36C78618R0051-005.pdf

Department of Veterans Affairs Washington, DC

Phase I Environmental Site Assessment Proposed National Veterans Burial Ground

5 Acres South of Hildreth Road Cheyenne, Wyoming

December 2014

Teamwork - Trust - Leadership Since 1927

44265 Plymouth Oaks Blvd.

Plymouth, MI 48170

T 734-455-8600 F 734-455-8608 www.ttlassoc.com

November 25, 2015 TTL Project No. 11854.01

Department of Veterans Affairs c/o Mr. Richard Banchoff ISI Professional Services 1201 15th Street, NW, Suite 200 Washington, DC 20005

Phase I Environmental Site Assessment Proposed National Veterans Burial Ground

5 Acres South of Hildreth Road Cheyenne, Wyoming

Dear Mr. Banchoff:

The final report for the Phase I Environmental Site Assessment (ESA) conducted for the Department of Veterans Affairs (VA) by TTL Associates, Inc. (TTL) for the above-referenced site is enclosed.

This project was performed in conformance with the requirements specified in the American Society for Testing and Materials (ASTM) “Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process,” E 1527-13. The purpose of this Phase I ESA was to identify, to the extent feasible pursuant to the processes described in ASTM E 1527-13, Recognized Environmental Conditions in connection with the site.

TTL appreciates the opportunity to provide ISI Professional Services and VA with our environmental services. Should you have any questions or require additional information, please contact Rob Clark at (734) 582-4902.

Sincerely, TTL Associates, Inc.

Paul J. Jackson Robin J. Clark Environmental Scientist Senior Scientist

V:\Toledo\VA\Cheyenne WY Cemetery\Site 1 Report Docs\Site 1 (5 acres) Ph I ESA 12-15-14.doc

PHASE I ENVIRONMENTAL SITE ASSESSMENT

PROPOSED NATIONAL VETERANS BURIAL GROUND

5 ACRES SOUTH OF HILDRETH ROAD

CHEYENNE, WYOMING

FOR

DEPARTMENT OF VETERANS AFFAIRS

CFM, REAL PROPERTY SERVICE

425 I STREET, NW

WASHINGTON, DC

DECEMBER 16, 2014

TTL PROJECT NO. 11854.01

TTL ASSOCIATES, INC.

44265 PLYMOUTH OAKS BOULEVARD

PLYMOUTH, MICHIGAN 48170

(734) 455-8600

FAX: (734) 455-8608

Proposed National Veterans Burial Ground, Cheyenne, WY December 2014 TTL Project No. 11854.01 Page i

TABLE OF CONTENTS

Page No.

EXECUTIVE SUMMARY .......................................................................................................E-1

1.0 INTRODUCTION

1.1 Purpose and Scope of Work

1.2 Limitations and Exceptions of Assessment

1.3 User Provided Information

1.3.1 Reason for Performing the Phase I ESA

1.3.2 Environmental Liens and Activity and Use Limitations

1.3.3 Specialized Knowledge

1.3.4 Commonly Known or Reasonably Ascertainable Information

1.3.5 Valuation Reduction for Environmental Issues

1.4 Additional Services

2.0 SITE DESCRIPTION

2.1 Site Location and Legal Description

2.2 Site Utilities

2.3 Physical Setting

2.3.1 Topography

2.3.2 Soils/Geology

2.3.3 Hydrology

3.0 SITE HISTORICAL/RECORDS REVIEW

3.1 Summary of Historical/Records Review

3.2 Ownership Information

3.3 Prior Use Interviews with Owner(s) and Occupant(s)

3.4 Local Government Agency Record Review

3.5 Historical Maps

3.6 Historical City Directories

3.7 Aerial Photographs

3.8 Previous Environmental Reports

4.0 SITE RECONNAISSANCE

4.1 Methodology and Limiting Conditions

4.2 Site Description and Current Uses

4.3 Detailed Site Observations

TTL Project No. 11854.01 Page ii

TABLE OF CONTENTS (CONTINUED)

Page No.

5.0 REGULATORY FILE SEARCH

6.0 CURRENT AND HISTORICAL USES OF ADJOINING PROPERTIES

7.0 DATA GAPS

8.0 OPINION

9.0 DECLARATION

10.0 REFERENCES AND RECORDS OF COMMUNICATION

TABLES

Table 1.0 Summary of Historical Site Uses Table 2.0 Summary of Site Observations Table 3.0 Facilities Identified on the ASTM-Specified Federal, State and Tribal Databases

FIGURES

Figure 1.0 Site Location Map (USGS Topographic Map) Figure 2.0 Site Sketch

APPENDICES

Appendix A: Local Government Agency Records Appendix B: Questionnaires Appendix C: Historical Maps Appendix D: Aerial Photographs Appendix E: Site Photographs Appendix F: Environmental Database Report Appendix G: TTL Team Resumes

TTL Project No. 11854.01 Page E-1

EXECUTIVE SUMMARY

This report presents the methodology and findings of a Phase I Environmental Site Assessment (ESA) conducted for the Department of Veterans Affairs (VA) by TTL Associates, Inc. (TTL) in November and December 2014 for approximately five acres of land located south of Hildreth Road in Cheyenne, Laramie County, Wyoming (site). The site is one of two properties being considered by VA for the establishment of a National Veterans Burial Ground. This Phase I ESA was performed in conformance with the scope and limitations of the American Society for Testing and Materials (ASTM) “Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process,” E 1527-13. The purpose of this Phase I ESA was to identify, to the extent feasible pursuant to the processes prescribed in ASTM E 1527-13, Recognized Environmental Conditions (RECs) in connection with the site through site reconnaissance, interviews, and a review of reasonably ascertainable regulatory and historical documentation.

Findings and Opinions

The site is approximately five acres in area and is included within the southwestern portion of an approximately 2,192-acre parcel owned by the City of Cheyenne. The site is currently unimproved vacant land with a dirt road crossing the central portion of the site from north to south. The site has been unimproved agricultural research land and grazing land since at least 1911. The site was leased by the City to the US Department of Agriculture (USDA) and used as part of the USDA Cheyenne Horticultural Field Station from 1928 to 1974 and High Plains Grassland Research Station from 1974 to 2007. Since 2007, the site has been grassy vacant land associated with the City’s High Plains Arboretum.

Based upon the information obtained and evaluated as part of this Phase I ESA, the following suspect environmental conditions were identified in association with the site:

• The USDA Agricultural Research Service facility (8408 Hildreth Road), located approximately 300 feet north of the site, was identified as a Resource Conservation and Recovery Act (RCRA) – conditionally exempt small quantity generator (CESQG), underground storage tank (UST or TANKS), leaking UST (LTANKS), Solid and Hazardous Waste Facility (SHWF), and Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) – No Further Remedial Action Planned (NFRAP) facility. The site was included in the land operated by this facility from 1928 to 2007. The RCRA and SHWF databases indicate that the USDA facility has been a generator of hazardous wastes since at least 1990. One violation pertaining to “used oil generator” was reported in August 1997 with compliance in September 1997. An additional compliance evaluation inspection was conducted in July 2011 with no reported violations. No spills or releases were identified associated with the RCRA listing. Mr. Shane Hott, Maintenance Supervisor for the USDA facility indicated that hazardous substance handling and storage at the USDA facility is conducted in a building located approximately 600 feet north of the site. Based on the distance of this area from the site and the absence of reported spills or releases associated

TTL Project No. 11854.01 Page E-2 with the RCRA activities, the small quantity hazardous material storage and handling at the USDA facility is not considered to be a REC in connection with the site.

The UST (TANKS) database indicated that the USDA facility included one 560-gallon diesel UST and one 560-gallon gasoline UST that were installed in October 1957 and removed in January 1991. Leaks were detected from both USTs. The LTANKS database indicated that a release from a UST system occurred and received regulatory closure. According to information from the Wyoming Department of Environmental Quality (WDEQ), regulatory closure was received in May 2003. According to Mr. Hott, the former USTs were located approximately 400 feet north of the site. Based on the removal of these USTs, the regulatory closure for the associated release, and their distance from the site, the former USTs are not considered to be a REC in connection with the site.

The CERCLA-NFRAP database indicated that the facility was discovered in December 1989, Preliminary Assessment was completed in September 1993 and determined that the facility did not qualify for listing on the National Priority List (NPL), and the facility was archived in September 1993. No additional information was available from the CERCLA-NFRAP database. Information provided by the USDA indicated that the CERCLA-NFRAP database listing is associated with a landfill area located approximately 500 feet southeast of the site.

Based on its regulatory status (non-NPL), distance from the site, and downgradient location from the site, the USDA landfill is not considered to be a REC with respect to the site.

Conclusions

TTL has performed a Phase I ESA of the site in conformance with the scope and limitations of ASTM E 1527-13. Any exceptions to, or deletions from, this practice are described in Section

1.2 of this report. This Phase I ESA has revealed no evidence of RECs in connection with the site.

Recommendations

TTL recommends no further action at this time.

TTL Project No. 11854.01 Page 1

1.0 INTRODUCTION

This report presents the methodology and findings of a Phase I Environmental Site Assessment (ESA) conducted for the Department of Veterans Affairs (VA) by TTL Associates, Inc. (TTL) in November and December 2014 for five acres of land located south of Hildreth Road in Cheyenne, Laramie County, Wyoming (site). The Phase I ESA has been performed in conformance with the scope and limitations of the American Society for Testing and Materials (ASTM) "Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process,” E 1527-13.

1.1 Purpose and Scope of Work

The purpose of this Phase I ESA was to identify, to the extent feasible pursuant to ASTM E 1527-13, Recognized Environmental Conditions (RECs) in connection with the site. RECs are defined as:

“The presence or likely presence of any hazardous substances or petroleum products in, on, or at a property (site): 1) due to any release to the environment; 2) under conditions indicative of a release to the environment; or 3) under conditions that indicate a material threat of a future release to the environment.” The term does not include de minimis conditions that generally do not present a threat to human health or the environment and that generally would not be the subject of an enforcement action if brought to the attention of the appropriate governmental agencies. The term includes hazardous substances or petroleum products even under conditions in compliance with laws.

The ASTM E 1527-13 Phase I ESA scope of work consists of four components: records review, site reconnaissance, interviews, and a report. All conclusions made in this report are based upon the assessment performed and are subject to the Limitations and Exceptions presented in Section

1.2 and the Data Gaps as presented in Section 7.0 of this report.

1.2 Limitations and Exceptions of Assessment

The information contained in this report was prepared for VA and is intended for its sole use.

Only the party noted above may rely on the information contained within this Phase I ESA report. Written consent from VA is required to release any or all information contained in this report to other users. The scope of the services performed in this Phase I ESA might not be appropriate to satisfy the needs of other users; any use or reuse of this document without prior written consent is at the sole risk of said user.

The conclusions and recommendations presented in this report are professional opinions based solely upon the information described in this report and TTL's interpretation of this information.

The information presented in this report was compiled and evaluated using generally accepted environmental assessment practices. The information, conclusions, and recommendations are intended exclusively for the purpose outlined herein.

TTL Project No. 11854.01 Page 2

TTL has reviewed the available information for this site and will not be responsible for conditions arising from concealed, withheld, or incorrect information. In addition, areas that were not accessible or that would have required demolition in order to investigate, such as pavement, walls, and floors were not inspected. No air quality monitoring or chemical analyses of building materials, soil, surface water, drinking water, or groundwater were performed as part of this assessment, except as noted within this report.

No Phase I ESA can wholly eliminate uncertainty regarding the potential for RECs in connection with the site. Performance of a Phase I ESA within the scope and limitations of the ASTM E 1527-13 standard is intended to reduce, but not eliminate, uncertainty regarding the potential for RECs in connection with the site, subject to reasonable limits of time and cost.

The limitations of, and exceptions to, this Phase I ESA include:

• Overgrown vegetation limited observations of the site’s ground surface.

• The information contained in this report is accurate only to the degree implied by the methods used in conducting this Phase I ESA.

• The data presented in this report are qualitative, because sampling and subsequent analyses were not included in the scope of work.

• The information obtained from publicly available sources is presumed to be reliable.

• Only those records, resources, and information which could be reasonably obtained within the time limitations dictated and set forth by our client were utilized in the performance of this Phase I ESA.

• Information revealed by person(s) interviewed is presumed to be accurate and truthful.

• The following considerations, not intended to be an all-inclusive list, are outside the scope of the ASTM E 1527-13 standard and are not included within the performance of this Phase I

ESA:

- Asbestos-containing materials survey.

- Radon testing.

- Lead-based paint testing.

- Lead in drinking water.

- Wetlands determination or delineation.

- Regulatory compliance.

- Cultural and historical resources.

- Industrial hygiene.

- Health and safety.

- Ecological resources.

- Endangered species.

TTL Project No. 11854.01 Page 3

- Indoor air quality.

- Biological agents.

- Mold.

- High voltage power lines.

- Soil and/or groundwater testing.

This report does not represent a legal opinion, a guarantee, warranty, or a certification. The current conclusions do not result in any warranty that the site does not contain unidentified regulated materials. Should additional surface, subsurface, or chemical data become available, the findings and conclusions contained in this report shall not be considered valid unless these data are reviewed and the conclusions of the report are modified or approved in writing by TTL.

1.3 User Provided Information

ISI Professional Services retained TTL to perform this assessment on behalf of VA. The following information was provided to TTL regarding the purpose of performing this Phase I ESA and any existing environmental information that VA may have regarding the site.

1.3.1 Reason for Performing the Phase I ESA

This Phase I ESA was requested in connection with an anticipated property transaction. VA intends to purchase one of two properties in Cheyenne, Wyoming for the development of National Veterans Burial Ground. The site is one of the properties under consideration for the proposed National Veterans Burial Ground.

1.3.2 Environmental Liens and Activity and Use Limitations

VA representatives indicated that they were unaware of environmental cleanup liens or activity and use limitations (AULs), institutional or engineering control restrictions, for the site.

1.3.3 Specialized Knowledge

VA indicated that is has no special knowledge of the site.

1.3.4 Commonly Known or Reasonably Ascertainable Information

VA indicated that the site is currently unimproved land owned by the City of Cheyenne that was formerly used by the US Department of Agriculture (USDA).

1.3.5 Valuation Reduction for Environmental Issues

VA indicated that the proposed purchase price for the site is consistent with the fair market value for the property, as determined through a real estate appraisal. There is no indication that the

TTL Project No. 11854.01 Page 4 purchase price has been reduced because contamination is known or believed to be present at the site.

1.4 Additional Services

TTL did not perform additional services beyond the ASTM E 1527-13 scope of work for this Phase I ESA.

TTL Project No. 11854.01 Page 5

2.0 SITE DESCRIPTION

This section discusses the site location and legal description, site utilities, and the site’s physical setting characteristics.

2.1 Site Location and Legal Description

Site Address(es): No address, five acres south of Hildreth Road in the western portion of the High Plains Arboretum, City of Cheyenne, Laramie County, Wyoming

Historical Site Address(es): No historical/additional addresses were identified

Side of the Street: Approximately 300 feet south of the west end of

Hildreth Road

Nearest Intersection: Approximately 4,700 feet west of the intersection of

Hildreth and Round Top Roads

Parcel Number(s): Approximately five acres in the southwestern portion of 14670810000200 (approximately 2,192 acres)

Zoning: Public (P)

The site is approximately 5 acres in area and is included in the southwestern portion of an approximately 2,192-acre parcel owned by the City of Cheyenne, as designated above. The site is currently unimproved vacant land with a dirt road crossing the central portion of the site from north to south. Refer to Figure 1.0, which is a map indicating the approximate location of the site and Figure 2.0, which depicts the site features. A plat map, which illustrates the approximate boundaries of the 2,192-acre parcel that includes the site, was obtained from the Laramie County internet website and is included in Appendix A.

2.2 Site Utilities

Current/Former Water Supply: Municipal water is provided to the site vicinity by the

City of Cheyenne. The site has been unimproved land since at least 1911 and is unlikely to have included an historic water supply.

Current/Former Sewage Connection: Properties in the vicinity of the site are serviced by private septic systems. The site has been unimproved land since at least 1911 and is unlikely to have included an historic septic system. However, Mr. Justin Derner, USDA representative, stated that a septic system line that relays wastes from the USDA facility buildings

TTL Project No. 11854.01 Page 6 located north of the site to a septic field located approximately 600 feet southeast of the site crosses the site from the north-central boundary to the southeast corner. Mr. Derner indicated that he is not aware of any problems associated with the septic system line.

Current/Former Heating Supply: Natural gas is provided to the site vicinity by Cheyenne Light, Fuel, and Power. The site has been unimproved land since at least 1911 and is unlikely to have included an historic heating supply system.

Based on the distance of the leach field from the site and reported absence of problems associated with the line, the septic system line is not considered to be a REC with respect to the site.

2.3 Physical Setting

This section discusses the topography, geology, and hydrology in the vicinity of the site. An understanding of the site’s physical setting is necessary to evaluate the potential for impact to the site from possible RECs at and in the vicinity of the site.

2.3.1 Topography

The Round Top Lake, Wyoming United States Geological Survey (USGS) Topographic Quadrangle (dated 2012) indicates that surficial topography at the site [elevation approximately 6,245 feet above mean sea level (amsl)] slopes to the southeast towards Crow Creek (elevation approximately 6,170 feet amsl), located approximately one mile southeast of the site. The site is located in a northwest-southeast trending valley between Round Top (elevation 6,400 feet amsl) to the north and a 6,400 feet amsl hill to the south. The nearest surface water body is a small detention pond located approximately 100 feet northeast of the site. Round Top Lake and Round Top Reservoir, the source of municipal water supplied to the site area, are located approximately 3,000 feet northeast of the site.

2.3.2 Soils/Geology

According to the Wyoming State Geological Survey (WGS), the City of Cheyenne is located in the Denver-Cheyenne Basin of the High Plains Subdivision of the Great Plains Physiographic Province and is characterized by nearly horizontal strata of Late Tertiary age.

According to the USDA Natural Resources Conservation Service (NRCS) Web Soil Survey, the site contains three soil types identified as Albinas loam, 0 to 6 percent slopes (central and southeastern portions), Altvan loam, 0 to 6 percent slopes (northern portion), and Evanston loam, 0 to 6 percent slopes (southwestern corner). These soils are characterized as well drained soils with moderately high to high permeability and a water table greater than 80 inches below ground surface (bgs).

TTL Project No. 11854.01 Page 7

Mr. Todd Feezer of the City of Cheyenne Parks and Recreation Department indicated that 10 feet deep soil borings were conducted at the site and easterly adjacent property in early 2014 to assess if the soil and water table conditions were suitable for a cemetery. Soils at the site were reported to consist of topsoil from the ground surface to 2 feet bgs, clay from 2 to 3 feet bgs, gravel from 3 to 4 feet bgs, and clay from 4 to 10 feet bgs.

2.3.3 Hydrology

Individual private water wells are generally not currently used in the site area for drinking water as indicated by the presence of a public drinking water supply system.

According to the WGS, the site vicinity is underlain by the Ogallala aquifer and the underlying White River aquifer, characterized by late Miocene to early Pliocene-aged coarse sedimentary rocks and fine-grained sandstone with interbedded beds of tuff and bentonite, and discontinuous lenses of arkose and conglomerate, respectively.

Mr. Feezer stated that four shallow groundwater piezometers were installed at the site and the easterly adjoining property to assess the suitability of the area for a cemetery. One of the piezometers was installed on the site. Water levels in the on-site piezometer, which was installed at a depth of 10 feet bgs, ranged from 7.3 to 7.4 feet bgs during March through June 2014.

Site-specific information pertaining to the groundwater flow direction was not identified during this assessment. The groundwater table often mimics the ground surface topography. Therefore, groundwater in the site vicinity is inferred to flow to the southeast towards Crow Creek.

TTL Project No. 11854.01 Page 8

3.0 SITE HISTORICAL/RECORDS REVIEW

The review of historical sources is utilized to develop a history of the previous uses of the site, in order to help identify the likelihood of past uses having led to RECs in connection with the site.

3.1 Summary of Historical/Records Review

A review of historical resources identified during the performance of this Phase I ESA has identified the following current/historical uses of the site:

Table 1.0 Summary of Historical Site Uses

Year Identified Use(s)

At Least 1911 to Present

The site has been unimproved agricultural research land and grazing land since at least 1911. The site was used by the USDA as part of the Cheyenne Horticultural Field Station from 1928 to 1974 and High Plains Grassland Research Station from 1974 to 2007. From the 1940s until the 1980s, the site contained plants and nursery stock. Since at least 1990, the site has been grassy land. In 2007 the site reverted to the City of Cheyenne to become part of the High Plains Arboretum.

The identified historical and current uses of the site are not considered to be RECs in connection with the site.

3.2 Ownership Information

Site ownership information obtained from City of Cheyenne and Laramie County indicates that the site is currently owned by the City of Cheyenne. Information provided by the USDA indicates the site was leased to the USDA from 1928 to 2007 as part of the High Plains Grassland Research Station; however, the lease associated with the site and surrounding land was terminated in 2007 in order to establish the High Plains Arboretum.

3.3 Prior Use Interviews with Owner(s) and Occupant(s)

TTL interviewed Mr. Todd Feezer of the City of Cheyenne Parks and Recreation Department, the current site owner representative; Mr. Justin Derner of the USDA, former site occupant representative; and Mr. Shane Hott, Maintenance Supervisor for the USDA facility, to obtain information to assist in the identification of RECs in connection with the site. Mr. Feezer, Mr.

Derner, and Mr. Hott were unaware of any environmental concerns associated with the site. Mr.

Feezer, Mr. Derner, and Mr. Hott indicated that the site has been unimproved land used by the USDA for agricultural research and livestock grazing from 1928 until 2007. Mr. Derner stated the USDA facility that included the site was operated as horticultural field research station that planted and propagated trees, shrubs, vegetables, flowers, and grasses from 1928 through 1974

TTL Project No. 11854.01 Page 9 and was operated as grasslands/grazing research station after 1974. Mr. Derner and Mr. Hott also indicated that a septic system line currently crosses the site from the north-central boundary to the southeast corner. The septic system line reportedly relays wastes from the USDA facility buildings located north of the site to a septic field located approximately 600 feet southeast of the site.

Mr. Derner indicated that a shop/pesticide storage building may have been located on the site historically; however, Mr. Hott stated the shop/pesticide storage building was located approximately 600 feet north of the site. Mr. Hott also stated that all the current and former buildings associated with the USDA facility are located at least 150 feet north of the site.

Questionnaires regarding the availability of “helpful documents” (as defined by ASTM E 1527-

13) pertaining to liens, recorded activity and use limitations, environmental violations, permits, previous environmental reports, and/or other environmental documents for the site were completed by Mr. Feezer and Mr. Derner, and are provided in Appendix B. Key Site Manager Questionnaires were also completed by Mr. Feezer and Mr. Derner, and are provided in Appendix B. Available information provided by Mr. Feezer and Mr. Derner is discussed in its respective section of this report.

3.4 Local Government Agency Record Review

The following agencies were contacted to obtain information regarding potential environmental concerns associated with the site:

• Cheyenne Fire Department (CFD)

• City of Cheyenne Parks and Recreation Department (CPRD)

• Laramie County Internet Website

• Laramie County Health Department (LCHD)

The CFD and CPRD were contacted for environmental information concerning the site. The CFD and CPRD indicated that they had no environmental records for the site.

The Laramie County internet website indicated that the site is located in the southwestern part of an approximately 2,192-acre parcel owned by the City of Cheyenne. No environmentally significant information was identified from the Laramie County internet website.

The LCHD was contacted for environmental information concerning the site. No response was received within the timeframe of this Phase I ESA.

Copies of the information provided by local agencies are included in Appendix A.

3.5 Historical Maps

Environmental Data Resources, Inc. (EDR) indicated that historical Sanborn Fire Insurance maps are not available for the site area. Historic topographic maps dated 1911, 1914, 1950, 1954, TTL Project No. 11854.01 Page 10

1961, 1981, and 2012 were obtained from USGS. The site is depicted as unimproved land on each of the historic topographic maps. The site is depicted as part of the USDA Horticultural Field Station in the historic topographic maps dated from 1950 to 2012.

Copies of the historical maps reviewed are included in Appendix C.

3.6 Historical City Directories

Historical city directory information was not available for the site.

3.7 Aerial Photographs

Aerial photographs of the site and vicinity dated 1947, 1976, 1978, 1980, 1990, 1991, 2001, 2006, 2009, and 2012 were obtained from EDR. An aerial photograph of the site and vicinity dated 2014 was obtained from the Google Earth internet website. The site is depicted as unimproved land with a road crossing the central portion of the site from north to south in each of the aerial photographs. The 1947 through 1980 photographs depict the site with plants/nursery stock in east-west oriented rows. Subsequent aerial photographs depict the site as grassy land.

Due to the poor quality and scale of some of the aerial photographs reviewed, the level of ascertainable detail was limited. Copies of the aerial photographs reviewed are included in Appendix D.

3.8 Previous Environmental Reports

No previous environmental reports were provided to TTL by VA or site representatives.

TTL Project No. 11854.01 Page 11

4.0 SITE RECONNAISSANCE

This section discusses the observations of the site during field activities.

4.1 Methodology and Limiting Conditions

Field activities were conducted by Ms. Carrie Hess of TTL on December 4, 2014. These activities included a grounds reconnaissance to observe site conditions to identify RECs, if any, at the site and adjoining properties. TTL’s systematic approach for performing the site reconnaissance was to obtain overlapping views of the site. Refer to Figure 2.0 for the approximate locations of pertinent site features. Photographs of the site, pertinent site features, and surrounding properties are included in Appendix E.

On the day of the site visit, the weather was cloudy, with temperatures in the upper 40s.

4.2 Site Description and Current Uses

Roadway access to the site is currently available from an unnamed dirt road along the northern site boundary. The site is currently unimproved grassy vacant land with a dirt road crossing the central portion of the site from north to south. A small tree nursery (two rows of conifers less than 12 inches tall) is located along the western site boundary.

4.3 Site Observations

TTL’s site observations that were performed to identify potential RECs in connection with the site are summarized below in Table 4.0.

TTL Project No. 11854.01 Page 12

Table 2.0

Summary of Site Observations Observed On-site?

Comments Yes No Possible

Hazardous Material Storage and/or Handling

X

Petroleum Products Storage and/or Handling

X

Electrical Transformers X Hydraulic Lifts X Floor Drains and/or Sumps X USTs X ASTs X Noxious Odors X Pools of Liquid X Staining (Interior or Exterior) X Stressed Vegetation X Pits, Ponds, or Lagoons X Filled Areas X Wells (drinking, monitoring, dry)

X One piezometer is located in the northwestern portion of the site.

Septic System X Other Observations X

One piezometer was observed in the northwestern portion of the site. Mr. Feezer indicated that the piezometer was installed at the site at a depth of approximately 10 feet bgs to assess the depth to groundwater and to evaluate the suitability of the site for a cemetery. The piezometer is not indicative of a known or suspected spill and is not considered to be a REC.

No other potential environmental concerns were identified during the site reconnaissance.

TTL Project No. 11854.01 Page 13

5.0 REGULATORY FILE SEARCH

EDR was contracted to perform a search of ASTM-specified federal, state and tribal databases to obtain information that will assist in the identification of potential RECs in connection with the site. This database report identifies known facilities of environmental concern within their respective minimum search distance radii as specified by ASTM E 1527-13. A copy of the EDR report is presented in Appendix F. The federal, state and tribal databases researched and their respective minimum search distances are summarized below.

Federal Records

• National Priority List (NPL) – 1.0 mile radius

• Delisted NPL – 0.5 mile radius

• Comprehensive Environmental Response, Compensation, and Liability Information System

(CERCLIS) – 0.5 mile radius

• CERCLIS No Further Remedial Action Planned (NFRAP) – 0.5 mile radius

• Resource Conservation and Recovery Act (RCRA)

- Treatment, Storage, and Disposal (TSD) facilities – 0.5 mile radius

- Corrective Action Facilities (CORRACTS) – 1.0 mile radius

- Small Quantity Generators (SQG) – Site and Adjoining

- Large Quantity Generators (LQG) – Site and Adjoining

• Emergency Response Notification System (ERNS) – Site

• Institutional Control/Engineering Control Registries – Site

• Facility Index System (FINDS) – Site

State and Tribal Records

• State and Tribal Hazardous Waste Sites (SHWS) – 1.0 mile radius

• Solid Waste Landfills and Solid Waste Disposal Sites – 0.5 mile radius

• Underground Storage Tanks (USTs) – Site and Adjoining

• Leaking Underground Storage Tanks (LUST) – 0.5 mile radius

• State Incident Management Database (IMD) – 0.5 mile radius

• Institutional Control/Engineering Control Registries – 0.5 mile radius

• Voluntary Cleanup Sites – 0.5 mile radius

• Brownfield Sites – 0.5 mile radius

Table 3.0 summarizes the facilities identified in the ASTM-specified federal, state and tribal databases within the respective search distances and 0.5 mile from the site. Properties greater than 0.5 mile from the site are not considered to be potential RECs due to their distance from the site. Table 3.0 also provides an evaluation of each identified property as a potential REC based on its regulatory status, distance, or direction from the site. Groundwater is inferred to flow to the southeast in the site area based on topography.

TTL Project No. 11854.01 Page 14

Table 3.0

Facilities Identified on the ASTM-Specified Federal, State and Tribal Databases

Facility Name and Address Database Listing Approximate Distance and

Direction from Site

REC

(Yes/No)

USDA Agricultural Research Service 8408 Hildreth Road

RCRA-CESQG

UST (TANKS)

LTANKS

SHWF

CERCLA – NFRAP

Financial Assurance

600 feet north (RCRA), 400 feet north (UST and

LTANKS), and 500 feet southeast

(CERCLA-NFRAP)

No

The USDA Agricultural Research Service facility (8408 Hildreth Road), is located approximately 300 feet north of the site, and was identified as a Resource Conservation and Recovery Act (RCRA) – conditionally exempt small quantity generator (CESQG), UST (TANKS), LTANKS, Solid and Hazardous Waste Facility (SHWF), and CERCLA – NFRAP facility. The site was included in the land operated by this facility from 1928 to 2007. The RCRA and SHWF databases indicate that the USDA facility has been a small quantity generator of hazardous wastes since at least 1990. One violation pertaining to “used oil generator” was identified in August 1997 with compliance in September 1997. An additional compliance evaluation inspection was conducted in July 2011 with no reported violations. No spills or releases were identified associated with the RCRA listing. Mr. Hott indicated that hazardous substance handling and storage at the USDA facility occurs in a building located approximately 600 feet north of the site. Based on the distance of this area from the site, and the absence of reported spills or releases associated with the RCRA activities, the small quantity hazardous material storage and handling at the USDA facility is not considered to be a REC in connection with the site.

The UST (TANKS) database indicated that the USDA facility included one 560-gallon diesel UST and one 560-gallon gasoline UST installed in October 1957 and removed in January 1991.

Leaks were detected from both USTs. The LTANKS database indicated that a release from a UST system occurred and received regulatory closure. No additional information was reported in the LTANKS database. According to information obtained from the Wyoming Department of Environmental Quality (WDEQ), regulatory closure was received in May 2003. According to Mr. Hott, the former USTs were located approximately 400 feet north of the site. Based on the removal of these USTs, the regulatory closure of the associated release, and their distance from the site, the former USTs are not considered to be a REC in connection with the site.

The CERCLA-NFRAP database indicated that the facility was discovered in December 1989, Preliminary Assessment was completed in September 1993 and determined that the facility did not qualify for listing on the National Priority List (NPL), and the facility was archived in September 1993. No additional information was available from the CERCLA-NFRAP database.

Information provided by the USDA indicated that the CERCLA-NFRAP database listing is associated with a landfill area located approximately 500 feet southeast of the site. Based on its

TTL Project No. 11854.01 Page 15 regulatory status (non-NPL), distance from the site, and downgradient location from the site, the USDA landfill is not considered to be a REC with respect to the site.

Based on its distance from the site, facility status, and/or inferred cross- or down-gradient location, the remaining facility identified on the above-referenced ASTM-specified state and federal databases is not considered to be RECs in connection with the site. No facilities were identified on EDR’s “Orphan” list. For detailed “Orphan” facilities information, refer to Appendix F.

TTL Project No. 11854.01 Page 16

6.0 CURRENT AND HISTORICAL USES OF ADJOINING PROPERTIES

This section discusses the current and historical uses of the properties adjoining and surrounding the site to evaluate potential or identified RECs in the vicinity of the site. The information below describes the extent that indications of current and past uses of adjoining properties were identified through site reconnaissance, interviews, record reviews, or client-provided information obtained during this Phase I ESA for the site, as specified in Section 3.0 of this report. The historical and current uses of the adjoining properties are as follows:

North: The area located adjoining to the north of the site is unimproved grassy land.

The area approximately 150 to 200 feet north of the site is occupied by greenhouses, and a lathe building associated with the USDA facility from 1928 to 2007. This area has been part of the High Plains Arboretum since 2007.

East: The area located adjoining to the east of the site has been unimproved land since at least 1911. This area was associated with the USDA facility from 1928 to 2007, and contained plants and nursery stock from the 1940s through 1980 and grassy land since at least 1990. This area has been part of the High Plains Arboretum since 2007.

South: The area located adjoining to the south of the site has been unimproved land since at least 1911. This area was associated with the USDA facility from 1928 to 2007, and contained plants and nursery stock from the 1940s through 1980s and grassy land since at least 1990. This area has been part of the High Plains Arboretum since 2007.

West: The area located adjoining to the west has been unimproved land since at least

1911 and mostly grassy land since at least 1947.

Based on available information, none of the identified current and historical uses of adjoining and surrounding properties are considered to be RECs in connection with the site.

TTL Project No. 11854.01 Page 17

7.0 DATA GAPS

Data failure occurs when standard historical resources that are reasonably ascertainable and likely to be useful have been reviewed and yet the objective of identifying the use of the site to the first use or 1940, whichever is earlier, has not been met. As indicated in ASTM E1527-13, data failure is not uncommon when performing Phase I ESAs. TTL identified the use of the site back to 1911, at which point was unimproved land.

The term “significant data gap,” in the context of this report, is defined as a lack of information, which, in TTL’s professional judgment, might materially impact TTL’s ability to identify RECs at the site. Examples of significant data gaps might include inaccessibility to a portion of the property during site reconnaissance or the inability to interview a site owner. No significant data gaps were encountered during this Phase I ESA.

TTL Project No. 11854.01 Page 18

8.0 OPINION

TTL has performed a Phase I ESA of the site in conformance with the scope and limitations of ASTM E 1527-13. Any exceptions to, or deletions from, this practice are described in Section

1.2 of this report. This Phase I ESA has revealed no evidence of RECs in connection with the site.

TTL Project No. 11854.01 Page 19

9.0 DECLARATION

This assessment was performed utilizing methods and procedures consistent with customary practice designed to conform to acceptable industry standards. The TTL team that performed this Phase I ESA consisted of environmental staff and professionals that have training and expertise in performing Phase I ESAs. Resumes for the TTL team that performed this assessment are provided in Appendix G. Environmental Scientists performed the site reconnaissance, research, and interviews and prepared the report. A Senior Scientist coordinated with the client, provided technical guidance, provided Quality Assurance/Quality Control and technical reviews.

We declare that, to the best of our professional knowledge and belief, we meet the definition of Environmental Professional as defined in 312.10 of 40 CFR 312 and we have the specific qualifications based on education, training, and experience to assess a property of the nature, history, and setting of the subject property (site). We have developed and performed the all appropriate inquiries in conformance with the standards and practices set forth in 40 CFR Part 312.

PREPARED BY:

PAUL J. JACKSON

ENVIRONMENTAL SCIENTIST

APPROVED BY:

ROBIN J. CLARK

SENIOR SCIENTIST

TTL Project No. 11854.01 Page 20

10.0 REFERENCES AND RECORDS OF COMMUNICATION

Resources utilized and persons contacted to obtain information to complete this Phase I ESA included, but were not limited to:

City of Cheyenne Parks and Recreation Department, provided site information, November 2014.

City of Cheyenne Fire Department, provided site information, November 2014.

EDR, search of state and federal databases which included, but were not limited to, the following resources: FEMA; NWI; NPL; CERCLIS; CERCLIS NFRAP; ERNS; RCRIS SQG/LQG;

TSD; CORRACTS; SHWS; USTs; LUSTs; and SWL; Sanborn Fire Insurance Map information; and aerial photographs, November 19, 2014.

Google Earth Internet Website, provided 2014 aerial photograph, November 2014.

Laramie County Internet Website, provided site information, November 2014.

Laramie County Health Department, provided site information, November 2014.

Mr. Todd Feezer, City of Cheyenne Parks and Recreation Department, site owner representative, completed site owner and key site manager questionnaires and provided site information, November 2014.

Mr. Justin Derner, Research Leader, USDA Rangeland Resources Research Unit, former site occupant representative, completed site owner and key site manager questionnaires and provided site information, November 2014.

Mr. Shane Hott, Maintenance Supervisor, USDA High Plains Grassland Research Station, former site occupant representative, provided site information, December 2014.

United States Department of Agriculture (USDA) Natural Resources Conservations Service

(NRCS) Web Soil Survey, provided site soil information, December 2014.

United States Geological Survey, provided Cheyenne and Round Top Lake, Wyoming

Quadrangle map, dated 1911, 1914, 1950, 1954, 1961, 1981, and 2012, November 2014.

Wyoming Department of Environmental Quality, provided site information, December 2014.

Wyoming State Geological Survey, provided site geology information, December 2014.

FIGURES

APPENDIX A

LOCAL GOVERNMENT AGENCY RECORDS

1 Record(s) Found

• Pidn : 14670810000200

• Local#: 00014006708010 iTax

• Account : R0030497 Property Detail

• Name : CITY OF CHEYENNE CITY CLERKS OFFICE

• Mailing : 2101 ONEIL AVE RM 101

• Mailing : CHEYENNE WY 82001

• St Address :

• Deed Book & Page: 1957 AN 1549

• Deed Date : 2006-07-06

• Legal : 14-67: SEC 8, 9, AND 16; PLUS (11.60 AC) A TRACT IN THE SW1/4 SW1/4 SEC 15, DESC AS: BEG

AT A PNT ON THE WEST LINE OF SD SEC 15, SD PNT BEING 1056' NORTHERLY FROM THE SOUTHWEST

COR OF SEC 15; TH SOU

• Type : Exempt

• Tax Roll Area : 2,191.94 acres, 95,480,906 sq ft

Page 1 of 1Laramie County, Wyoming, GIS Attribute Data

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Detail of R0030497

Parcel Information

Property Owner(s): CITY OF CHEYENNE CITY CLERKS OFFICE

Mailing Address: 2101 ONEIL AVE RM 101

CHEYENNE, WY 82001

Street Address:

Tax District:0102

Local #:00014006708010 Treasurer's Property Tax Information

Legal Description: 14-67: SEC 8, 9, AND 16; PLUS (11.60 AC) A TRACT IN THE SW1/4 SW1/4 SEC

15, DESC AS: BEG AT A PNT ON THE WEST LINE OF SD SEC 15, SD PNT BEING

1056' NORTHERLY FROM THE SOUTHWEST COR OF SEC 15; TH SOUTHERLY

ALONG SD WEST LINE OF SEC 15, 1056' TO THE SOUTHWEST COR OF SEC 15;

TH EAST ALONG THE SOUTH LINE OF SEC 15, 957'; TH NORTHWESTERLY TO

THE SD POB; PLUS POR SEC 21, NORTH OF RR; PLUS POR W1/2 W1/2 SEC 22,

NORTH OF RR.

2014 Market Value:$ 0 ($ 0 Land + $ 0 Improvements)

2014 Assessed Value:$ 0

Page 1 of 2MapServer - Laramie County, Wyoming

10/14/2014http://arcims.laramiecounty.com/mapserver/map

Map

This map/data is made possible through the Cheyenne and Laramie County Cooperative GIS (CLCCGIS) Program and is for display purposes only. The CLCCGIS invokes its sovereign and governmental immunity in allowing access to or use of this data, and makes no warranties as to the validity, and assumes no liability associated with the use or misuse of this information.

Page 2 of 2MapServer - Laramie County, Wyoming

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APPENDIX B

QUESTIONNAIRES

HELPFUL DOCUMENTS QUESTIONNAIRE

Property: Approximately 5 Acres (Site 1) TTL Project No.: 11854.01

Southwest of Hildreth Road Loop

– USDA Rangeland Resources

Research Center

Cheyenne Wyoming Date: 11/19/14

The following is a list of potential documents regarding the environmental status of the above-referenced property that are recommended to be obtained by the ASTM E 1527-05 standard. Please review this list and check the appropriate box (yes or no) indicating your knowledge of the existence of the documents listed below. In addition, if the document exists, please indicate the availability of a copy, and whenever possible, please attach a copy of the available documents to this questionnaire and return it to TTL Associates, Inc. Thank you for your time.

EXISTING DOCUMENT AVAILABLE

DOCUMENT YES NO COPY

Environmental Assessment Reports X

Environmental Compliance Audit Reports X

Environmental Permits (e.g., solid waste disposal, hazardous waste disposal, NPDES, wastewater, injection)

Registrations for Aboveground (AST) or

Underground (UST) Storage Tanks

Material Safety Data Sheets (MSDS) X

Community Right-to-Know Plan X

Safety Plans, Spill Prevention, Prevention and Preparedness Plans, etc.

Hydrogeologic Conditions Reports X

Violations Notices from Regulatory

Agencies

Environmental Liens X

Hazardous Waste Generator Notices X

Geotechnical Studies X

Risk Assessments X

Recorded Limitations of Activity and Use for the Property

Pending, Threatened, Past Litigation or

Administrative Proceedings Relevant to

Petroleum and Hazardous Substances

NAME: Todd Feezer, Asst. Director SIGNATURE:

V:\Toledo\Controlled Documents\Phase I\Phase I ESA Forms\Phase I ESA Helpful Documents Questionnaire.doc September 2008

KEY SITE MANAGER QUESTIONNAIRE

The following is a list of questions regarding the environmental status of the above-referenced property (Site). Please answer all questions to the best of your knowledge and in good faith. Mark the column corresponding to the appropriate response.

Additional details necessary to explain any yes or unknown responses should be provided in the “Comments” column.

Please return the completed questionnaire to TTL Associates, Inc. Thank you for your time.

QUESTION RESPONSE COMMENTS

Y N Unk

1A. Is the Site used for an industrial use? X

1B. Are any adjoining properties used for an industrial use? X

2A. To the best of your knowledge, has the Site been used for an industrial use in the past?

2B. To the best of your knowledge, has any adjoining properties been used for an industrial use in the past?

3A. Is the Site used as a gasoline station, motor repair facility, commercial printing facility, dry cleaners, photo developing laboratory, junkyard or landfill, or as a waste treatment, storage, disposal, processing, or recycling facility?

3B. Is any adjoining property used as a gasoline station, motor repair facility, commercial printing facility, dry cleaners, photo developing laboratory, junkyard or landfill, or as a waste treatment, storage, disposal, processing, or recycling facility?

4A. To the best of your knowledge, has the Site been used as a gasoline station, motor repair facility, commercial printing facility, dry cleaners, photo developing laboratory, junkyard or landfill, or as a waste treatment, storage, disposal, processing, or recycling facility?

4B. To the best of your knowledge, has any adjoining property been used as a gasoline station, motor repair facility, commercial printing facility, dry cleaners, photo developing laboratory, junkyard or landfill, or as a waste treatment, storage, disposal, processing, or recycling facility?

X

5A. Are there currently any automotive or industrial batteries, pesticides, paints, or other chemicals in individual containers of greater than five gallons in volume or fifty gallons in the aggregate, stored on or used at the Site?

X

5B. To the best of your knowledge, have there been previously any automotive or industrial batteries, pesticides, paints, or other chemicals in individual containers of greater than five gallons in volume or fifty gallons in the aggregate, stored on or used at the

S…