1. Location

2. Project Description

3. Scope of Work

4. Contract Type

5. Unit Pricing

6. Contract Considerations

7. Project Close Out

Bid Sheet

Exhibit 1: Easton Iron & Metal – Cleanup Plan (HDR, September 19, 2025)

Exhibit 2: Former Easton Iron & Metal Co.- Site Specific Field Sampling Plan (HDR, December 12, 2025)

Exhibit 3: EPA Cleanup Grant Cooperative Agreement and Conditions

Exhibit 4: Davis-Bacon Wage Rate Determination

12-18-25

Easton Iron & Metal Site

Hot Spot Remediation

Technical Specifications

Easton Iron & Metal Site - Hot Spot Remediation Technical Specifications

1. Location The location of the work is 1100-1164 Bushkill Drive, Easton, PA 08042. The site is a former scrapyard operated by the Easton Iron & Metal Company and includes work on parcels both north and south of Bushkill Drive (collectively, the “Site”)

2. Project Description The Site was originally developed in the 1800s with a lime making kiln and quarry, and later housed an automotive repair shop, filling station, and a metal recycling facility/srapyard known as “Easton Iron & Metal”, which went out of business in 2015. With the goal of facilitating the Site’s redevelopment, the Redevelopment Authority of Easton (“RDA”) purchased the property in late 2019 and subsequently transferred ownership to the City of Easton (“City”) who is its current owner. Since the Site was acquired, all buildings have been demolished and the Site is currently vacant.

In 2021, the City issued a Request for Development Proposals (RFDP) to identify a real estate developer to work with the City to redevelop the Site through a public-private partnership.

Through that process, the City identified VM Development Group (“VMDG”) as the “preferred developer” for the project. VMDG’s plan, called The Foundry, envisions the Site being transformed into a $60M+ mixed-use development.

Environmental site characterization work at the Site has identified that several contaminants exceeded their applicable Pennsylvania residential and nonresidential Sitewide Health Standards (RSHS/NRSHS) in soils and groundwater. The metals antimony, arsenic, iron, lead, manganese, mercury, nickel, and selenium were found to exceed the RSHS and NRSHS, and thallium and vanadium exceeded the RSHS. The volatile organic compounds (VOCs) Trichloroethylene and Vinyl chloride exceeded the RSHS and NRSHS. Semi-volatile organic compounds (SVOCs) exceeded the RSHS in 19 of 46 samples, and exceeded the NRSHS in one location. PCBs were detected above the RSHS in one location but did not exceed the NRSHS in any samples. VOC results were also compared to the applicable PA soil SHS screening values for Vapor Intrusion into buildings (SVSOIL). SVSOIL screening values (SV) were exceeded at 14 sample locations, including for Trichloroethene, Methylene Chloride, and tetrachloroethylene.

The metals manganese and iron, as well as Tetrachloroethylene (PCE), were all detected in the groundwater at concentrations exceeding their respective RSHS/NRSHS.

The site is enrolled in Pennsylvania’s Voluntary Cleanup Program (“VCP”, aka “Act 2”). The cleanup is anticipated to address documented exceedances of heavy metals, volatile organic compounds (VOCs), and semi-volatile organic compounds (SVOCs) in Site soils; VOC exceedances of Soil Vapor Intrusion screening values; and heavy metals and Tetrachloroethylene

(PCE) in groundwater. The Site will be remediated to achieve a risk-based Act 2 Site-Specific Standard based on the proposed mixed-use redevelopment of the site. This will be accomplished via the removal of certain soil “hot spots”, as well as a series of engineering and institutional controls such as exposure pathway elimination (capping the site with impervious surfaces and/or clean fill) and a deed restriction limiting future uses of the site and restricting future use of groundwater.

In 2024, the City was awarded a grant for the project through the U.S. Environmental Protection Agency (EPA) Brownfield Cleanup Grant program (“Cleanup Grant”). These funds are to be used to develop and implement a cleanup plan for the Site that meets applicable cleanup standards under Act 2 as we all as applicable EPA requirements. Through the Cleanup Grant, the City hired HDR Engineering to work with PADEP and USEPA to develop a site-wide Cleanup Plan (see Exhibit 1), which outlines how the Site will be remediated to achieve a risk-based Act 2 Site-Specific Standard based on the future use. HDR Engineering also developed a Site- Specific Field Sampling Plan (see Exhibit 2) which outlines the specifications for the remediation.

3. Scope of Work The scope of work (Work) for this contract is outlined in the Site-Specific Field Sampling Plan (see Exhibit 2). Note that the Work includes hot spot soil remediation, waste profile sampling, post-excavation sampling, backfilling of hot spot excavations with clean fill, and applicable reporting, but it does not include construction of engineering controls (i.e., capping) per the approved Cleanup Plan.

4. Contract Type The Work shall be performed on a unit price basis. Bidders shall furnish all labor, materials, equipment, and services necessary to complete the Work in accordance with the Contract Documents. Payment will be made based on the actual measured quantities of Work performed and the unit prices submitted on the Bid Sheet.

5. Unit Pricing Bidder shall provide a unit price for each item listed in the Bid Sheet. Unit prices shall include all direct and indirect costs, including but not limited to labor, materials, equipment, transportation, overhead, profit, and applicable taxes and fees. Unless otherwise stated, unit prices shall remain firm for the duration of the Contract.

The quantities listed in the Bid Scheet are approximate and for cost estimation purposes only.

Actual quantities may vary. The City does not guarantee any minimum or maximum quantity.

Payment will be based solely on the actual quantities of Work measured and accepted by the City or City’s Representative in accordance with the specifications.

Payment will be calculated as: Payment = (Actual Measured Quantity) × (Unit Price) No additional payment will be made for items not specifically listed in the Bid Sheet unless authorized by written Change Order.

If actual quantities differ significantly from estimated quantities, either party may request an adjustment. An adjustment will be considered only when the variation causes a material change in cost or performance method, and the change exceeds 25% of the estimated quantity for that item. Any adjustment shall be made through a written Change Order.

Certain items may be designated as “lump sum.” Lump sum prices shall include all work necessary to complete that item, regardless of actual quantity or effort required.

The Bidder acknowledges having examined the site and all Contract Documents. By submitting a bid, the Bidder accepts the risk that actual conditions and quantities may differ from those shown in the Bid Documents.

Unit prices and the extended total price shall be typed or written legibly in ink on the Bid Sheet.

In case of discrepancy between the unit price and the extended total price, the unit price shall govern.

6. Contract Considerations All or a portion of this contract will be funded by the Cleanup Grant. As such, the contractor shall comply with any and all federal requirements in the implementation of the contract, including but not limited to compliance with the Cleanup Grant Cooperative Agreement and associated Administrative Conditions (see Exhibit 3). One of the compliance requirements is the payment of federal Davis Bacon Wage Rates, the rate finding for which is provided as Exhibit 4.

Notification shall be given by the Contractor to the City and/or the City’s Representative a minimum of 72 hours prior to the start of any Work.

Applications for Payment shall be submitted monthly on a standard form, or if approved, Contractor’s electronic media derived form. Use a Schedule of Values for listing items in Application for Payment.

The City and/or the City’s Representative may advise of minor changes in the Work not involving an adjustment to Contract Price or Contract Time by issuing supplemental instructions.

The City and/or the City’s Representative may issue a Notice of Change which includes a detailed description of a proposed change with supplementary or revised drawings and specifications. Contractor will prepare and submit an estimate within five (5) days. Change Orders will be via standard form.

The Contractor may propose changes by submitting a request for change to City and/or the City’s Representative, describing the proposed change and its full effect on the Work. Include a statement describing the reason for the change, and the effect on the Contract Price and Contract Time with full documentation. Document any requested substitutions, which shall not be made unless first approved by the City and/or the City’s Representative.

Work Directive Change: The City and/or the City’s Representative may issue a Work Directive Change, instructing the Contractor to proceed with a change in the Work, for subsequent inclusion in a Change Order. Document will describe changes in the Work, and designate method of determining any change in Contract Price or Contract Time. Contractor will promptly execute the change.

Contractor shall maintain detailed records of Work and provide full information required for evaluation of proposed changes, and to substantiate costs for changes in the Work.

7. Project Close Out Contractor shall submit written certification that the Work has been completed in accordance with Contract Documents and ready for review and inspection by the City or City’s Representative. Provide submittals to the City or City’s Representative that are required by governing or other authorities. Submit final Application for Payment identifying total adjusted Contract Price, previous payments, and sum remaining due.

Item Notes Units Estimated Quantity Unit Rate Total Cost

Day Rate Exavation

Includes all labor, equipment, expenses and costs related to excavation of the material and stockpiling if necessary Per Day 3

Transportation and Disposal

Includes all permits license, equipment, labor, to remove impacted soils from the site to an approriate landfill or desitnation following all federal state and local regulation. Per CY 1,787

Transport and Disposal of PCB Transformer Hull One hull left onsite (Assume Empty) Lump Sum NA NA

Analytical Costs

Volatile Organic Compounds (EPA Method 8260) For attainment sampling Per Sample 55

Semivolatile Organic Compounds (EPA Method 8270) For attainment sampling Per Sample 55

Metals (EPA Method 6000/7000 series) For attainment sampling Per Sample 55

PCBs (EPA Method 8081) For attainment or sampling Per Sample

PA Form U analysis For disposal and waste characterization Per Sample

Reporting and Permitting

All costs related to providing documentation for the project including but not limited to Davis Bacon Requirements, transportationa dn diposal dcoumentation, health and Saefty documentation, and license. Lump Sum NA NA

Geotextile fabric For delineation of excavation and remaining materials Square Yard 500

Import of Clean Fill Material Must meet the definition of Clean Fill as defined in the PADEP Management of Fill Policy Per Tri-Axle 120

Bid Sheet

Easton Iron & Metal Site Hot Spot Cleanup

Exhibit 1: Easton Iron & Metal – Cleanup Plan (HDR, September 19, 2025)

Cleanup Plan

Easton Iron and Metal

1100-1164 Bushkill Drive, City of Easton, PA September 19, 2025 i

Contents

1 Introduction

1.1 Previous Site Uses and Previous Cleanup/Remediation

1.2 Site Assessment Findings

1.3 Site Remedy

2.0 List of Contacts

2 Remedial Alternatives Evaluation

2.1 Remedial Alternative Options

2.2 Recommended Remedial Alternative

3 Treatability Studies 4 Design Plans and Specifications

4.1 Hot Spot Excavation

4.2 Engineering Controls

4.2.1 Vapor Retardant and Passive Vapor Control System

4.2.2 Proposed Slab on Grade Buildings

4.2.3 Proposed Asphalt Pavement Areas

4.2.4 Landscaped Areas

4.3 Site Use Restrictions

5 Post Remediation Care Plan

5.1 Construction Phase

5.2 Post-Construction Phase

5.3 Operation and Maintenance of the Vapor Mitigation System

5.3.1 System Verification

5.3.2 Annual Inspection

5.3.3 Record Keeping and Reporting

6 Cooperation or Agreement of Third Party 7 Public Comments 8 Signatures

8.1 Qualifications of Environmental Professionals

ii

Figures

Figure 1- Site Location

Attachments

Attachment A- Areas of Concern and Hot Spots for Excavation

Attachment B- Engineering Design Plans

Attachment C- Typical Cross-Section of the Vapor Barrier System

Attachment D- Typical Cross-Section of the Proposed Caps

Attachment E- Generic Cap Inspection Form

1 Introduction HDR Engineering, Inc. (HDR) on behalf of the City of Easton is pleased to present this Cleanup Plan (CP) for the tracts associated with 1100-1164 Bushkill Drive City of Easton, Northampton County, Pennsylvania (Site). The CP details the remedial actions, engineering and institutional controls that are proposed to eliminate existing environmental exposure pathways associated with soil contamination on the Site and to demonstrate compliance with Section 250.404 and

250.410 of Pennsylvania’s Land Recycling and Environmental Standards Act (Act 2) Regulations. The Site is proposed for redevelopment with mixed use properties consisting of an approximately 20,000 square feet of commercial space, ~200 residential units, and a trail connection to the Karl Stirner Arts Trail.

The City of Easton and Northampton County though a United States Environmental Protection Agency (UESPA) Cleanup Grant and Revolving Loan Fund will complete the needed actions to demonstrate attainment of the Site-Specific standard in pursuit of release of liability under Act 2

Site Location The Site associated with the tracts is located within the Bushkill Creek Corridor (Corridor) at 1100-1164 Bushkill Drive in Easton, PA. The parcels referenced consist of two tracts of land totaling approximately 15 acres. (Figure 1). The northern tax tract identified on the Northampton County Geographic Information System (GIS) website is approximately 10.37 acres with Tract (Property) Identification Number (PIN) L9NE1 17 10 0310 and mailing addresses of 1100-1113 Bushkill Drive, Easton, PA. Geographic coordinates at the approximate center of the northern tract of the Site are 40.700673° North and -75.220648° West. Bushkill Drive separates the northern tract from the southern tract. The southern tract includes approximately four acres of land and is associated with the same PIN (L9NE1 17 10 0310). Geographic coordinates at the approximate center of the southern tract of the Site are 40.700029° North and -75.219080° West.

The northern tract is zoned Adaptive Reuse (AR), which is a zoning district designed to promote the redevelopment and revitalization of underutilized and underperforming areas of the city, the uses of which are industrial development, residential, institutional, and commercial. The southern tract is zoned as River Corridor (RC), a zoning district designed to accommodate appropriate development while providing for adequate protection and buffering of the city’s waterways and other natural resources; assisting in flood management; protecting environmentally sensitive areas; and meeting the need for local and regional greenways, open space, and recreation within the city.

Currently, the Site is vacant, and historic structures are no longer present. Most of the Site is overgrown with vegetation. Fencing encompasses some areas on the northern and southern tracts, and temporary roadways have been constructed of recycled asphalt material. Public utilities are available for the Site. The Site is infrequently used for temporary laydown, stone stockpile and trailer storage

The Site is surrounded by a mix of residential, commercial, and public properties. Single family homes and apartment buildings are to the west, north, and east. East of the Site are Gil Machine & Tool Co Machine shop, WB Moore Biotechnology Company, and Pacific Pride fueling station.

Directly east of the southern tract is Deiter Heating, the former location of Walters Tire and Oil Company and Sinclair Oil Refinery. Bushkill Creek, an accompanying trail (Karl Stirner Arts Trail), US Route 22, and the Easton Cemetery are to the south.

1.1 Previous Site Uses and Previous Cleanup/Remediation

The Site was the former location of a lime kiln facility, which operated from 1885 to approximately 1927. In 1927, the Site operated as Crew Levick Company Motor Oil Station, which included a rectangle-shaped building used to store oil barrels and four oil tanks. In 1949, the north tract of the Site was used as a scrap metal yard and filling station with three USTs along Bushkill Drive.

In 1949, the southern tract was used as a junk yard. In 1958, both the northern tract and southern tract were developed with an auto repair garage and scrap metal yard. From 1958 to 2015, the Site operated as a scrap metal recycling business under the ownership of the Easton Iron & Metal Company. The scrap yard was serviced with rail during its operation.

1.2 Site Assessment Findings

Previous investigations include:

• Phase I ESA Report dated February 4, 2019 (HDR)

• Phase II ESA Report dated December 31, 2019 (HDR)

• Phase II ESA Report Addendum dated June 1, 2020 (HDR)

• Targeted Brownfields Assessment (TBA) – Phase II Environmental Site Assessment dated January 31, 2025 (Tetra Tech Inc.)

Findings for the reports identified above are listed by area of concern below, Attachment A:

• Quarry Fill Area (Northern Tract)

Arsenic was detected in soil samples at concentrations exceeding the Pennsylvania Department of Environmental Protection (PADEP) Medium Specific Concentrations (MSC) for direct contact (DC) in residential soil. Contaminants of concern in connection with the former Quarry Fill Area include metals (arsenic) and residual oil related compounds (benzo(a) pyrene).

• Former Railroad and Railroad Spur Area (Northern and Southern Tracts) Heavy metals (lead) were detected exceeding a PADEP risk standards.

• Historically Contaminated Fill Material (Northern and Southern Tracts) PCBs, heavy metals, and residual oils were detected in impacted fill material at concentrations exceeding the regulatory standards for direct contact and soil to groundwater pathways.

• Former Waste Piles (Northern Tract) Analysis of the sample was limited to PCB and hexavalent chromium. Aroclors and PCB were detected in waste piles. PCB concentrations of 100 mg/kg were detected in surface soil of the waste piles, exceeding the regulatory standards. This sample was collected from the area of the eastern former waste pile. Contaminants of concern in connection with former waste piles fill include PCB, lead, and arsenic.

• Historical Storage of Oil-Barrels and Oil Tanks allegedly by Crew Levick Co. (Southern Tract) Subsurface soil samples were collected and analyzed for petroleum products, solvents, PCBs, and metals plus mercury and were not detected at concentrations exceeding the regulatory standards.

• Former Filling Station and Automotive Repair Facility (Northern Tract) Arsenic was detected in soil at the former filling station and automotive repair facility.

Groundwater samples from monitoring well MW-1 in this area were collected and analyzed for petroleum products, solvents and residual oils and dissolved metals. Contaminants of concern in connection with the former filling station and automotive repair facility include arsenic in soil and dissolved iron, and manganese in groundwater.

• Former Metal Scrap Yard Areas (Northern and Southern Tracts) The facility was historically operated as a scrap yard. Residual oils and heavy metals were detected in soil above regulatory standards.

• Former Automobile Salvage Yard (Southern Tract) Former metal scrapyard areas included PCBs and heavy metals.

• Leaking Pad Mounted Transformer Containing PCB (Southern Tract) PCBs and residual oils exceeded the regulatory standards in soil.

• Area Of Former Potentially Leaking Drums (Northern Tract) Two separate areas of former potentially leaking drums on northern portion of the Site are in the southwest corner of the former filling station and automotive repair facility by the road (southwest), and the other approximately 100 feet northeast of the former filling station and automotive repair facility (northeast). PCBs, and heavy metals were detected in surface soil.

• Battery Components in Soil (Northern Tract) Lead-acid battery components were identified in soil borings. Exceedances of lead were identified in the vicinity of battery components.

• Former Sinclair Refining Co. & Walters Oil (Offsite)

Located east of the southern Tract, the former Sinclair Refining Co. & Walters oil stored and distributed petroleum products. Samples were not collected as per EPA approval, however, petroleum products are a contaminant of concern on the property.

1.3 Site Remedy

The proposed future redeveloped of the Site includes; four mixed use buildings, parking areas, a parking garage, and a trail connection (the Foundry).

The VM Development Group’s (VMDG) plan for the Foundry envisions the site being transformed into a $40M+ mixed-use community with approximately 20,000 square feet of commercial space and parking on the buildings’ first floors, approximately 200 residential units on the upper floors, and unique architecture focused on the environment, science, recreation, sustainability, nature, and art.

The City of Easton and VMDG are planning a synergistic relationship between The Foundry and nearby R&H Simon Silk Mill (which was also redeveloped by VMDG) to further encourage commercial tenants to the Corridor creating jobs and helping foster new business owners and entrepreneurs. The Foundry will also further foster pedestrian connectivity in the Corridor by connecting the Karl Stirner Arts Trail to pedestrian facilities along Bushkill Drive through the Site.

In addition to new businesses, the residential units will establish new opportunities for community growth and will create indirect economic impacts in the form of disposable income being directed to local businesses.

2 List of Contacts Owner:

City of Easton

Representative: John Kingsley Title: Director Department: Community and Economic Development Phone Number: 610-250-6719 Email: jkingsley@easton-pa.gov

Remediator:

To be determined

Developer:

VM Development Group, LLC

Representative: Gretchen Rice Phone Number: 610-330-9800 x3 Email: GRice@VMDgrp.com

Consultant HDR Engineering, Inc.

Representative: Vincent Carbone, PG Title: Senior Geologist/Project Manager Phone Number: D 610-807-5104, M 610- 972-8223 Email: Vincent.carbone@hdrinc.com

3 Remedial Alternatives Evaluation

3.1 Remedial Alternative Options

The following remedial alternatives were generated based on the previous remedial investigations and planned development of the Site.

Alternative Pros Cons Estimated Cost

1. Use a combination of capping, vapor barriers, and hot spot excavation to eliminate

• Eliminates Direct Contact and Soil to Groundwater pathways.

• Most cost-effective option.

• The cap will need regular inspections and periodic maintenance.

• Any planned disturbance would need to be managed by the Soil Management Plan.

• $2,500,000 (Based on redesign using impervious cap and cover, landscaping and institutional controls.)

exposure pathways.

• Future use of the Site will rely on Engineering controls to maintain elimination of pathway exposure.

2. Excavation of all impacted soil.

• Removes impacted soil and eliminates the need for engineering and institution controls.

• No need for cap maintenance or inspections.

• Impacted soil may be within the water table and this alternative could potentially require excavation of saturated materials.

• This would be the most expensive solution.

Impacted soil is estimated to span approximately 435,600 square feet across the two tracts.

• $10,000,000 (Based on estimated volume to remove scrap/soil mix to native soil.)

3. No Remediation on the Site and rely on natural attenuation to reduce contaminants over time.

• Least expensive.

• The Site will likely sit undeveloped, and contaminants will remain for extended periods of time through natural attenuation.

• Will require decades of monitoring to resolve residual impacts to soil.

• Metals and scrap material will not be removed maintaining potential source areas.

• $100,000/yr (Based on maintenance and security of the properties indefinitely.)

3.2 Recommended Remedial Alternative

The recommended remedial alternative for the Site is Option 1 in Section 2.1 above. This is the preferred alternative as it eliminates the current exposure pathways, ensures the Site will be adequately remediated as per the Site-Specific Standard based on the factors set forth in Section 304(j) of Act 2., and is the most cost-effective alternative. Hot Spot Excavation is detailed in Section 2.2.1 below and details of the Engineered control are described in Section

5.0 of this CP. If future redevelopment plans change, then the remediation alternatives will be reevaluated.

4 Treatability Studies Treatability studies were not completed as part of this CP or previous investigations and reporting efforts as treatment is not being proposed for remediation.

5 Design Plans and Specifications

5.1 Hot Spot Excavation

Three areas as shown on Attachment A indicate the hot spots that will be excavated in conjunction with redevelopment activities. Two hot spots are located on the northern tract and are associated with the following areas and contaminants of concern:

• Former leaking drum area- Total PCBs and lead

• Former scrap metal/acid battery storage/ and former waste pile storage area- Antimony, arsenic, iron, lead, mercury, and zinc

The total area in the northern tract to be excavated is estimated to be 337 cubic yards. One hot spot are located on the southern tract and are associated with the following areas and contaminants of concern:

• Former PCB transformer storage area- No samples collected, assumed PCBs

• Former scrap metal area- Total PCBs, Iron, Lead, Manganese, and Mercury.

The total areas in the southern tract for exaction is estimated to be1,450 cubic yards.

The areas will be excavated to a minimum of 3.5 feet below ground surface (bgs). Prior to excavation waste profile samples will be collected for disposal purposes based on the volume estimated for disposal. Once a disposal location has been identified, excavation will begin, and material will be directly loaded into lined (if necessary) dump trucks and hauled to the approved landfill. A copy of all manifests will be retained for documentation purposes.

Post excavation samples will be collected to confirm removal of the contaminated material. The 75/10x rule will be utilized to demonstrate attainment. The 75/10x rule states that a minimum of 75% of the samples will not exceed the applicable PADEP Non-residential standard nor will one sample exceed the standard by greater than 10 times. Once contaminated material is appropriately removed the areas will be backfilled with 2A modified stone in support of redevelopment activities. The areas will then be capped as per the Engineering design plans in Attachment B.

5.2 Engineering Controls

Pathway elimination for direct contact, soil to groundwater leaching, and vapor migration to indoor air will be accomplished by the controls described in this section in addition to the site use restrictions discussed in Section 5.2. The proposed engineering controls are included as Attachment B.

5.2.1 Vapor Retardant and Passive Vapor Control System

A passive vapor control system will minimize the potential for volatile organic vapors, that have been identified in subsurface soils underlying the Site, from migrating into the proposed buildings.

The passive vapor control system will consist of the following:

• 4 inch-Reinforced Concrete floor

• Three inches of a compacted 2A stone subbase

• Minimum of 10-mil Vapor Barrier Membrane- composite barrier designed to eliminate organic permeation

• Two cushion layers of eight-ounce geotextile fabric to protect the vapor barrier integrity

Vapor Barrier System details are provided in the below sections.

5.2.1.1 VAPOR BARRIER MEMBRANE

A polymer membrane will be installed beneath the concrete slab of the proposed building. The membrane will meet or exceed the criteria established in ASTM E1745, Standard Specification for Plastic Water Vapor Retarders used in Contact with Soil or Granular Fill under Concrete Slabs.

The membrane will be selected for its resistance to degradation from petroleum hydrocarbon constituents in the sub-surface. The vapor barrier will be installed directly beneath the concrete slab. Since the integrity of the membrane is critical to vapor permeation mitigation a layer of geotextile fabric will be placed below the vapor barrier to protect it from puncture during construction. Penetrations of the membrane for pipes and foundations will be sealed with materials (boots and/or tape) in accordance with the manufacture recommendations. To ensure compliance with manufacturer installation specifications, all membrane installation activities will be overseen by a qualified membrane installer. Attachment C presents a typical cross-section of the vapor barrier system and provides design details for sealing potential vapor entry points (seams, penetrations, and wall joints).

5.2.1.2 CUSHION LAYER

Two 8-ounce non-woven, needle punched (NWNP) geotextile fabric will be placed above and below the vapor barrier to protect it from puncture during construction. The cushion layer will be installed consistent with manufacturer recommendations.

5.2.2 Proposed Slab on Grade Buildings

One slab on grade mixed use building with an area of approximately 25,000 square feet each, will be constructed on the northern tract. The concrete slabs will consist of a minimum of 4-inches of air-entrained concrete with steel wire mesh reinforcement, underlain by the proposed vapor barrier discussed in Section 4.1.1 placed over compacted subgrade.

One slab on grade mixed use building with an area of approximately 23,000 square feet each, will be constructed on the southern tract. The concrete slabs will consist of 4-inches of air-entrained concrete with steel wire mesh reinforcement, underlain by 6-inches of 2A modified crushed aggregate (no slag), placed over compacted subgrade.

5.2.3 Proposed Asphalt Pavement Areas

Asphalt parking lots and driveways will be constructed to the north and east of the buildings on the northern tract as well at the eastern, western and southeastern areas of the southern tract.

Asphalt pavement will consist of 1 ½-inches of Superpave asphalt mixture wearing course, underlain by a 2-inch binder course, underlain by 6-inches of 2A aggregate subbase, placed over a geotextile demarcation fabric and compacted subgrade. The geotextile fabric will act as a warning barrier during any future earth disturbances. A typical cross-section of the proposed caps are included as Attachment C.

5.2.4 Landscaped Areas

Areas not paved or under a slab on grade foundation will be landscaped with grass, shrubs, and/or trees. These caps will include one foot of clean fill and a geotextile demarcation fabric prior to final landscaping. The geotextile fabric will act as a warning barrier during any future earth disturbances. Elevation measurements will be collected by a Pennsylvania Licensed Surveyor prior to and following the installation of the clean fill to document that the appropriate thickness of clean fill is placed. A recreational trail will be included in the edge of the landscaping for public access and will consist of 2-4 inches of bituminous pavement with a 4 inch 2A aggregate subbase.

5.3 Site Use Restrictions

Deed restrictions will be used to control future use of the Site, groundwater underlying the Site, and subsurface activities. These restrictions are as follows:

I. In no event shall the Site or any part thereof be used for any of the following purposes:

• Single family or multifamily grade level dwellings or otherwise as a residence or dwelling quarters, constructed on the base floor, for any person or persons;

• Camp grounds;

• Daycare centers, nurseries, kindergartens, elementary and secondary schools, vocational or technical schools, or similar facilities;

• Hospitals, nursing homes, shelters, group homes, or similar facilities;

• Cemeteries; and

• The planting and raising of plants for crops for human consumption.

II. Any digging, excavating, grading, pile driving or other earth moving activities shall be conducted at the Site or any part thereof including, without limitation, the excavation or removal of asphalt, concrete, soil or other ground cover and foundations and the digging of foundations for buildings and trenches for utilities, in compliance with all applicable federal, state and local rules, regulations and ordinances including, without limitation those pertaining to the environment and those pertaining to human health and occupational safety, and in compliance with the post remediation care plan or Soil Management Plan (SMP) approved by the PADEP and/or the USEPA as part of a Cleanup Plan.

III. Without limiting the generality of the foregoing if any asphalt, concrete, soil or other ground cover is excavated or removed from any part of the Site, such materials shall be stored, managed, transported, and disposed of in compliance with the Soil Management Plan approved by the PADEP and/or the USEPA as part of a Cleanup Plan.

IV. Groundwater underlying the property or any part thereof shall not be used for any purpose and no wells for the extraction thereof shall be installed, permitted or utilized on the Site or any part thereof; provided, however, monitoring wells may be installed and operated on the property by Seller, its successors and assigns solely for the purpose of monitoring, treating and remediation of such groundwater.

6 Post Remediation Care Plan

6.1 Construction Phase

To ensure appropriate controls are in place to prevent the runoff of impacted soil and/or residual materials the Site will be inspected by the Lot’s owner, or their designated representative, on a routine basis for erosion and/or damage during the construction phase of the project.

Additionally, the Site will be inspected annually for accidental or planned disturbance that require repair and/or restoration. The schedule of these inspections will depend on the level of construction activity, the level of storm water runoff, and other factors that may affect the integrity of the proposed cap. Inspections will document onsite erosion occurring at the Site and/or damage to the cap being installed and identify the corrective actions taken to mitigate the condition, e.g., replace soil and reseed, install erosion controls. Inspection reports will be maintained on file within the Site facility and one copy will be forwarded to the central office of the Northeast Regional office of PADEP.

Inspections will be replaced by the protocols specified in the SMP upon completion of construction. The SMP identifies the procedures to be followed when breaches to the cap occur, whether accidental or planned. The owner of the Site at that time will be responsible for adhering to the procedures and protocols set forth on the SMP.

6.2 Post-Construction Phase

Annual Cap Inspection

To ensure the integrity of engineering controls, the capped areas will be inspected by the owner, or designated representative, for damage to the cap on an annual basis. Inspections will document any damage to the cap and identify the corrective actions taken to mitigate the conditions. Corrective actions involving the repair/replacement of the engineering controls shall be performed in accordance with the SMP, which details procedures for material management and cap replacement. Inspection reports will be maintained on file within the Site facility and a copy will be forwarded to the Central and Northeast Regional office of PADEP. A Generic Cap Inspection Form is included as Attachment E of this report.

Planned Cap Disturbances

Future development and/or maintenance activities performed on the property may require existing engineering controls to be temporarily disturbed or removed. Procedures set forth in the SMP shall be followed by any parties that perform the work. As such, any engineering control that is disturbed or removed must be replaced with the same engineering control or another approved engineering control as described in the Cleanup Plan. If replacing the engineering control is not desired, the owner will characterize regulated substances in the soils/materials beneath the removed engineering control and manage or remediate those soils/materials in accordance with Act 2 and all applicable laws and regulations. The material management procedures cited in the SMP will be required at all times when conducting any intrusive activities that breach capped areas.

Institutional Controls

To ensure ongoing compliance with the Act 2 Site-Specific Standard, institutional controls have been recorded in the deed for the subject property. Details of the institutional controls are presented in Section 4.2 above. Furthermore, environmental covenants are referenced in the deed for the property. The deed and environmental covenant will be submitted under separate covers.

6.3 Operation and Maintenance of the Vapor Mitigation System

6.3.1 System Verification

Post-construction sampling will be indoor air sampling to verify the operational effectiveness of the vapor control system. The following procedures will be employed to collect and analyze the samples:

1. Directly following the completion of construction of the primary structural building components, but prior to interior build out, or habitation the owner’s representative will collect air samples from the interior of the buildings to determine the effectiveness of the vapor controls. One indoor air sample from the building. The indoor air will be analyzed for TCE, EPA method TO-15-SIM.

2. The analytical results of the indoor air samples will be compared to the PADEP SVIA. If there are no exceedances of these criteria, construction will proceed. If the indoor air samples exceed the SVIA, potential background vapor sources will be evaluated and removed if present. An Indoor air sample will then be recollected within two weeks, where necessary. If the resample results do not exceed the SVIA, construction will proceed If the recollected sample results exceed the action levels, construction will proceed, and a system upgrade may be recommended.

3. A report will be prepared and submitted to PADEP detailing the analytical results of the indoor air samples. The results for the COCs will be compared to the PADEP SVIA listed in Table 5 of the VI Technical Guidance Manual. Should established action levels be exceeded an appropriate response action will be developed using the decision matrix and recommended to the PADEP.

6.3.2 Annual Inspection

6.3.2.1 PASSIVE VAPOR CONTROL SYSTEM

On an annual basis the owner or owners representative will inspect the building’s foundation for cracks, depressions or other unconformities that may allow preferential pathways into the building. If identified the repair will be noted and maintained in the record.

6.3.3 Record Keeping and Reporting

Inspection reports for the annual inspections will be maintained on file within the Site facility and a copy will be forwarded to the northeast office of the PADEP upon request.

7 Cooperation or Agreement of Third Party The City of Easton upon approval of this Cleanup Plan agrees to provide access to the property(ies) as described in this Cleanup Plan as the Site, under the current address of 1100- 1164 Bushkill Drive, in Easton Pennsylvania, for the purpose of remediation and/or monitoring to the designated remediator and consultant. The designated remediator and/or consultant may be assigned by the owner of the property and or PADEP.

City of Easton Name: ___________________ Title: ____________________

Date: ___________________

8 Public Comments On January 10, 2022, a Notice of Intent to remediate (NIR) was published in the Express Times (Easton, Pennsylvania) and was provided to the local municipality on January 5, 2022. The NIR was submitted to the PADEP on January 14, 2022. In accordance with Act 2 regulations, the municipality was provided with a 30-day comment period and an opportunity to be involved in the development of the remediation and reuse plans for the property. Requests for involvement were not received because of the notices; therefore, a public-involvement plan was not required. The public notification regarding the submission of this Cleanup Plan was published on August 6, 2025 at the following location https://www.easton-pa.com/255/Current-Projects by the City of Easton.

A Community Relations Plan (CRP) was developed as part of the Cleanup Grant and the EPA Brownfield Cleanup Revolving Loan Fund (RLF) Grant awarded to the City of Easton for the https://nam12.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.easton-pa.com%2F255%2FCurrent-Projects&data=05%7C02%7Cvincent.carbone%40hdrinc.com%7C59a7a818a5d742b6fc9508ddf779aed7%7C3667e201cbdc48b39b425d2d3f16e2a9%7C0%7C0%7C638938824196143370%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=0PyZ40IQZ2IHHKE9VdjemuNOVfVuSN%2FT0gycOPbguQk%3D&reserved=0

Site. The CRP establishes procedures that allow the public and stakeholders to participate in the cleanup planning process and improve the public’s understanding and participation in the cleanup and redevelopment process.

9 Signatures

Qualified Environmental Professional Quality Control / Quality Assurance

Chelsea Tarbell, PG Vincent Carbone, PG

Geologist Senior Geologist/Program Manager

Professional Engineer

Brandon M. Walker, PE

Industrial Section Manager PA/OH/WV/DE

9.1 Qualifications of Environmental Professionals

This Cleanup Plan was prepared by the following HDR personnel:

Ms. Chelsea Tarbell, a geologist at HDR with 8 years of experience in the completion of environmental due diligence and liability activities. She has a B.A. in Geology from the University of Minnesota, Morris and is a licensed professional geologist in the state of Pennsylvania. Ms. Tarbell is experienced in the completion of large-scale environmental due diligence assessments including multi-township wide remediation investigations. Ms. Tarbell has been the technical lead on several environmental projects within the power, transportation, and industrial sectors across the United States. Her experience also encompasses ASTM 1527E-21 Phase I and Phase II assessments, emerging contaminants, remedial investigations, geophysical studies, hydrogeologic studies, interim remedial measures, site management, and operations, maintenance, and monitoring.

Mr. Brandon Walker has 22 years of experience in with a specialization in design of erosion and sediment control plans and stormwater management facilities associated with industrial and energy projects. Mr. Walker manages the Industrial Section for HDR’s PA/WV/OH/DE offices, where he leads a group of civil and mechanical engineers and designers. Prior to joining HDR, Brandon was a manager of an oil and gas engineering group in the Pittsburgh, Pennsylvania area and a project manager and lead engineer for several cross-country natural gas and liquids pipelines. He has performed civil and water resource design on small and large-scale projects and successfully designed wetland mitigation and stream restoration projects. Brandon’s additional experience includes preparing site grading for various types of facilities including compressor stations, Marcellus Shale well and brine injection well pads, beneficial use landfills, wind turbine power generation facilities, and clean waste fill disposal sites. He has prepared numerous types of earth disturbance permit applications for industrial, natural gas utility pipelines and compressor stations, plant wastewater discharge pipelines, and overhead transmission lines throughout the east coast and midwestern united states.

Quality Assurance / Quality Control was performed by the following HDR Personnel:

Mr. Vincent Carbone is a senior geologist and Professional Associate at HDR with over 33 years of experience in the completion of environmental due diligence, liability, and risk management activities. Mr. Carbone is the Due Diligence Technical Service Lead for HDR having performed numerous environmental due diligence assessments and reviews in the United States and Canada. Mr. Carbone is experienced in the completion of large-scale renewable power due diligence assessments including wind and solar facilities as large as 40 square miles. Mr. Carbone has completed many corridor due diligence assessments for transportation, power, and oil and gas clients. Mr. Carbone has also performed environmental due diligence on several large brownfield redevelopment projects throughout the United States.

Mr. Carbone has been the environmental manager for several complex decommissioning projects for several prominent utility companies including coal, combustion turbine, combined cycle and hydroelectric facilities in the United States and Canada. His experience also encompasses ASTM 1527E-21 Phase I and Phase II assessments, remedial investigations, geophysical studies, feasibility studies, interim remedial measures, site management, and operations, maintenance, and monitoring. Mr. Carbone is responsible for the geologic and hydrogeologic interpretation of geology and hydrogeology projects.

Sources: Esri, HERE, Garmin, USGS, Intermap, INCREMENT P, NRCan, Esri Japan, METI, Esri China (Hong Kong), Esri Korea, Esri (Thailand), NGCC, (c) OpenStreetMap contributors, and the GIS User Community

PATH: G:\JOBS\EIM\GIS\MAP_DOC\EIM_NOVEMBER2019_FIGS\FIG1_SITEMAP.MXD - USER: CTARBELL - DATE: 3/12/2020

SITE MAP

FIGURE 1

1100 BUSHKILL DR, EASTON PA

EASTON IRON AND METAL

0 0.2Miles O

LEGEND

Parcel Boundaries North Parcel

South Parcel

A Areas of Concern and Hot Spots for Excavation

(M)C0AE0

4/23/2024

1.0 to 2.0 ft bgs

SVOCs

13 mg/kg

16 mg/kg

19 mg/kg

MC0AH4

6.5 mg/kg

4/25/2024 Dibenz[a,h ]anthracene 3.2 mg/kg

1.0 to 2.0 ft bgs

Metals lndeno[1,2,3-cd]pyrene

Meta

11 mg/kg

45 mg/kg

66 mg/kg

5,400mg/kg

16,000 mg/kg

16 mg/kg

MC0AH5

4/25/2024

0.75 to 1.75 ft bgs

Metals

62 mg/kg

76 mg/kg

200,000 mg/kg

3,900 mg/kg

MC0AH2

4/25/2024

1.0 to 2.0 ft bgs

Date Saved: 01130125 EPA Contract No: 68HE032000003 TD No: 1604-23-05-001 Source: Esri, HERE, Garmin, (c) OpenStreetMap contributors, and the GIS user community

C0AF0

4/23/2024

0.0 to 1.0 ft bgs

PCB

91 mg/kg

11 mg/kg

100 mg/kg

EIM-5076

MC0AE3

4/23/2024

1.0 to 2.0 ft bgs

C0AF1

4/23/2024

MSC Soil to GW - PADEP SWHS MSC for organic and inorganic regulated substance in soil, soil to groundwater numeric values (higher values) for residential used aquifers with total dissolved solids s2,500 milligrams per liter (mg/I).

MSC DC Residential - PADEP SWHS MSC for organic and inorganic regulated substances in soil, direct contact numeric values for residential sites.

MSC DC Non-Residential O to 2 ft - PADEP SWHS MSC for organic and inorganic regulated substances in soil, direct contact numeric values for surface soil (0 to 2 feet) nonresidential sites.

MSC DC Non-Residential 2 to 15 ft - PADEP SWHS MSC for organic and inorganic regulated substances in soil, direct contact numeric values for subsurface soil.

Exceeds MSC DC Residential

Exceeds the MSC Soil to GW

Exceeds MSC DC Residential and Soil to GW

Exceeds MSC DC Redidential and Non-Residential O to 2 ft

Exceeds MSC Soil to GW, DC Residential and Non-Residential 1 to 2 ft

O Soil Boring Location

Former Railroad & Railroad Spur

• Former Areas of Leaking Drums

Approximate Area Where Lead Acid Battery Pieces Were Observed

Former Automotive Salvage

Former Filling Station and Automotive Repair Facility

Former Metal Scrap Yard

Former Waste Piles

Historical Contaminated Fill Material/ Asbestos-Containing Material in Fill

North Parcel of Site bgs = Below ground surface EIM = Easton Iron and Metal

FT=FEET

GW - Groundwater J = Estimated concentration qualifier mg/kg = Milligrams per kilogram MSC - Medium Specific Concentrations PADEP - Pennsylvania Department of

Environmental Protection PCB - Chlorinated biphenyls SWHS - Statewide Health Standards

N

40 0

Feet

Easton Iron and Metal Phase II ESA Easton, Northampton County, Pennsylvania

Figure 5

Soil Boring Locations With Detections Exceeding PADEP SWHS - North Parcel

Prepared For: EPA STAR T R3 Vl

[ "11;] TETRA TECH

Prepared By: K. Orzada

Coordinate System: NAO 1983 2011 StatePlane Pennsylvania South FIPS 3702 Ft US

SPRABHUDEV

Polygon

SPRABHUDEV

PolyLine

SPRABHUDEV

Text Box

AREA A

SPRABHUDEV

Text Box

AREA B

(M)C0AG7

4/24/2024

1.0 to 2.0 ft bgs

PCB

12 mg/kg

6 mg/kg

15 mg/kg

33 mg/kg

MC0AA2 Metals

4/24/2024 280 mg/kg

74 mg/kg

210,000 mg/kg

1 ,400 ITVJ/kg

2,600 mg/kg

6,800 mg/kg

11 mg/kg

MC0AG6

4/24/2024

1.5 to 2.0 ft bgs

Metals

29 mg/kg

11,000 mg/kg

16,000 mg/kg

Exceeds MSC DC Residential

Exceeds the MSC Soil to GW

Exceeds MSC DC Residential and Soil to GW

Exceeds MSC DC Redidential and Non-Residential 0 to 2 ft

Exceeds MSC Soil to GW, DC Residential and Non-Residential 1 to 2 ft

Date Saved: 01130125 EPA Contract No: 68HE032000003 TD No: 1604-23-05-001 Source: Esri, HERE, Garmin, (c) OpenStreetMap contributors, and the GIS user community

C0AG1

4/24/2024

MC0AG3

4/24/2024

MC0AF9

4/24/2024

2.0 to 3.0 ft bgs

Metals

47 J mg/kg

480,000 mg/kg

680 mg/kg

3,000 mg/kg

930 mg/kg

MSC Soil to GW - PADEP SWHS MSC for organic and inorganic regulated substance in soil, soil to groundwater numeric values (higher values) for residential used aquifers with total dissolved solids s2,500 milligrams per liter (mg/I).

MSC DC Residential - PADEP SWHS MSC for organic and inorganic regulated substances in soil, direct contact numeric values for residential sites.

MSC DC Non-Residential O to 2 ft - PADEP SWHS MSC for organic and inorganic regulated substances in soil, direct contact numeric values for surface soil (0 to 2 feet) nonresidential sites.

MSC DC Non-Residential 2 to 15 ft -…