of the property and a 1,960 square foot commercial building with a basement located in the southeastern portion of the property (Figure 2). A gravel parking lot is present north of the buildings. The subject property is zoned D-1: Downtown District. The western multi-tenant building is currently vacant and the eastern building is occupied by Sweeting Dessert and Teas. Municipal water and sewer, as well as natural gas, electrical, and telecommunications utilities are available to the subject property. No water supply wells exist or will be installed in association with the subject property. Standard and other historical sources document the western subject parcel was developed with a dwelling in the southern portion of the parcel by The remainder of the property was vacant land. A storefront was constructed along the southern and southeastern sides of the dwelling between 1931 and Between 1949 and 1956, the southern portion of the storefront was demolished and an addition was constructed to the north of the southeastern portion of the storefront. The former dwelling was demolished and additions were constructed to the west of the original building portion by 1960 to improve the building to the current layout. Occupants of the western parcel have consisted of various restaurants, retail stores, and offices since at least Additionally, a tenant space in the western building, identified as 1209 South University Avenue, was occupied by Campus Paint Shop from at least 1973 to Based on the short timeframe of the operations and likely retail operation, PM has not identified this former occupant as a REC. Page 1

5 Due Care Compliance Report for the Commercial Property PM Project No ; October 14, 2016 The eastern subject parcel was developed with the construction of the current building in the southern portion of the parcel between 1931 and Prior to that time, the property was vacant land. The eastern building was occupied by a grocer and baking company from at least 1939 to 1947 and various dry cleaners and/or dyers from 1955 to The eastern building has been occupied by various restaurant occupants since at least PM was unable to determine the former occupants at the eastern building between 1977 and The building may have been occupied by dry cleaners and/or dyers or other commercial/restaurant operations during this time. 1.2 Intended Use of the Subject Property The subject property will be redeveloped for mixed retail operations and residential use. The subject property will be utilized for Residential and Nonresidential use with no chemical use and storage. 1.3 Summary of Previous Site Investigations PM reviewed a previous Phase I ESA completed for the western subject parcel ( South University Avenue) by McDowell & Associates and dated June 5, At the time of the Phase I ESA, the western portion of the subject building was occupied by Safe Sex Store and the eastern portion of the building was vacant. Similar historical information was documented as included in PM s October 2016 Phase I ESA. No onsite Recognized Environmental Conditions (RECs) were identified. Off-site RECs were identified associated with the former dry cleaning and/or dyeing operations at 1213 South University, which was not included as part of the subject property in the previous report and was considered the east adjoining property; and the former gasoline dispensing operations located to the southwest at 1202 South University Avenue and 1220 South University Avenue (which is also identified as an open Leaking Underground Storage Tank site). PM did not identify the gasoline dispensing stations to the southwest as a REC; however, no significant deficiencies were identified through review of the previous Phase I ESA. PM completed a Phase I Environmental Site Assessment (ESA) for the subject property dated October 14, 2016, in which the following onsite REC was identified: The eastern subject building was historically occupied by dry cleaning and/or dying operations from at least 1955 to 1979, and potentially from 1955 until the 1990s or 2000s Dry cleaning operations commonly involve the usage of general hazardous substances and/or petroleum products, which, if improperly managed and/or disposed of, can be a source of contamination. This time period preceded major environmental regulations and current waste management and disposal procedures. The historical waste management practices associated with the former dry cleaning operations are unknown and may be a source of subsurface contamination and also represents a vapor intrusion condition. No adjoining and/or nearby RECs were identified. PM completed a BEA dated October 14, 2016, which documents that on September 9, 2016, PM completed a scope of work consisting of the advancement of five soil borings (SB-1 through SB-5) to a maximum depth of 25.0 feet below ground surface (bgs), the installation of two subslab soil gas sampling points (SG-1 and SG-2), the collection of eight soil samples for laboratory analysis of volatile organic compounds (VOCs) and polynuclear aromatic hydrocarbons (PNAs), Page 2

6 Due Care Compliance Report for the Commercial Property PM Project No ; October 14, 2016 and the collection of two soil gas samples for laboratory analysis of VOCs, to assess the REC identified in the October 2016 Phase I ESA. The analytical results and locations of soil borings and soil gas samples from the September 2016 subsurface investigation activities completed by PM are discussed below and summarized in Figures 3 and 4 and on Tables 1 and Geology and Hydrogeology Based on review of the soil boring logs, the soil stratigraphy at the subject property generally consists of sand or sandy clay to 25.0 feet bgs, the maximum depth explored. No groundwater was encountered to a depth of 25.0 feet bgs in any of the soil borings advanced on the subject property. Based on the municipal water connection and the absence of water supply wells, the groundwater ingestion pathway is not complete, and therefore the Part 201 Residential and Nonresidential Drinking Water Protection (DWP) cleanup criteria are not applicable to the subject property. Additionally, based on the connection of the subject property to combined sanitary and storm water sewers and the distance to the nearest surface water body, the groundwater surface water interface pathway is not complete, and the Part 201 Groundwater Surface Water Interface Protection (GSIP) cleanup criteria are not applicable to the subject property. 2.0 LOCATION OF CONTAMINATION MEDIA ON THE SUBJECT PROPERTY The analytical results for the soil and groundwater samples collected at the subject property in 2014 were compared with the MDEQ cleanup criteria as presented in Part 201 Rules through , dated December 30, 2013 entitled Cleanup Criteria Requirements for Response Activity, in accordance with Section 20120a(1) using the Residential and Nonresidential cleanup criteria. PM also compared the analytical results with the MDEQ Residential and Nonresidential Vapor Intrusion Screening Levels (VISLs) as presented in the Guidance Document for the Vapor Intrusion Pathway, dated May The analytical results from the site investigation activities are summarized on Figures 3 and 4 and in Tables 1 and 2 (including CAS#). 2.1 Soil Analytical Results The soil analytical results are summarized in Tables 1 and 2. Concentrations of tetrachloroethylene were detected in the soil samples collected at SB-1 ( and feet bgs) and SB-2 ( and feet bgs) above the Part 201 Residential and Nonresidential DWP, GSIP, and Residential Soil Volatilization to Indoor Air Inhalation (SVII) cleanup criteria. Concentrations of tetrachloroethylene were detected in the soil samples analyzed from SB-3 ( and feet bgs) and SB-4 ( feet bgs) above Part 201 Residential and Nonresidential DWP and GSIP cleanup criteria. A concentration of tetrachloroethylene was detected in the soil sample collected at SB-5 ( feet bgs) above laboratory method detection limits (MDLs), but was below the most restrictive Part 201 Residential cleanup criteria. No other concentrations of VOCs were detected in any the soil samples analyzed above laboratory MDLs. No concentrations of PNAs were detected in any of the soil samples collected at the subject property above laboratory MDLs. Page 3

7 2.2 Soil Gas Analytical Results Due Care Compliance Report for the Commercial Property PM Project No ; October 14, 2016 The soil gas analytical results are summarized on Figure 4 and in Table 2. A concentration of tetrachloroethylene was detected in the soil gas sample collected at SG-1 above the Part 201 Residential VISLs. Concentrations of acetone, benzene, cyclohexane, heptane, hexane, propylene, tetrachloroethylene, toluene, and trichlorofluoromethane were detected in the soil gas sample collected at SG-2 above laboratory MDLs, but were below the most restrictive Part 201 Residential cleanup criteria. No other concentrations of VOCs were identified in either of the soil gas samples collected above laboratory MDLs. 3.0 EXPOSURE PATHWAY EVALUATION The following exposure pathways were evaluated, including: groundwater ingestion, soil leaching to groundwater, groundwater surface water interface, direct contact, and ambient and indoor air inhalation from contaminated soil and groundwater. Exposure pathways are eliminated when it is demonstrated that unacceptable exposures do not exist and that response activities are not required to prevent or mitigate unacceptable exposures. The subject property is currently zoned D-1: Downtown District, which is consistent with a Nonresidential property use in accordance with Part 201. Based upon the planned residential use of the subject property, the Part 201 Residential cleanup criteria are applicable. The following exposure pathway analysis is based on the limited information collected during previous investigation activities. If evidence is discovered of additional impact, the exposure pathways will need to be re-evaluated. Pathway HUMAN EXPOSURE PATHWAYS Are Applicable Criteria Exceeded? (Applicable Criteria) Nonresidential Soil Soil Gas Groundwater Ingestion Yes NA Volatilization to Indoor Air Human Exposure Pathway Complete or Potentially Complete? Justification Connected to municipal water No potable or other supply wells are present on the subject property. No groundwater encountered. Yes/No Yes Yes Exceedances identified Yes Ambient Air Inhalation No No Criteria not exceeded NA Direct Contact No NA Criteria not exceeded NA Bold Response activities are required based upon a relevant human exposure pathway and exceedance of an applicable criterion (Section 3.0). NA Not Applicable No Page 4

8 Due Care Compliance Report for the Commercial Property PM Project No ; October 14, 2016 Migration Via Utility Corridors or other means Fire and Explosion Hazards OTHER PATHWAYS AND DUE CARE CONSIDERATIONS Utility corridors on or adjacent to the subject property may represent pathways for contaminant migration. Utility corridors may additionally act as a conduit for direct contact and inhalation exposure to third parties completing subsurface work. Exceedances were detected in the soil samples collected at SB-1 and SB-2 above the Part 201 Residential SVII and in the soil gas sample collected at SG-1 above the Residential VISLs. Although the areas of impact at the subject property are covered by the concrete building foundation, the potential exists that utility workers may come into contact with soil and soil gas contamination. Appropriate notices to utility easement holds regarding the presence of soil and soil gas contamination have been submitted as outlined in Section 4.0 (Appendix B). No compounds were identified above the flammability and explosively screening level. 4.0 PLAN FOR RESPONSE ACTIVITY The following represents response activities that will prevent or mitigate unacceptable exposure and allow for the intended use of the subject property in a manner that protects the public s health and safety, based upon the current and intended use of the subject property: Contaminant concentrations identified in soil and soil gas samples collected from the subject property indicate exceedances to the Part 201 Residential SVII screening levels and Residential VISLs. Therefore, the following due care response activities will be undertaken to prevent unacceptable exposure within the building: Additional assessment is required to assess the potential for volatilization to indoor air, consisting of soil gas and indoor air sampling. In lieu of additional assessment, a presumptive remedy will need to be installed prior to occupancy consisting of a passive barrier and venting or a sub-slab depressurization (SSD) system. If changes to the property use, zoning, operations, and/or layout occur, re-evaluation of potential exposure pathways and associated amendments to this report will be required. All potential third party contractors who may work sub-grade on the subject property will be notified of the presence of soil contaminants and that site-specific health and safety plans and/or requirements for 40-hour personal protection and safety training are necessary if working in the impacted area of the subject property. The owner will provide prospective future owners with the existing documentation, including this DDCC and the October 2016 BEA concerning the existing subsurface contamination. 5.0 EVALUATION AND DEMONSTRATION OF COMPLIANCE WITH SECTION 7A OBLIGATIONS The following sections provide documentation that the proposed usage of the subject property will be in compliance with Section 7a obligations. 5.1 Exacerbation (Section 7a(1)(a)) The following measures will be undertaken to prevent exacerbation of existing contamination: Page 5

9 Due Care Compliance Report for the Commercial Property PM Project No ; October 14, 2016 In the event the property owner or occupant intends to move soil or groundwater, proper characterization will be completed to prevent movement of impact soils to un-impacted areas, followed by appropriate disposal as needed. 5.2 Due Care (Section 7a(1)(b)) Based on the current and anticipated use, due care will be exercised by undertaking the activities outlined in Section 4.0 to allow for the intended use of the facility in a manner that protects the public health and safety. Potable water on the property is municipally supplied, but the owner/operator will ensure that groundwater at the subject property is not utilized for any purpose. If construction activities occur in the future, an environmental professional may be present. Any subsurface construction will be planned and implemented in a manner as to not increase offsite migration along subsurface utility, sewer, or structure corridors. Due to the contaminant concentrations identified in soil and soil gas samples collected from the subject property above the Part 201 Residential SVII screening levels and Residential VISLs, written notices have been provided to easement holders of record, utility franchise holders of record, and the owners and/or operators of all public utilities that serve the subject property (Appendix A). 5.3 Reasonable Precautions (Section 7a(1)(c)) Reasonable precautions will be taken against the reasonable foreseeable acts or omissions of a third party and the consequences that are foreseeable could result from those acts or omissions. Third parties who intend to perform subsurface work on the property will be notified prior to beginning work to allow proper management of impacted soil (if present) to prevent exacerbation and to comply with Section 7a. The owner will provide prospective future owners with the existing documentation, including this DDCC and the October 2016 BEA concerning the existing subsurface contamination. 5.4 Reasonable Cooperation, Assistance, and Access (Section 7a(1)(d)) Reasonable cooperation, assistance, and access will be provided to the persons (i.e. including liable parties) that are authorized to conduct response activities at the facility, including the cooperation and access necessary for the installation, integrity, operation, and maintenance of any complete or partial response activity at the facility. 5.5 Use Restriction Compliance (Section 7a(1)(e)) No land use or resource use restrictions are known or required in connection with the planned response activities and nonresidential land use. In the event that any land use or resource use restriction is placed on the facility, the owner will comply with them. Page 6

10 Due Care Compliance Report for the Commercial Property PM Project No ; October 14, Effectiveness or Integrity of Use Restrictions (Section 7a(1)(f)) The effectiveness and integrity of any land use or resource restrictions employed at the facility will not be impeded. 6.0 DUE CARE DOCUMENTATION Rule 1003(5) of Section 20107a of P.A. 451, as amended requires that documentation, be maintained for the subject property, demonstrating that the subject property is in compliance with Section 7a of Part 201. Documentation may include, but is not limited to, the following compliance documentation. Notices to easement holders of record, utility franchise holders of record, and owners and/or operators of all public utilities that serve the subject property, regarding onsite soil and/or groundwater contamination (Appendix A); Copies of notices to third party contractors who may work sub-grade on the subject property, including excavation contractors and utility employees; Documentation of subsurface construction activities in impacted areas, including any soil and/or groundwater sampling/characterization reports and waste disposal manifests; and; Evidence of additional assessment or documentation of the installation of a presumptive remedy to address soil volatilization to indoor air. If you have questions regarding this report, please contact PM at Report Prepared By: Report Reviewed By: Andrea Galli Project Consultant Jennifer Ritchie, CPG Regional Site Investigation Manager Page 7

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17 TABLE 1 SUMMARY OF SOIL ANALYTICAL RESULTS VOLATILE ORGANIC COMPOUNDS AND POLYNUCLEAR AROMATIC COMPOUNDS SOUTH UNIVERSITY AVENUE, ANN ARBOR, MICHIGAN PM PROJECT # VOLATILE ORGANIC COMPOUNDS (VOCs) AND POLYNUCLEAR AROMATIC COMPOUNDS (PNAs) (µg/kg) Tetrachloroethylene Other VOCs PNAs Sample ID SB-1 SB-1 SB-2 SB-2 SB-3 SB-3 SB-4 SB-5 Chemical Abstract Service Number (CAS#) Sample Date Sample Depth (feet bgs) Various Various VOCs PNAs 09/09/ ,100 <MDL <MDL 09/09/ ,300 <MDL <MDL 09/09/ ,300 <MDL <MDL 09/09/ ,200 <MDL <MDL 09/09/ ,040 <MDL <MDL 09/09/ ,700 <MDL <MDL 09/09/ ,840 <MDL <MDL 09/09/ <MDL <MDL Cleanup Criteria Requirements for Response Activity (R R ) Generic Soil Cleanup Criteria Tables 2 and 3: Residential and Non-Residential Part 201 Generic Cleanup Criteria and Screening Levels/Part 213 Risk-Based Screening Levels, December 30, 2013 Residential (µg/kg) Statewide Default Background Levels Drinking Water Protection (Res DWP) Groundwater Surface Water Interface Protection (GSIP) Soil Volatilization to Indoor Air Inhalation (Res SVII) Ambient Air Infinite Source Volatile Soil Inhalation (Res VSI) Ambient Air Finite VSI for 5 Meter Source Thickness Ambient Air Finite VSI for 2 Meter Source Thickness Ambient Air Particulate Soil Inhalation (Res PSI) Direct Contact (Res DC) NA NA NA 100 Various Various 1,200 {X} Various Various 11,000 Various Various 1.70E+05 Various Various 4.80E+05 Various Various 1.1E+06 Various Various 2.7E+09 Various Various 2.0E+05 {C} Various Various Nonresidential (µg/kg) Drinking Water Protection (Nonres DWP) Soil Volatilization to Indoor Air Inhalation (Nonres SVII) Ambient Air Infinite Source Volatile Soil Inhalation (Nonres VSI) Ambient Air Finite VSI for 5 Meter Source Thickness Ambient Air Finite VSI for 2 Meter Source Thickness Ambient Air Particulate Soil Inhalation (Nonres PSI) Direct Contact (Nonres DC) 100 Various Various 21,000 Various Various 2.10E+05 Various Various 4.90E+05 Various Various 1.1E+06 Various Various 1.2E+09 Various Various 9.3E+05 {C} Various Various Screening Levels (µg/kg) Soil Saturation Concentration Screening Levels (Csat) 88,000 Various Various Applicable Criterion Exceeded BOLD Value Exceeds Applicable Criterion bgs Below Ground Surface (feet) <MDL Not detected at levels above the laboratory Method Detection Limit (MDL) or Minimum Quantitative Level (MQL) NA Not Applicable

18 TABLE 2 SUMMARY OF SOIL GAS ANALYTICAL RESULTS VOLATILE ORGANIC COMPOUNDS SOUTH UNIVERSITY AVENUE, ANN ARBOR, MICHIGAN PM PROJECT # VOLATILE ORGANIC COMPOUNDS (VOCs) (µg/m 3 ) Acetone Benzene Cyclohexane Heptane Hexane Propylene Tetrachloroethylene Toluene Trichlorofluoromethane Other VOCs Chemical Abstract Service Number (CAS#) Sample ID Sample Date Sample Depth Various VOCs SG-1 09/09/2016 Sub-slab <3,100 <320 <340 <410 <350 <170 14,000 <380 <560 <MDL SG-2 09/09/2016 Sub-slab <MDL MDEQ Guidance Document For The Vapor Intrusion Pathway, Policy and Procedure Number: , Appendix D Vapor Intrusion Screening Values, May 2013 Vapor Intrusion Shallow Sub-Slab Soil Gas Screening Levels ( 1.5m bgs) (SG VI-SS ) Vapor Intrusion Deep Soil Gas Screening Levels (SG VI ) Vapor Intrusion Shallow Sub-Slab Soil Gas Screening Levels ( 1.5m bgs) (SG VI-SS ) Vapor Intrusion Deep Soil Gas Screening Levels (SG VI ) Residential Screening Levels (µg/m 3 ) 2.10E E E+05 24,000 NDC 1, E E+06 Various 2.10E+06 1, E E E+05 NDC 12, E E+07 Various Nonresidential Screening Levels (µg/m 3 ) 3.40E+06 2, E E E+05 NDC 23, E E+07 Various 3.40E+07 22, E E E+06 NDC 2.30E E E+08 Various Applicable Criteria/RBSL Exceeded BOLD Value Exceeds Applicable Criteria bgs Below Ground Surface (feet) <MDL Not detected at levels above the laboratory Method Detection Limit (MDL) or Minimum Quantitative Level (MQL)

19 Appendix A

20 Detroit 607 Shelby, Suite 650 Detroit, MI t: Berkley 4080 W. 11 Mile Road Berkley, MI t: Lansing 3340 Ranger Road Lansing, MI t: Grand Rapids th Street NW, Suite 301 Grand Rapids, MI t: October 14, 2016 City of Ann Arbor Public Services Administration and Safety Management Larcom City Hall, 6th Floor 301 East Huron Ann Arbor, Michigan RE: Commercial Property Project No To Whom It May Concern: (PM) is providing written notice to public utilities that serve the property located at South University Avenue, Ann Arbor, Washtenaw County, Michigan. This notice is being provided to satisfy the reporting requirements for due care obligations under Rule 1013 of Section 20107(a) of Part 201 of the Natural Resources and Environmental Protection Act (NREPA), P.A. 451 of 1994 (Part 201), as amended. The subject property is a facility as specified in Section 20120a(1)(a) or (17) in Part 201 based on the analytical results of soil and soil gas samples collected during a subsurface investigation. Contaminant concentrations have been identified in soil samples above Part 201 Residential and Nonresidential Drinking Water Protection (DWP), Groundwater Surface Water Interface Protection (GSIP), and Residential Soil Volatilization to Indoor Air Inhalation (SVII) cleanup criteria at SB-1, SB-2, SB-3, and SB-4. A concentration of tetrachloroethylene was detected in the soil gas sample collected at SG-1 above the Part 201 Residential Shallow Sub-Slab Soil Gas Vapor Intrusion Screening Levels (VISLs). Refer to the attached Figures and Tables for additional information regarding the location of the impact. Aside from the identified locations, additional areas may be present with elevated contaminant concentrations. All contractors who may work sub-grade on the subject site, including excavation contractors and utility employees, are advised to take appropriate safety precautions when working on the property. 40-Hour hazardous materials safety training, personal protection equipment, and site safety plans may be necessary if working subsurface at the subject site. Soil or groundwater must be characterized prior to movement on the subject property or prior to removal from the subject property. Additional documentation concerning the existing subsurface contamination is available upon request. Please contact us at (800) if you have any questions or require any additional information. Sincerely, Andrea Galli Project Consultant Enclosure ALABAMA I FLORIDA I ILLINOIS I MICHIGAN I MISSISSIPPI I NEW JERSEY I NORTH CAROLINA I OHIO I TENNESSEE I Q U A L I T Y S E R V I C E S O L U T I O N S

21 Detroit 607 Shelby, Suite 650 Detroit, MI t: Berkley 4080 W. 11 Mile Road Berkley, MI t: Lansing 3340 Ranger Road Lansing, MI t: Grand Rapids th Street NW, Suite 301 Grand Rapids, MI t: October 14, 2016 Mark T. Smith AT&T 308 South Akerd, Room 1700 Dallas, Texas RE: Commercial Property Project No Dear Mr. Smith: (PM) is providing written notice to public utilities that serve the property located at South University Avenue, Ann Arbor, Washtenaw County, Michigan. This notice is being provided to satisfy the reporting requirements for due care obligations under Rule 1013 of Section 20107(a) of Part 201 of the Natural Resources and Environmental Protection Act (NREPA), P.A. 451 of 1994 (Part 201), as amended. The subject property is a facility as specified in Section 20120a(1)(a) or (17) in Part 201 based on the analytical results of soil and soil gas samples collected during a subsurface investigation. Contaminant concentrations have been identified in soil samples above Part 201 Residential and Nonresidential Drinking Water Protection (DWP), Groundwater Surface Water Interface Protection (GSIP), and Residential Soil Volatilization to Indoor Air Inhalation (SVII) cleanup criteria at SB-1, SB-2, SB-3, and SB- 4. A concentration of tetrachloroethylene was detected in the soil gas sample collected at SG-1 above the Part 201 Residential Shallow Sub-Slab Soil Gas Vapor Intrusion Screening Levels (VISLs). Refer to the attached Figures and Tables for additional information regarding the location of the impact. Aside from the identified locations, additional areas may be present with elevated contaminant concentrations. All contractors who may work sub-grade on the subject site, including excavation contractors and utility employees, are advised to take appropriate safety precautions when working on the property. 40-Hour hazardous materials safety training, personal protection equipment, and site safety plans may be necessary if working subsurface at the subject site. Soil or groundwater must be characterized prior to movement on the subject property or prior to removal from the subject property. Additional documentation concerning the existing subsurface contamination is available upon request. Please contact us at (800) if you have any questions or require any additional information. Sincerely, Andrea Galli Project Consultant Enclosure ALABAMA I FLORIDA I ILLINOIS I MICHIGAN I MISSISSIPPI I NEW JERSEY I NORTH CAROLINA I OHIO I TENNESSEE I Q U A L I T Y S E R V I C E S O L U T I O N S

22 Detroit 607 Shelby, Suite 650 Detroit, MI t: Berkley 4080 W. 11 Mile Road Berkley, MI t: Lansing 3340 Ranger Road Lansing, MI t: Grand Rapids th Street NW, Suite 301 Grand Rapids, MI t: October 14, 2016 Jorg Schueler Safety Manager, Comcast Van Dyke Avenue, Building B Sterling Heights, Michigan RE: Commercial Property Project No Dear Mr. Schueler: (PM) is providing written notice to public utilities that serve the property located at South University Avenue, Ann Arbor, Washtenaw County, Michigan. This notice is being provided to satisfy the reporting requirements for due care obligations under Rule 1013 of Section 20107(a) of Part 201 of the Natural Resources and Environmental Protection Act (NREPA), P.A. 451 of 1994 (Part 201), as amended. The subject property is a facility as specified in Section 20120a(1)(a) or (17) in Part 201 based on the analytical results of soil and soil gas samples collected during a subsurface investigation. Contaminant concentrations have been identified in soil samples above Part 201 Residential and Nonresidential Drinking Water Protection (DWP), Groundwater Surface Water Interface Protection (GSIP), and Residential Soil Volatilization to Indoor Air Inhalation (SVII) cleanup criteria at SB-1, SB-2, SB-3, and SB- 4. A concentration of tetrachloroethylene was detected in the soil gas sample collected at SG-1 above the Part 201 Residential Shallow Sub-Slab Soil Gas Vapor Intrusion Screening Levels (VISLs). Refer to the attached Figures and Tables for additional information regarding the location of the impact. Aside from the identified locations, additional areas may be present with elevated contaminant concentrations. All contractors who may work sub-grade on the subject site, including excavation contractors and utility employees, are advised to take appropriate safety precautions when working on the property. 40-Hour hazardous materials safety training, personal protection equipment, and site safety plans may be necessary if working subsurface at the subject site. Soil or groundwater must be characterized prior to movement on the subject property or prior to removal from the subject property. Additional documentation concerning the existing subsurface contamination is available upon request. Please contact us at (800) if you have any questions or require any additional information. Sincerely, Andrea Galli Project Consultant Enclosure ALABAMA I FLORIDA I ILLINOIS I MICHIGAN I MISSISSIPPI I NEW JERSEY I NORTH CAROLINA I OHIO I TENNESSEE I Q U A L I T Y S E R V I C E S O L U T I O N S

23 Detroit 607 Shelby, Suite 650 Detroit, MI t: Berkley 4080 W. 11 Mile Road Berkley, MI t: Lansing 3340 Ranger Road Lansing, MI t: Grand Rapids th Street NW, Suite 301 Grand Rapids, MI t: October 14, 2016 DTE Energy Attn: Ms. Betty White-Clark nd Avenue GO655 Detroit, Michigan RE: Commercial Property Project No Dear Ms. White-Clark: (PM) is providing written notice to public utilities that serve the property located at South University Avenue, Ann Arbor, Washtenaw County, Michigan. This notice is being provided to satisfy the reporting requirements for due care obligations under Rule 1013 of Section 20107(a) of Part 201 of the Natural Resources and Environmental Protection Act (NREPA), P.A. 451 of 1994 (Part 201), as amended. The subject property is a facility as specified in Section 20120a(1)(a) or (17) in Part 201 based on the analytical results of soil and soil gas samples collected during a subsurface investigation. Contaminant concentrations have been identified in soil samples above Part 201 Residential and Nonresidential Drinking Water Protection (DWP), Groundwater Surface Water Interface Protection (GSIP), and Residential Soil Volatilization to Indoor Air Inhalation (SVII) cleanup criteria at SB-1, SB-2, SB-3, and SB- 4. A concentration of tetrachloroethylene was detected in the soil gas sample collected at SG-1 above the Part 201 Residential Shallow Sub-Slab Soil Gas Vapor Intrusion Screening Levels (VISLs). Refer to the attached Figures and Tables for additional information regarding the location of the impact. Aside from the identified locations, additional areas may be present with elevated contaminant concentrations. All contractors who may work sub-grade on the subject site, including excavation contractors and utility employees, are advised to take appropriate safety precautions when working on the property. 40-Hour hazardous materials safety training, personal protection equipment, and site safety plans may be necessary if working subsurface at the subject site. Soil or groundwater must be characterized prior to movement on the subject property or prior to removal from the subject property. Additional documentation concerning the existing subsurface contamination is available upon request. Please contact us at (800) if you have any questions or require any additional information. Sincerely, Andrea Galli Project Consultant Enclosure ALABAMA I FLORIDA I ILLINOIS I MICHIGAN I MISSISSIPPI I NEW JERSEY I NORTH CAROLINA I OHIO I TENNESSEE I Q U A L I T Y S E R V I C E S O L U T I O N S