36C78618R0078-003.pdf

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REVISION DATE 4/11/2016

B160197 P1ESA

Environmental Services Geotechnical Engineering Construction Materials Testing Special Inspections

2791 S. Victory View Way Boise, Idaho 83709 (208) 376-4748 Fax (208) 322-6515 mti@mti-id.com www.mti-id.com

MATERIALS

TESTING &

INSPECTION

PHASE I ENVIRONMENTAL SITE

ASSESSMENT

for Proposed Veterans Burial Ground

E. Elm Street Buhl, Idaho prepared for:

Department of Veterans Affairs 425 I Street, NW Washington, DC 20001

MTI File Number: B160197e Date: April 11, 2016

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MR. KEVIN DOWNEY

DEPARTMENT OF VETERANS AFFAIRS

425 I Street, NW

Washington, DC 20001

Re: Environmental Site Assessment, Phase I

Proposed Veterans Burial Ground

E. Elm Street

Buhl, Idaho

Dear Mr. Downey:

The attached document renders the observations, conclusions, and recommendations of Materials Testing &

Inspection, Inc. MTI appreciates the opportunity to be of assistance to you on this project.

The following is the Environmental Professional statement as required by the ASTM 1527-13:

I declare that, to the best of my professional knowledge and belief, I meet the definition of an

Environmental Professional as defined in 40 CFR 312.10 of this part. I have the specific qualifications based on education, training, and experience to assess a property of the nature, history, and setting of the

Property. I have developed and performed all the appropriate inquiries in conformance with the standards and practices set forth in 40 CFR Part 312.

MTI would be pleased to continue our role as environmental consultants as the project progresses. If MTI can be of any further assistance to you, please feel free to call (208) 376-4748.

Respectfully Submitted, MATERIALS TESTING & INSPECTION, INC.

Jennifer Babione Reviewed by: Jon Kruck

Project Manager Environmental Project Manager cc: file

This is a copyrighted document. Unauthorized use or copying of this document is strictly prohibited. See “Application For Authorization to Use” located at the end of this document if use or copying is desired by anyone other than the Client(s) and for the Project referenced above.

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TABLE OF CONTENTS

EXECUTIVE SUMMARY

INTRODUCTION

General Purpose Scope of Services Significant Assumptions Limitations and Exceptions of Assessment Warranty and Limiting Conditions Authorization, Special Terms, and Conditions User Reliance

SUBJECT PROPERTY

Subject Property Location and Legal Description Subject Property and Vicinity Characteristics Current Uses of the Subject Property Descriptions of Structures, Roads, and Other Improvements on the Subject Property Current Use of Adjoining Properties

USER PROVIDED INFORMATION

Title Records Environmental Liens or Activity and Use Limitations Specialized Knowledge Commonly Known or Reasonably Ascertainable Information Valuation Reduction for Environmental Issues Owner, Property Manager, and Occupant Information Reason for Performing the Phase I Environmental Site Assessment

RECORDS REVIEW

Standard Environmental Record Sources, Federal, and State Additional Environmental Records Sources Physical Setting and Source(s) Historical Use Information Historical Use Information on the Property Historical Use Information on Adjoining Properties

SITE RECONNAISSANCE

Methodology and Limiting Conditions General Site Setting Exterior Observations Interior Observations

INFORMATION FROM INTERVIEWS

Interview with Owner Interview with Site Manager/Occupant Interview with Local Government Officials Interview with Others

NON-SCOPE CONSIDERATIONS

FINDINGS

OPINION

CONCLUSIONS

DEVIATIONS

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EXECUTIVE SUMMARY

Materials Testing & Inspection, Inc. (MTI) has conducted a Phase I Environmental Site Assessment (Phase I

ESA) in conformance with the scope and limitations of the ASTM International, E1527-13 Standard Practice for Environmental Site Assessments of E. Elm Street, Buhl, Idaho, the subject Property. This section briefly describes the report; for a comprehensive understanding of the items detailed, this report must be read in its entirety.

The subject Property was located in the Section 31, Township 9 South, Range 15 East of the Boise Meridian and was generally situated at the northeast corner of the intersection of E. Elm Street and North 1600 East in

Buhl, Twin Falls County, State of Idaho. The subject Property comprised a 6.4-acre portion of a 12.345-acre parcel located within a mixed-use area of rural Buhl, and residential and agricultural sites were located within the general vicinity of the subject Property. At the time of site reconnaissance, Seneca Foods leased the subject

Property for agricultural purposes.

MTI has not identified any known or suspect recognized environmental conditions (RECs) on the subject

Property and recommends no additional investigation based on our findings.

REPORT SUMMARY

Section No RECs REC Recommendations

Data Gaps √

Current/Historical Uses of the subject Property √

Current/Historical Use of the Adjoining Properties √

Specialized Knowledge √

Standard Environmental Records Sources √

Historical Research √

Hazardous Substances and Petroleum Products √

Drums √

Staining √

ASTs √

USTs √

PCBs √

Solid Waste Disposal √

Stressed Vegetation √

Pits, Ponds, And Lagoons √

Wells √

Discharge Features √

Interviews √

As noted in the warranty section, this report is limited to the information available or known to MTI as of the date of the report. If any additional information becomes available, it will be forwarded to you for your evaluation.

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INTRODUCTION

General

This report presents the findings and conclusions of the Phase I Environmental Site Assessment (Phase I ESA) conducted for Department of Veterans Affairs on the Proposed Veterans Burial Ground, which is located at E.

Elm Street, Buhl, Idaho.

Purpose

The purpose of this Phase I ESA is to identify, to the extent feasible pursuant to the processes prescribed in

ASTM Standard E1527-13, recognized environmental conditions (RECs) in connection with the subject

Property. The purpose of ASTM Standard E1527-13 is to define good commercial and customary practice in the United States of America for conducting an environmental site assessment of a parcel of commercial real estate with respect to the range of contaminants within the scope of the Comprehensive Environmental

Response, Compensation, and Liability Act (CERCLA) and petroleum products. As such, ASTM E1527-13 is intended to permit the user to satisfy one of the requirements to qualify for the innocent landowner defense to

CERCLA liability: That is, the practices that constitute “all appropriate inquiries into the previous ownership and uses of the Property consistent with good commercial and customary practice” as defined in 42 USC §

9601(35)(B).

In defining a standard of good commercial and customary practice for conducting an environmental site assessment of a parcel of property, the goal of the processes established by ASTM E1527-13 is to attempt to identify recognized environmental conditions. The term recognized environmental conditions means “the presence or likely presence of any hazardous substances or petroleum products in, on, or at a property: 1) due to release to the environment; 2) under conditions indicative of a release to the environment: or 3) under conditions that pose a material threat of a future release to the environment”. The term includes hazardous substances or petroleum products even under conditions in compliance with laws. The term is not intended to include de minimis conditions that generally do not present a material risk of harm to public health or the environment and that generally would not be the subject of an enforcement action if brought to the attention of appropriate governmental agencies.

The term “presence of any hazardous substances or petroleum products in, on, or at a property” is self-defined.

The term “likely presence of any hazardous substances or petroleum products in, on, or at a property” reflects the potential for contamination from the federal and state standard environmental record sources that are required to be reviewed under ASTM E1527. ASTM E1527 requires the review of standard sources with a minimum search distance (radius) realizing that there is potential for contamination from these types of sources to extend to the subject Property.

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Scope of Services

The research consisted of obtaining information from sources including governmental agencies, public utilities and where possible, the current property owners. Federal, state, and local government records were reviewed to identify reports of environmental conditions on the subject and adjacent properties that may affect the subject

Property. A complete listing of the databases reviewed can be found in the Records Review section of this report. A description of these databases can be found in the Glossary of Terms Used section in the appendix of this report.

Under ASTM E1527-13, the User has an obligation to report to the preparer of the Phase I ESA any environmental liens encumbering the subject Property or any specialized knowledge or experience of the User that would provide important information about previous ownership or uses of the subject Property that may be material to identifying recognized environmental conditions (RECs). As a matter of routine, MTI asks the

Owner or other individual(s) with actual knowledge of the Property to complete our Environmental

Questionnaire. Actual knowledge is defined by ASTM E1527 as — the knowledge actually possessed by an individual who is a real person, rather than an entity. Actual knowledge is to be distinguished from constructive knowledge as that knowledge imputed to an individual or entity. MTI’s questionnaire is modeled from the ASTM E 1528 Transaction Screen Process with some additions. An Environmental Questionnaire and

Disclosure Statement was presented to the property owner and/or User of this document to obtain pertinent environmental information regarding the present and past use of the subject Property. This document has been completed and is discussed herein. Where available, additional information was obtained from interviews with people having actual knowledge of the site that might reveal recognized environmental conditions on the

Property.

Significant Assumptions

During our site reconnaissance and subsequent research, MTI assumed the following:

1. The land included for assessment, as defined by the client in the form of a site plan, plat map, legal description or other mechanism, coincides with the actual property boundaries recorded at the county assessor’s office.

2. Local groundwater flow is similar to regional groundwater gradient.

Limitations and Exceptions of Assessment

The site reconnaissance conducted on April 6, 2016 encountered no interference to the observance of surface conditions or access.

Data Gaps

MTI attempted to identify all obvious uses of the subject Property since the first developed use, or back to 1940, whichever was earlier. Historical records obtained during this assessment did not reveal any limitations to this requirement.

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Warranty and Limiting Conditions

The field observations and research reported herein are considered sufficient in detail and scope to form a reasonable basis for a general environmental assessment of the subject Property within the context of ASTM

E1527. MTI warrants that the findings and conclusions contained herein have been promulgated in accordance with generally accepted environmental engineering methods, only for the subject Property described in this report.

These environmental methods are necessarily limited to the conditions observed at the time of the reconnaissance and research. The report is also limited to the information available at the time it was prepared.

In the event additional information is provided to MTI following the report, it may, but is not required to, be forwarded to the client in the form received for evaluation by the client. There is a distinct possibility that conditions may exist that could not be identified within the scope of the assessment or that were not apparent during the site reconnaissance. MTI cannot warrant or guarantee that the information provided is complete or accurate. MTI prepared this report for the use of Department of Veterans Affairs (“Client”), and the conclusions and recommendations presented in this report are based upon the agreed upon scope of work outlined in the report and the Contract for Professional Services between the Client and MTI (“Consultant”).

Use or misuse of this report, or reliance upon the findings hereof by any parties other than the Client, is at their own risk. Neither Client nor Consultant makes any representation of warranty to such other parties as to the accuracy or completeness of this report or the suitability of its use by such other parties for any purpose whatsoever, known or unknown to Client or Consultant. Neither Client nor Consultant shall have any liability to indemnify or hold harmless third parties for any losses incurred by the actual or purported use or misuse of this report. This report represents the opinion of MTI, and no other warranties are implied or expressed.

Authorization, Special Terms, and Conditions

Authorization to perform this assessment was given in the form of a written notice to proceed from Kevin

Downey to Karl Languirand of MTI on March 11, 2016 and is subject to all of the terms, conditions, and limitations described in the Contract/Purchase Order entered into between Department of Veterans Affairs and

MTI. As per the Client’s instructions, MTI did not perform any additional screenings, investigations, surveys, or assessments, such as the following: radon, asbestos-containing material, lead-based paint, lead-in-drinking water, wetland, PCB sampling, regulatory compliance, ecological/natural resources or impacts, endangered species, indoor air quality, cultural and historical resources, industrial hygiene, health and safety, or high-voltage power lines.

User Reliance

The User understands and agrees that the document listed above is a copyrighted document, which MTI is the copyrighted owner, and that unauthorized use or copying this document is strictly prohibited without the express written permission of MTI. The User understands that MTI may withhold such permission at its sole discretion or grant such permission upon such terms and conditions as it deems acceptable, such as the execution of a Hold Harmless Agreement or the payment of a re-use fee. Third parties may obtain a “Letter of

Reliance” or “Read and Rely” letter from MTI if agreed to by the User.

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SUBJECT PROPERTY

Subject Property Location and Legal Description

The subject Property was located in the Section 31, Township 9 South, Range 15 East of the Boise Meridian and was generally situated at the northeast corner of the intersection of E. Elm Street and North 1600 East in

Buhl, Twin Falls County, State of Idaho. Additional information describing the subject Property is included in the appendix of this report.

Subject Property and Vicinity Characteristics

The subject Property comprised a 6.4-acre portion of a 12.345-acre parcel. The Twin Falls County Assessor provided the following information pertaining to the subject Property:

1) The property owner was Shirley S. Love.

2) The parcel number was RP09S15E317205.

Access to the site was gained from the two-lane, asphalt-paved Elm Street, which was located adjacent to the north side of the Property. The subject Property was located within a mixed-use area of rural Buhl, and residential and agricultural sites were located within the general vicinity of the subject Property.

Current Uses of the Subject Property

At the time of site reconnaissance, Seneca Foods leased the subject Property for agricultural purposes.

Descriptions of Structures, Roads, and Other Improvements on the Subject Property

The subject Property was developed as agricultural and had been recently planted with barley by Seneca Foods.

Irrigation serviced the Property via an irrigation system along the northern Property boundary.

Current Use of Adjoining Properties

The adjacent site to the north was occupied by the West End Cemetery. The adjacent sites to the east and south were occupied by agricultural land. The adjacent site to the west was occupied by a residence.

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USER PROVIDED INFORMATION

Under the standards as outlined in the ASTM E1527-13 the User of the Phase I ESA has certain responsibilities regarding notification to the preparer of the report. Specifically, the User must notify the preparer of the report of any environmental liens encumbering the subject Property or any specialized knowledge or information about previous ownership or uses of the subject Property that may be material to identifying RECs.

Title Records

The Client did not request nor provide a chain-of-title as part of the scope of this Phase I ESA. MTI determined prior use of the subject Property with the aid of other records sources and interviews.

Environmental Liens or Activity and Use Limitations

No past or current environmental liens, deed restrictions, consent agreements, or government actions were reported by the User.

Specialized Knowledge

The Client/User did not report any specialized knowledge or provide any specialized documentation to MTI for review.

Commonly Known or Reasonably Ascertainable Information

The Client/User did not report any commonly known or reasonably ascertainable information that is considered a REC in connection with the subject Property.

Valuation Reduction for Environmental Issues

No unexpected RECs were discovered by performing this ESA.

Owner, Property Manager, and Occupant Information

Information provided by the property owner, property manager, or occupant did not indicate a REC in connection with the Property.

Reason for Performing the Phase I Environmental Site Assessment

MTI’s understanding is that the Property is being sold by Shirley Love. This Phase I ESA fulfills one requirement of the innocent landowner defense to CERCLA liability.

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RECORDS REVIEW

The purpose of the records review is to obtain and review records that will help identify recognized environmental conditions in connection with the Property.

Standard Environmental Record Sources, Federal, and State

The review of the available federal and state environmental information included those properties or incident reports within an area not smaller than the ASTM 1527-13 minimum search distance (radius). The records review indicates the following summary of state and federal environmental data, which identifies potential environmental problem sites and other activities from the records of the State of Idaho and the United States

Environmental Protection Agency (US EPA):

STANDARD ENVIRONMENTAL RECORD SOURCES

REVIEWED

APPROXIMATE MINIMUM SEARCH

DISTANCE IN MILES (KM)

IDENTIFIED ON

PROPERTY

Federal NPL site list 1.0 (1.6) No

Federal delisted NPL site list 0.5 (0.8) No

Federal CERCLIS list 0.5 (0.8) No Federal CERCLIS NFRAP site list 0.5 (0.8) No

Federal RCRA CORRACTS facilities list 1.0 (1.6) No

Federal RCRA non-CORRACTS TSD facilities list 0.5 (0.8) No Federal RCRA (small and large-quantity) generators list Property and adjoining properties No Federal institutional/engineering control registries Property only No

Federal ERNS list Property only No

State or tribal lists of hazardous waste sites identified for investigation or remediation (NPL and CERCLIS equivalents)

NPL equivalent – 1.0 (1.6)

CERCLIS equivalent – 0.5 (0.8)

No

No

State or tribal landfill and/or solid waste disposal site lists 0.5 (0.8) No State or tribal leaking UST lists 0.5 (0.8) No State or tribal registered UST lists Property and adjoining properties No State or tribal institutional/engineering control registries Property only No

State or tribal voluntary cleanup sites 0.5 (0.8) No

State or tribal Brownfield sites 0.5 (0.8) No

I. STATE OF IDAHO ASTM DATABASE INFORMATION

1. State Priority List State of Idaho uses US EPA CERCLIS List

2. Leaking Underground Storage Tank Facility List 00 LUST sites within a 0.5 Mile Radius.

3. Solid Waste Landfill Capacity Inventory 00 SWF sites within a 0.5 Mile Radius.

4. Underground Storage Tank Facility List 00 UST sites within a 0.25 Mile Radius.

5. Voluntary Cleanup Sites 00 Voluntary cleanup sites within a 0.5 Mile Radius

6. Brownfield Sites 00 Brownfield sites within a 0.5 Mile Radius.

II. FEDERAL ASTM DATABASE INFORMATION

1. National Priorities List (NPL) 00 NPL sites within a 1.0 Mile Radius.

2. Delisted NPL 00 delisted NPL sites within a 0.5 Mile Radius.

3. Comprehensive Environmental Response, Compensation and Liability Information System

(CERCLIS) / CERCLIS NFRAP

00 CERCLIS / CERCLIS NFRAP sites within a 0.5

Mile Radius.

4. Resource Conservation and Recovery Act (RCRA)

Corrective Action Report

00 CORRACTS sites within a 1.0 Mile Radius.

5. RCRA small- and large-quantity generators 00 RCRA facilities within a 0.25 Mile Radius.

6. RCRA Treatment, Storage, and Disposal (TSD) 00 RCRA-TSD facilities within a 0.5 Mile Radius.

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MTI reviewed those sites that were listed within the ASTM 1527-13 minimum search distance and researched only those sites from the report that posed a potential environmental impact to or were located on the subject

Property. A copy of the database report, provided by Environmental Data Resources, Inc. (EDR), is included in the appendix.

No sites were listed in the state and federal database report within the ASTM E1527-13 Minimum Search

Distance from the subject Property. Therefore, based on information obtained from the database report, no sites were found that represent an environmental impact to the subject Property.

Additional Environmental Records Sources

MTI determined that the review of the above standard environmental record sources was sufficient; therefore, no additional environmental record sources were examined.

Physical Setting and Source(s)

The subject site is located upon the Lower Snake River Plain, which is directly underlain by a thick sequence of basalt formations. These basalt formations typically have been deposited on metamorphosed alluvial sands and gravels The area is underlain by a thick sequence of volcanic flows that erupted during the past 12 million years onto pre-Cenozoic rocks. The layered basalt formations typically are near 200 feet thick. In the vicinity of the project site, Stricker Butte basalts, which were deposited during the Pliocene, are identified as the bedrock. The soil veneer, which covers the basalt, is relatively thin and consists of clay and silt with sand, which are found to depths of less than 20 feet. (Othberg and Stanford, 1992). The Soil Survey Map for Twin Falls County lists the soil type as Minveno silt loam with 2 to 8 percent slopes. This soil type is characterized as well drained, with permeability that is very low to moderately low. Beneath this, the layered basalt formations typically are near

200 feet thick. Based on the regional topography and local surface water flow directions, the local groundwater gradient in this area is north to northwest.

The soil type on the Property was identified as Portneuf and Sluka silt loams. Portneuf silt loam consists of silty alluvium and/or loess and/or lacustrine deposits and is characterized as a very deep, well drained soil.

Sluka silt loam consists of mixed alluvium and characterized as a moderately deep, well drained soil.

The subject Property and vicinity were characterized in part through the use of the following literature resources:

U. S. Department of Agriculture, Natural Resources Conservation Service. Web Soil Survey Database, http://websoilsurvey.sc.egov.usda.gov.

United States Geological Survey (USGS), 7.5 Minute Topographic map Clover, Idaho, dated 1951 and photorevised 1992.

Historical Use Information

The objective of consulting historical sources is to develop a history of the previous uses or occupancies of the

Property and surrounding area in order to identify those uses or occupancies that are likely to have led to recognized environmental conditions in connection with the Property. During our research, MTI consulted at least five of the eight ASTM listed record sources that include the following: (1) aerial photographs, (2) fire insurance maps, (3) property tax files, (4) recorded land title records, (5) USGS topographic maps, (6) local street directories, (7) building department records, and (8) zoning / land use records.

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Aerial Photographs

MTI reviewed aerial photographs for the subject Property and surrounding area from Valley Air Photos and

Google™ Earth. No RECs were indicated by our review of the aerial photographs, and a copy of the Valley Air aerial photography is included in the appendix of this report. The following table summarizes the research:

AERIAL PHOTOGRAPHS

DATE SUBJECT PROPERTY SURROUNDING PROPERTIES

The subject Property was depicted as agricultural land.

The surrounding vicinity was rural residential and agricultural properties. The adjacent property to the north was occupied by a cemetery.

The subject Property was depicted as similar to the 1963 photograph.

The surrounding sites were similar to the 1963 aerial photograph.

Google™

Earth

The subject Property was depicted as similar to the 1987 photograph.

The surrounding sites were similar to the 1987 aerial photograph.

Google™

Earth

The subject Property was depicted as similar to the 1993 photograph.

The surrounding sites were similar to the 1993 aerial photograph.

Google™

Earth

The subject Property was depicted as similar to the 2003 photograph.

The surrounding sites were similar to the 2003 aerial photograph. A commercial facility, Seneca Foods, had been developed to the west.

Fire Insurance Maps

The Sanborn Fire Insurance maps did not provide coverage for the subject Property.

Property Tax Files

MTI did not review property tax files as a part of this assessment.

Recorded Land Title Records

The Client did not request nor provide a chain-of-title to include as part of the scope of this Phase I ESA. MTI determined prior use of the subject Property with the aid of other historical records sources and interviews.

USGS Topographic Map(s)

The 1992 (photoinspected from 1951) USGS 7.5 Minute Quadrangle depicted the subject Property in a rural area east of Buhl. The Buhl Cemetery was depicted on the adjacent property to the north. The map depicted a road immediately north of the subject Property that terminated at 1600 East, which was located immediately adjacent to the east. A copy of the topographic map is included in the appendix of this report. No RECs were indicated by our review of the topographic maps.

Local Street Directories

MTI reviewed the EDR City Directory Image Report for the area. The EDR report did not provide coverage prior to 1992 for the subject Property or surrounding properties. No RECs were indicated by our review of the city directories and a copy is included in the appendix of this report.

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Building Department Records

MTI did not review building department records as part of this assessment.

Zoning and Land Use Records

During our research, MTI consulted various record sources such as the Twin Falls County Assessor’s office and the 1939 Metsker’s Atlas. The Twin Falls County Assessor’s office indicated that the subject Property consisted of a portion of a 12.345-acre parcel owned by Shirley S. Love. The 1939 Metsker’s Atlas identified the subject Property as owned by George Wade.

Historical Use Information on the Property

The Property was historically used for agricultural purposes. No RECs were noted during the historical records review.

Historical Use Information on Adjoining Properties

The surrounding properties were historically used for residential and agricultural purposes.

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SITE RECONNAISSANCE

The objective of site reconnaissance is to obtain information indicating the likelihood of identifying RECs in connection with the Property.

Methodology and Limiting Conditions

Visual reconnaissance was conducted April 6, 2016 in general accordance with MTI's standard environmental assessment procedures. This reconnaissance consisted of systematically walking the Property to provide an overlapping field of view and noting recognized environmental conditions as encountered. Photographic documentation of pertinent recognized environmental conditions, improvements, and adjacent properties was made and has been included in the appendix of this report. The reconnaissance of the adjacent properties was performed by walking the perimeter of the subject Property, by observing and photographing the readily accessible and visible areas bordering or adjacent to the subject Property, and by noting potential environmental conditions. At the time of the reconnaissance, all required areas were accessible. The scope of work did not include sampling of items such as soil, groundwater, surface water, drum contents, tanks, other containers, etc., for chemical laboratory analysis.

General Site Setting

At the time of site reconnaissance, MTI observed the subject Property was occupied by a recently planted agricultural crop. An irrigation ditch was observed along the northern Property boundary, and a portable sprinkler system was observed at the time reconnaissance.

Hazardous Substances and Petroleum Products

No hazardous substances were observed during the site reconnaissance.

Unidentified Substances

No unidentified substances were observed during the site reconnaissance.

Storage Tanks

No evidence of storage tanks was observed during the site reconnaissance.

Odors

No odors were discovered during the site reconnaissance.

Pools of Liquid

No pools of liquid were observed during the site reconnaissance.

Drums

No drums were observed during the site reconnaissance.

Staining

No staining was observed during the site reconnaissance.

ASTs

No evidence of aboveground storage tanks was observed during the site reconnaissance.

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Lack of Secondary Containment

Since no evidence of aboveground storage tanks was observed during the site reconnaissance, secondary containment is not applicable to the subject Property.

USTs

No evidence of underground storage tanks was observed during the site reconnaissance.

PCBs

No buildings, structures, or power transformers were observed during the site reconnaissance.

Solid Waste Disposal

There was no evidence found of waste disposal on the subject Property.

Surface Water Observations

No surface water was observed on the Property at the time of the site reconnaissance. The lot is graded such that it is not likely to receive offsite drainage. Storm water accumulating on the Property infiltrates surface soils.

Exterior Observations

The following subsections list the observations noted during the site reconnaissance specific to the accessed exterior spaces on the subject Property.

Stressed Vegetation

No stressed vegetation was found on the subject Property.

Pits, Ponds, and Lagoons

No pits, pond, or lagoons were found on the subject Property.

Wells

No wells were found on the subject Property. Irrigation water was obtained from offsite water sources. If any wells or well structures are discovered during the development of the Property, they should be abandoned in accordance with the Administrative Rules of the Idaho Water Resource Board Well Construction Standards

Rules IDAPA 37, Title 03, Chapter 09, Rule 25.

Septic Systems

No treatment plants or septic systems were observed on the subject Property. If during future development any existing tanks are discovered and are to be abandoned, they should be properly closed or removed. The Idaho

DEQ recommends the following procedures for septic tank abandonment: 1) disconnect the inlet and outlet piping; 2) pump the scum and septage with approved disposal; 3) fill the septic tank with earthen material or physically destroy the septic tank or remove the septic tank from the ground.

Discharge Features

No drains, catch basins, or oil/water separator vaults were observed on the subject Property.

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Soil Contamination

No evidence of soil contamination was observed on the subject Property during the site reconnaissance, and no indication of soil contamination was reported by the Idaho DEQ.

Groundwater Contamination

No evidence of groundwater contamination was found on the subject Property during the site reconnaissance, and no indication of groundwater contamination was reported by the Idaho DEQ.

Use of Pesticides

No evidence of pesticide usage was observed on the subject Property. Since the Property has been used for agricultural purposes, MTI presumed that there was a historical use of pesticides on the Property. As of the printing of this report, there was no evidence that past usage of pesticides, herbicides, or other agricultural chemicals were mixed, formulated, or disposed of at the Property.

Vapor Intrusion

Migrating contaminated groundwater is not a concern up groundwater gradient from the subject Property;

therefore, vapor intrusion is unlikely to occur.

Interior Observations

Since the subject Property lacked buildings or structures, no interior observations were noted.

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INFORMATION FROM INTERVIEWS

Interview with Owner

The property owner, Ms. Shirley Love, was interviewed using the standard MTI Questionnaire, which is modeled after the Transaction Screening Questionnaire from ASTM E 1528-14. A copy of the completed questionnaire is included in the appendix of this report. No RECs were reported or identified in connection with the subject Property from the completed questionnaire.

Interview with Site Manager/Occupant

Seneca Foods Plant Manager, Mr. Robert Severa, was interviewed using the standard MTI Questionnaire, which is modeled after the Transaction Screening Questionnaire from ASTM E 1528-14. A copy of the completed questionnaire is included in the appendix of this report. No RECs were reported or identified in connection with the subject Property from the completed questionnaire.

Interview with Local Government Officials

The standard environmental record sources do not warrant interviews with local government officials.

Interview with Others

No other persons were interviewed during this assessment.

NON-SCOPE CONSIDERATIONS

There may be additional environmental issues or conditions at a property that parties may wish to assess in connection with commercial real estate that are outside the scope of ASTM E1527. Some substances may be present on a property in quantities and under conditions that may lead to contamination of the property or of nearby properties that are not included in the CERCLA definition of hazardous substances (42 USC § 9601

(14)) or that do not otherwise present potential CERCLA liability. As per the Client’s instructions, MTI did not perform any additional screenings, investigations, surveys, or assessments for the subject Property, such as the following: radon, asbestos-containing material, lead-based paint, lead-in-drinking water, wetland, PCB sampling, regulatory compliance, ecological/natural resources or impacts, endangered species, indoor air quality, cultural and historical resources, industrial hygiene, health and safety, or high-voltage power lines.

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FINDINGS

As noted in the warranty section, this report is limited to the information available or known to MTI as of the date of the report, and if any additional information becomes available, it will be forwarded to you for your evaluation. During this assessment, MTI has not identified any known or suspect RECs, CRECs, HRECs, or de minimis conditions on the subject Property.

OPINION

It is MTI’s opinion that no RECs, CRECs, HRECs, or de minimis conditions exist on the subject Property.

CONCLUSIONS

MTI has conducted a Phase I ESA in conformance with the scope and limitations of ASTM International, E1527-13 of E. Elm Street, Buhl, Idaho, the subject Property. Any exception to, or deletions from, this practice are described in the Limitations and Exceptions of Assessment section of this report. This assessment has revealed no evidence of a REC in connection with the subject Property, and MTI recommends no additional investigation based on our findings.

DEVIATIONS

During our performance of this Phase I ESA, MTI did not deviate from ASTM E1527-13.

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APPLICATION FOR AUTHORIZATION TO USE COPYRIGHTED DOCUMENT

PROPOSED VETERANS BURIAL GROUND

E. ELM STREET

BUHL, IDAHO

TO: MATERIALS TESTING AND INSPECTION

2791 SOUTH VICTORY VIEW WAY

BOISE, ID 83709

FROM: Please clearly identify name and address of person/entity applying to use or copy this document.

Gentlemen:

APPLICANT hereby applies for permission to: (State here the use(s) contemplated) for the purpose(s) of: (State here why you wish to do what is contemplated as set forth above.)

Applicant understands and agrees that the document listed above is a copyrighted document, that Materials

Testing and Inspection, Inc., is the copyrighted owner and that unauthorized use of copying this document is strictly prohibited without the express written permission of Materials Testing and Inspection, Inc. Applicant understands that Materials Testing and Inspection, Inc., may withhold such permission at its sole discretion, or grant such permission upon such terms and conditions as it deems acceptable, such as the execution of a Hold

Harmless Agreement or the payment of a re-use fee.

Dated: _________________ ____________________________________

Applicant by: ___________________________________

Name

Title

NOTE: THIS APPLICATION MUST BE COMPLETED FOR USE OR COPYING OF THIS DOCUMENT BY ANYONE OTHER

THAN THE CLIENT.

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Appendix

GLOSSARY AND ACRONYMS

QUALIFICATIONS OF KEY ENVIRONMENTAL PROFESSIONALS

ENVIRONMENTAL QUESTIONNAIRE AND DISCLOSURE FORMS

EDR ENVIRONMENTAL RESEARCH REPORTS (STATE AND FEDERAL REPORT)

HISTORICAL INFORMATION AND LEGAL DESCRIPTION

VICINITY MAP

TOPOGRAPHIC MAP

SITE MAP WITH PHOTO LOCATIONS

PHOTOGRAPHS

AERIAL PHOTOGRAPHS

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Appendix

Environmental Services Geotechnical Engineering Construction Materials Testing Special Inspections

2791 S. Victory View Way • Boise, Idaho 83709 • (208) 376-4748 • Fax (208) 322-6515 mti@mti-id.com • www.mti-id.com Form XXXXX Rev 0

GLOSSARY & ACRONYMS

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Appendix

Environmental Services Geotechnical Engineering Construction Materials Testing Special Inspections mti@mti-id.com www.mti-id.com Form XXXXX Rev 0

GLOSSARY OF TERMS USED

Acrylonitrile—a colorless liquid used as a pesticide fumigant for stored grain, and in manufacturing acrylic rubber and fiber.

Asbestos—six naturally occurring fibrous variety of minerals found in certain types of rock. Of the six, the minerals chrysotile, amosite, and crocidolite have been most commonly used in building products. When mined and processed, asbestos is typically separated into very thin fibers.

Because asbestos is strong, incombustible, and corrosion resistant, asbestos was used in many commercial products beginning early in the 1900’s and peaking in the period from World War II into the 1970s. When inhaled in sufficient quantities, asbestos fibers can cause serious health problems.

Asbestos-Containing Material (ACM)—USEPA defines this as any material or product that contains more than 1% asbestos. US OSHA defines this as any material or product that contains asbestos in any percentage.

Biochemical oxygen demand—(BOD) a measure of the amount of oxygen consumed in biological processes that break down organic matter in water.

BTEX—benzene, toluene, ethyl benzene and xylene.

Clean Air Act Amendments—(CAA) Clean Air Act Amendments (1990); expands EPA enforcement powers and adds restriction on air toxics, ODSs, stationary and mobile emissions sources, and emissions implicated in acid rain and global warming.

CERCLA—Comprehensive Environmental Response, Compensation and Liability Act (1980, 1986); also Superfund; federal law authorizing identification and remediation of unsupervised hazardous waste sites.

CERCLIS—Comprehensive Environmental Response, Compensation and Liability Information System. CERCLIS contains information on sites identified by the USEPA as known or suspect abandoned, inactive or uncontrolled hazardous waste sites which may require cleanup.

CFC—chlorofluorocarbon; family of chemical substances used as refrigerants and solvents; believed to be associated with depletion of Earth's ozone layer.

CFR—Code of Federal Regulations; notation indicated volume number, part and section of the code, as in 29 CFR 1910.120.

Comprehensive Environmental Response, Compensation, and Liability Information System (CERCLIS)—the list of sites compiled by EPA that

EPA has investigated or is currently investigating for potential hazardous substance contamination for possible inclusion on the National Priorities

List.

Construction debris—concrete, brick, asphalt, and other such building materials discarded in the construction of a building or other improvement to property.

Contaminated public wells—public wells used for drinking water that have been designated by a government entity as contaminated by toxic substances (e.g., chlorinated solvents), or as having water unsafe to drink without treatment.

Clean Water Act—(CWA) (1972, 1987); federal law regulating pollutant discharges into surface waters or to POTWs.

DNAPL—dense, non-aqueous phase liquid.

Demolition debris—concrete, brick, asphalt, and other such building materials discarded in the demolition of a building or other improvement to

De minimis—conditions that generally do not present a material risk of harm to public health or the environment and that generally would not be the subject of an enforcement action if brought to the attention of appropriate governmental agencies.

Department of Energy—(DOE) U.S. Department of Energy; agency responsible for research and development of energy technology, marketing of federal power, the nuclear weapons program, and energy regulation.

Drum—a container (typically, but not necessarily, holding 55 gallons (208L) of liquid) that may be used to store hazardous substances or petroleum products.

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Dry wells—underground areas where soil has been removed and replaced with pea gravel, coarse sand, or large rocks. Dry wells are used for drainage, to control storm runoff, for the collection of spilled liquids (intentional and non-intentional) and wastewater disposal (often illegal).

Dwelling—structure or portion thereof used for residential habitation.

Environmental Lien—a charge, security, or encumbrance upon title to a property to secure the payment of a cost, damage, debt, obligation, or duty arising out of response actions, cleanup, or other remediation of hazardous substances or petroleum products upon a property, including (but not limited to) liens imposed pursuant to CERCLA 42 USC § 9607(1) and similar state or local laws.

EPCRA—Emergency Planning and Community Right to Know Act; see SARA Title III.

ERNS List—EPAs emergency response notification system list of reported CERCLA hazardous substance releases or spills in quantities greater than the reportable quantity, as maintained at the National Response Center. Notification requirements for such releases or spills are codified in 40 CFR

Parts 302 and 355.

Ex-situ—treatment of contaminated materials offsite or away from their point of generation.

Federal Register, (FR)—publication of the United States government published daily (except for federal holidays and weekends) containing all proposed and final regulations and some other activities of the federal government. When regulations become final, they are included in the Code of

Federal Regulations (CFR), as well as published in the Federal Register.

FIFRA—Federal Insecticide, Fungicide and Rodenticide Act (1972, 1988); federal law mandating toxicity testing and registration of pesticides.

FINDS—Facility Index System. FINDS contains both facility information and “pointers” to other sources that contain more detail. These include:

RCRIS, PCS (Permit Compliance System), AIRS (Aerometric Information Retrieval System), FATES (FIFRA [Federal Insecticide Fungicide

Rodenticide Act] and TSCA Enforcement System, FTTS [FIFRA/TSCA Tracking System]), CERCLIS,. DOCKET (Enforcement Docket used to manage and track information on civil judicial enforcement cases for all environmental statues), FURS (Federal Underground Injection Control), FRDS (Federal Reporting Data System), SIA (Surface Impoundments), CICIS (TSCA Chemicals in Commerce Information System), PADS, RCRA-

J (medical waste transporters/disposers), TRIS and TSCA.

Fire Insurance Maps—maps produced for private fire insurance map companies that indicate uses of properties at specified dates and that encompass the Property. These maps are often available at local libraries, historical societies, private resellers, or from the map companies who produced them.

Generator—a person, group, or organization whose activities produce hazardous waste.

HAP—hazardous air pollutant; any of 189 air toxics identified for regulation under the CAA Amendments.

Hazardous Substance—A substance defined as a hazardous substance pursuant to CERCLA 42 USC § 9601 (14), as interpreted by EPA regulations and the courts: “(A) any substance designated pursuant to section 1321 (b)(2)(A) of Title 33, (B) any element, compound, mixture, solution, or substance designated pursuant to section 9602 of this title, (C) any hazardous waste having the characteristics identified under or listed pursuant to section 3001 of the Solid Waste Disposal Act (42 USC § 6921) (but not including any waste the regulation of which under the Solid Waste Disposal

Act (42 USC § 6901 et seq.) has been suspended by Act of Congress), (D) any toxic pollutant listed under section 1317(a) of Title 33, (E) any hazardous air pollutant listed under section 112 of the Clean Air Act (42 USC § 7412), and (F) any imminently hazardous chemical substance or mixture with respect to which the Administrator (of EPA) has taken action pursuant to section 2606 of Title 15. The term does not include petroleum, including crude oil or any fraction thereof which is not otherwise specifically listed or designated as a hazardous substance under subparagraphs (A) through (F) of this paragraph, and the term does not include natural gas, natural gas liquids, liquefied natural gas, or synthetic gas usable for fuel (or mixtures of natural gas and such synthetic gas).”

Hazardous Waste—any hazardous waste having the characteristics identified under or listed pursuant to section 3001 of the Solid Waste Disposal

Act (42 USC § 6921) (but not including any waste the regulation of which under the Solid Waste Disposal Act (42 USC § 6901 et seq.) has been suspended by Act of Congress). The Solid Waste Disposal Act of 1980 amended RCRA. RCRA defines a hazardous waste, in 42 USC § 6903, as:

“solid waste, or combination of solid wastes, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may—

(A) cause, or significantly contribute to an increase in mortality or an increase in serious irreversible, or incapacitating irreversible, illness; or (B) pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of, or otherwise managed”.

HAZWOPER—Hazardous Waste Operations and Emergency Response

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HCFCs—hydrochlorofluorocarbon; family of substances temporarily allowed as CFC substitutes in refrigerants and industrial applications.

HMIRS—Hazardous Materials Information Reporting System. HMIRS contains hazardous material spill incidents reported to DOT.

HON—hazardous organic NESHAP; MACT standard for the organic chemical manufacturing industry.

HSWA—Hazardous and Solid Waste Amendments (1984); amendments to RCRA establishing a timetable for land bans and more stringent UST requirements.

IDLH—immediately dangerous to life or health.

In Situ—treatment of contaminated areas without excavation or other removal, as in the in situ treatment of contaminated soils through biodegradation.

Land bans: RCRA—provisions…