761_17183_SAR_SpecificationsAppIII.pdf

Bidding and Contract Document (02/19) Project Name: Philadelphia Street Site File No. 761/17183.SAR

APPENDIX III

SITE DATA

Bidding and Contract Document (02/19) Project Name: Philadelphia Street Site File No. 761/17183.SAR

2007 BROWNFIELD REDVELOPMENT

ASSESSMENT REPORT

Bidding and Contract Document (02/19) Project Name: Philadelphia Street Site File No. 761/17183.SAR

2009 UST/SOIL REMOVAL REPORT

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1.0 INTRODUCTION

The Mannik & Smith Group (MSG) was retained by the Michigan Department of Management and Budget (DMB) to perform interim response (IR) measures for the Michigan Department of Environmental Quality (DEQ) under the Architectural and Engineering (A&E) Indefinite Scope-Indefinite Delivery (ISID) Discretionary Contract (No. 00233) as the Professional Service Contractor at the John’s Tire Repair Property (Site), located at 665 East Philadelphia St., Detroit, Wayne County, Michigan. The Site was listed by the DEQ as an “Open” leaking underground storage tank (LUST) (Facility ID: 50005645 and Release # C-0270-08) site regulated under Part 213, Leaking Underground Storage Tanks of the Natural Resources and Environmental Protection Act (NREPA), 1994 P.A. 451, as amended.

The DEQ LUST database indicated two underground storage tanks (USTs) of unknown capacities and contents were present on the property. In 2007, DEQ conducted a geophysical survey on the property that identified the suspected location of two large underground storage tank (UST) and one small UST. Soil samples collected by DEQ in 2007, indicated that surficial and subsurface soils were impacted by petroleum products.

The property tax-reverted to the State in January of 2005 and is currently owned by the Michigan Land Bank Fast Track Authority (MLBFTA). To facilitate the property’s sale and redevelopment, the MLBFTA, through the DEQ and a United States Environmental Protection Agency (USEPA) Brownfield Cleanup Program grant, requested MSG’s professional services to assist with removal of the USTs and, to the extent practical and within budgetary constraints, impacted soils.

1.1 Site Description

The Site occupies approximately 0.28 acres located at 665 East Philadelphia St. in Detroit, Wayne County, Michigan. East Philadelphia Street borders the Site to the south and Oakland Street borders the Site to the east, with residential properties beyond both streets. Vacant light industrial/commercial property is located to the north and a small park is located to the east beyond Oakland Street. The Site as referenced to nearby roads and major topographical features is shown on Figure 1, Site Location Map.

The Site is a vacant property formerly occupied by a service station. The site vicinity is serviced by municipal water and sewerage system supplied by the City of Detroit. The former gasoline filling station and associated pavement and pump island have been removed from the property prior to MSG’s IR activities. The historic Site layout, including the former building, UST and pump island, is depicted on Figure 2, Site Schematic.

1.2 Project Background

The project background information presented in the following subsections was compiled using available historical information from the following documents:

• Brownfield Redevelopment Assessment Report, DEQ Pre-Remedial Group, September 13, 2007.

• Electromagnetic Survey Report, DEQ Remediation and Redevelopment Division (RRD), September 13, 2007.

In preparation and completion of this project, MSG had to rely on information obtained and interpreted by others and therefore, cannot attest to the veracity of such data. As such, MSG has accepted the work previously performed by others at face value.

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1.3 Site History

The Site is a former service station located in the City of Detroit. According to the limited historical data, the Site was used as a service station from 1950 until at least the late 1970s. The exact use of the site prior to 1950 is uncetain. Three (3) USTs were depicted on the south side of the building on a 1950 Sanborn map.

The DEQ electromagnetic survey conducted in 2007 indicated two large suspect USTs on the south side of the building and one small UST on the north side of the building. The survey was completed on March, 2007 using a Geonics EM-31.

In September 2007, the DEQ via cooperative agreement with the USEPA conducted a Brownfield Redevelopment Assessment (BFRA) for the Site. Soil sample results confirmed the Site is a “facility” due to petroleum hydrocarbons exceeding Part 213 Tier I Risk Based Screening Levels (RBSLs) as revised January 23, 2006 (a.k.a. Part 201 Generic Residential & Commercial I Cleanup Criteria). DEQ pre-abatement sample locations are depicted on Figure 3, Pre-Interim Response Soil Sample Locations. The soil samples collected by DEQ detected petroleum impacts near the UST cavities and the pump island exceed RBSLs. PNAs were also detected at levels above RBSLs in a shallow soil sample (SB-9, 1-2’) collected near a rear garage door of the former service station building. Both surface and sub-surface soil samples, had various metals detected at concentrations exceeded their respective RBSLs for the protection of drinking water and surface water.

The metal concentrations do not appear to be associated with a UST release.

The BFRA report recommended the removal of the USTs and risks due to direct contact with soils be evaluated prior to redevelopment. Pre-abatement soil petroleum impacts exceeding RBSLs are depicted on Figure 3, and summarized in Table 1, Pre-Abatement Soil Impacts Detection Summary.

To facilitate Site redevelopment, the City of Detroit razed the building and removed the pavement and pump islands from the property in 2009. The Site was graded pending UST and limited soil removal.

1.4 Hydrogeological Setting

Based on the USGS 7.5-minute Series Topographic Map Highland Park, Michigan Quadrangle (dated 1968, photorevised 1983), the Site is located approximately 630 feet above mean sea level (msl). The Site topography is relatively flat, with a regional slope decreasing gradually to the southeast. The nearest major surface water body is the Detroit River, which is approximately four (4) miles southeast of the Site. Shallow ground water flow typically mimics surface topography and would be anticipated to flow to the southeast, towards the Detroit River. However, based on the Detroit area regional geology (predominantly clay), shallow ground water would likely be of limited extent (if present) and its flow highly controlled by anthropogenic features such as storm drains and utility corridors.

A surficial geology map titled Quaternary Geology of Southern Michigan (compiled in 1982 by W.R. Farrand and published by the Michigan Geological Survey) depicts the surficial geology in the Site vicinity to be composed of gray to dark reddish brown lacustrine clay and silt. A bedrock map titled Bedrock Geology of Southern Michigan (compiled in 1987 by Randall L. Milstein and published by the Michigan Geological Survey) indicates bedrock beneath the Site is comprised of the Middle Devonian Dundee Limestone.

Results of the BFRA and MSG’s IR activities indicate Site geology consists primarily of silty fine sand with some gravel from just beneath the concrete surface (removed during demolition activities) to a depth of up to two (2) feet below grade. The sand is underlain by silty clay with gravel and sand to at least a depth of seven

(7) feet (the maximum depth investigated).

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2.0 OBJECTIVES AND SCOPE OF WORK

MSG developed project objectives and a scope of work pursuant to Part 213. The following subsections summarize the project objectives and scope of work employed during the completion of the IR activities at the Site conducted during the Summer of 2009. These objectives and scope of work are in general accordance with MSG’s IR Work Plan dated April 10, 2009.

2.1 Objectives

The objectives of the project were to remove the three (3) USTs and contaminated soils at the Site to the extent possible as allowed for by the project budget. The mitigation goal was to obtain a site classification of 3 or less in accordance with RRD Operational Memorandum No. 3 Part 213 LUST Site Classification System.

2.2 Scope of Work

To fulfill the objectives, MSG developed the following scope of work:

1) Prepare bid specifications and assist DEQ with procuring a trade contractor

2) Identify and properly abandon all utilities that were located within the excavation area.

3) Remove the two (2) 3,000 gallon USTs and one (1) 525 gallon UST.

4) Excavate impacted soils and dispose offsite.

5) Collect soil confirmation samples from the sidewalls and floor of the excavation.

6) Backfill and compact the excavation with MDOT Class II or Class III sand from a clean off-site source.

7) Restore the Site, including grading of lawn areas, placement of topsoil and hydroseeding.

8) Document and re-evaluate the site based on the findings and results of the IR activities.

3.0 METHODOLOGIES AND FIELD ACTIVITIES

MSG prepared bid specifications and assisted the State with selection of a trade contractor for this project. The State contracted with Job Site Services, Inc. (JSS) of Bay City Michigan to conduct UST removal and impacted soil excavation activities. MSG on behalf of MDEQ oversaw and documented the IR activities and collected confirmation samples from the IR soil excavations. The following subsections provide a description of the field methodologies employed by JSS and MSG during the completion of the work. A photographic log of the field activities is provided in Appendix A, Photographic Log.

3.1 UST Systems Removal

On October 5, 2009, a Caterpillar 325BL hydraulic excavator was used to remove soils and expose a 525 gallon steel UST located in the central portion of the Site. The UST was approximately 4 ft wide and 5’ 7” long. No piping associated with the 525 gallon UST was observed. The UST was full of what appeared to be a mixture of used motor oil and water. The UST contents were removed by Usher Oil (Usher) of Detroit, Michigan using a tanker truck. The UST interior was then vented and field screened using a four-gas meter for the lower explosive limit (LEL), oxygen, hydrogen sulfide, and carbon monoxide until the UST was safe for cleaning and dismantling. Once removed from the ground, the tank was observed to be in poor condition with rusting on the north side of the tank that had caused holes approximately ¾ of an inch in diameter. One pre-remedial excavation sample was collected from the soils directly below the former UST location (C UST) and submitted to the DEQ Laboratory for analysis of VOCs by USEPA method 8260, polynuclear aromatic hydrocarbons (PNAs) by USEPA method 8270 and lead by USEPA method 6020.

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Also on October 5, 2009, JSS utilized a hydraulic excavator to remove soils and expose two 3,000-gallon steel USTs located in the southern portion of the Site. Each of the tanks were approximately five (5) feet, four

(4) inches in width and approximately 18 feet in length. Both USTs contained water with a gas/diesel/petroleum fuel odor. The contents of each tank was removed by Usher using a tanker truck and properly disposed of offsite. After both USTs were removed from the ground, several holes in both tanks were observed. The holes ranged from pinholes to one inch in size.

The two 3,000-gallon USTs were removed from the ground on October 6, 2009. Once the USTs were removed from the ground, a pre-remedial excavation sample was collected from the soils beneath each of the fuel USTs (N UST and S UST) and submitted to the DEQ Laboratory for analysis of benzene, toluene, ethylbenzene and xylenes (BTEX) methyl-tert-butyl-ether (MTBE), and trimethylbenzenes (TMBs) by USEPA method 8260; PNAs by USEPA method 8270; and lead by USEPA method 6020. After the tanks were cut open, removed from the ground and staged on plastic sheeting, the interior of both the USTs were then field screened with a four-gas meter for the LEL, oxygen, hydrogen sulfide, and carbon monoxide and vented until the each UST was safe for cleaning and dismantling.

During the removal and excavation around the 3,000-gallon USTs, MSG encountered three pipes that began at the northeastern corner of the north UST and extended toward but terminated before reaching the former pump island as depicted on Figure 2. The piping run segment near the pump island is believed to have been removed by the City during building demolition and pavement removal. Photographs of the UST removal activities are included in Appendix A.

In total, Usher removed approximately 6,200 gallons of liquid from the three USTs located on site. All liquids were disposed/recycled at Usher Oil in Detroit, Michigan.

All three USTs and associated piping were taken to Kimmel Scrap Iron and Metal Company of Detroit, Michigan for recycling. A copy of the updated Registration of Underground Storage Tanks form EQP3821 submitted to the MDEQ Waste and Hazardous Materials Division is contained in Appendix B, UST Registration Documents.

3.2 Soil Excavation

From October 5 through 26, 2009 a Caterpillar 325BL hydraulic excavator with a two cubic yard bucket was used by JSS to excavate impacted soils. The soil excavation focused on removal of soils showed signs of the greatest petroleum hydrocarbon impact without encroaching upon or undermining the East Philadelphia and Oakland street rights-of-way. Sloping and/or tier benching was utilized as necessary to prevent collapse of excavation the sidewalls.

MSG directed the soil removal based on field screening of soils around the USTs using a calibrated photoionization detector (PID), visual staining, and olfactory evidence of impacts. The excavator loaded the petroleum hydrocarbon impacted soil directly into a gravel train for off-site disposal and transport. The petroleum hydrocarbon impacts extended through a fine-medium grained sand that had been used as backfill around the USTs and a short distance into the native clay soils. Some impacted soil could not be removed without undermining the right-of-way and consequently were left in place. The final remedial excavation covered an area of approximately 3,370 square feet and extended to a maximum depth of 12 feet below ground level in the former tank cavity area and eight feet below ground level in the northeastern portion of the southern excavation. Ground water was not present within the excavation. Approximately 1,760 tons of impacted soils were excavated and properly disposed of at Woodland Meadows RDF in Wayne, Michigan.

Waste disposal records and manifests are included in Appendix C, Waste Disposal Records. The approximate areas of excavations are depicted on Figure 4, Excavation Confirmation Sample Locations.

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Impacted soils were removed to the extent possible while protecting adjacent properties and right-of-ways and within budgetary constraints.

3.3 Confirmation Sample Collection

Concurrent with the soil excavation activities, MSG collected confirmatory soil samples to assess the extent of remaining impact. These confirmatory soil samples were collected at frequency described in the Sampling Strategies and Statistics Training Materials for Part 201 Cleanup Criteria guidance document dated 2002. In total, twenty-two (22) confirmation soil samples were collected from the excavation sidewalls and floor (thirteen sidewall and nine floor samples). Excavation floor and sidewall samples were collected by hand (when safely accessible) or by using the excavator bucket to acquire a grab sample. Confirmation soil sample locations are depicted on Figure 4.

Soil samples collected from the central UST (that appeared to be utilized for used motor oil storage) excavation were submitted to the DEQ Laboratory for analysis of VOCs by EPA Method 8260, PNAs using USEPA Method 8270, and metals by EPA Method 6010/6020. The metals tested include: cadmium, chromium, copper, nickel, lead, zinc, barium, cobolt, manganese, iron, lithium, aluminum, beryllium, molybdenum, strontium, titanium and vanadium. Analytical detections for the soil samples are summarized in Table 2, Confirmation Sample Analytical Detections Summary.

Soil samples collected from the southern excavation (that housed the two USTs utilized for fuel storage) were submitted to the DEQ Laboratory for analysis of BTEX/MTBE/TMB by USEPA Method 8260, PNAs using USEPA Method 8270 and lead by USEPA Method 6020. Analytical results for soil samples collected in the southern excavation are summarized in Table 2.

3.4 Excavation Backfill and Site Restoration

Upon completion of the excavation and confirmation sampling, MDOT Class II fill sand was placed into the excavations and compacted in eight (8) inch lifts. AApproximately 1,670 tons of MDOT Class II sand was used during the backfilling operations. Four (4) inches of clean topsoil were placed over the excavations, disturbed areas and traffic areas. In total, approximately 80 cubic yards of topsoil were used to restore the Site. On October 13, 2009, Terrafirma Landscape and Irrigation (Terrafirma) of Ann Arbor covered the topsoil with hydroseed. Photographs of the hydroseeding activities are included in Appendix A.

4.0 RISK BASED CORRECTIVE ACTION EVALUATION

As part of this IR, MSG completed a contaminant exposure pathway evaluation in general accordance with Section 21307(2) (a),(e) and (3)(c); ASTM standard E 1739, Standard Guide for Risk-Based Corrective Action Applied at Petroleum Release Sites, dated 1995 (re-authorized 2002); and the DEQ Remediation and Redevelopment Division Cleanup Criteria Training guidance document dated Summer 2007. The exposure pathway evaluation is used to identify reasonable and relevant pathways as they relate to specific site conditions for determining applicable cleanup criteria. All cleanup criteria associated with a reasonable and relevant exposure pathway are applicable to a site unless the exposure route is reliably restricted.

Figure 5, Exposure Pathway Evaluation presents the results of the contaminant pathway evaluation for the John’s Tire Repair Site based on data gathered by MSG as part of the IR activities and the findings of previous investigations conducted by the DEQ. The pathway evaluation was completed by 1) identifying primary and secondary sources of hazardous substance; 2) evaluating the exposure routes and transport mechanisms if the exposure point is not the source; and 3) identifying potential receptors. Based on the results of this pathway evaluation, analytical results were compared to all Part 213 RBSLs with reasonable and relevant pathways.

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4.1 Source of Hazardous Substance

Primary sources of hazardous substance on the John’s Tire Repair property include three UST systems and a suspected spill(s) near the rear garage door of the former service station that resulted in PNA impacted surface soils. Two of the USTs were located on the southern side of the property and used for storage of fuel that was dispensed through a pump island on the eastern side of the structure (adjacent to Oakland Street).

A third small UST that was apparently used for waste oil storage was located in the central portion of the property. Secondary source materials include impacted soils associated with UST systems and PNA (likely motor oil) spill. The three UST systems and most of the impacted soil were removed during MSG’s interim response activities. The approximate former locations of these primary and secondary sources of hazardous substance are depicted on Figure 3.

MDEQ observed and sampled (SB-9, 1-2’) stained surface soils with PNAs impacts in the vicinity of a rear garage door on the form service station building (Figure 3). MSG did not observe the impacted surface soils and it is likely that they were removed during demolition and grading activities by the City of Detroit, prior to the IR actions.

4.2 Pathway Evaluation

The relevance of each exposure pathway was evaluated based on the physical setting, taking into account current and potential future site conditions and mechanisms that may expose a receptor to chemical impacts originating at the Site. Figure 5 summarizes the exposure evaluation, the exposure pathways relevance to the Site conditions, and applicable Part 213 Tier I RBSLs. The exposure pathways and applicable Part 213 RBSLs for each pathway evaluated are specified below:

• Acute fire and explosion hazards and non-systemic inhalation hazards.

• Soil Leaching to Ground Water used for Drinking Water.

• Soil Leaching to Ground Water Venting to Surface Water.

• Soil Leaching to Ground Water Protective of Ground Water Direct Contact.

• Soil Volatilization to Indoor Air.

• Soil Volatilization to Ambient Air.

• Soil Inhalation of Particulate Matter.

• Soil Direct Contact.

• Ground Water Direct Contact.

• Ground Water Ingestion as Drinking Water.

• Ground Water Volatilization to Indoor Air.

• Ground Water Venting to Surface Water.

Acute Fire and Explosion Hazards and Inhalation Hazards The presence of free product and/or soil or ground water grossly impacted by VOCs may pose a fire and explosion risk or non-systemic (acute) inhalation risk. Soil saturation concentration screening levels (Csat) have been developed by MDEQ. Acute screening levels for flammability explosivity (FESLs) and inhalation (AISL) for ground water have also been developed by MDEQ.

Historically the USTs contained free product and a mixture of free product a water was removed from one or more of the USTs during IR activities. A release from the UST systems has occurred and grossly impacted soil were removed during the IR excavation. Based on the historic presence free product of free product in the USTs, and encountered grossly impacted soils during IR activities, there is a potential for acute hazards to be present. Therefore, acute hazards pathways may become complete making it relevant and analytical results will be compared to their respective acute hazard RBSLs.

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Soil Leaching to Ground Water used for Drinking Water The soil leaching to ground water used for drinking water pathway identifies the potential of a chemical to leach from soil and impact ground water at concentrations greater than the corresponding drinking water criteria (DWC). The RBSLs for the soil leaching to ground water used for drinking water are the drinking water protection criteria (DWPC).

Ground water was not encountered during the excavation activities and based on regional hydrogeology is not likely to be found in significant quantities. Currently all area residences and businesses are serviced by the City of Detroit municipal water supply system and therefore the soil leaching to ground water used for drinking water pathway is currently incomplete. However, if a vulnerable aquifer is present in the area and a drinking water supply well was installed in the aquifer the DWPC pathway may be completed and therefore the soil leaching to ground water used for drinking water pathway is relevant until, proven otherwise, and analytical results will be compared to the DWPC.

Soil Leaching to Ground Water Venting to Surface Water The soil leaching to ground water venting to surface water pathway identifies the potential of a chemical to leach from soil and impact ground water at concentrations greater than the corresponding ground water surface water interface criteria (GSIC). The RBSLs for the soil leaching to ground water venting to surface water pathway are the ground water surface water interface protection criteria (GSIPC).

The Detroit River is the nearest major surface water body and is located approximately four miles southeast of the Site. The Detroit area is serviced by a combined storm/sanitary sewer system. Therefore, the soil leaching to ground water venting to surface water pathway is currently incomplete. However the pathway could become complete if a surface water body was installed (i.e. pond) or a storm drain that discharges to a surface water body was constructed in the vicinity of the impacted soils. Therefore the soil leaching to ground water venting to surface water pathway may become complete, making it relevant and analytical results will be compared to the GSIPC.

Soil Leaching to Ground Water Protective of Direct Contact The soil leaching to ground water protective of direct contact pathway identifies the potential of a chemical to leach from soil and impact ground water at concentrations greater than the corresponding ground water contact criteria (GCC). The RBSLs for the soil leaching to ground water protective of the direct contact pathway are the ground water contact protection criteria (GCPC).

Ground water may be present in thin sand seams or utility corridors beneath the Site and utility or construction workers may reasonably come into contact with impacted water. Therefore, soil leaching to ground water protective of direct contact is or may reasonably become complete making it a relevant pathway for the Site and analytical results will be compared to GCPC.

Soil Volatilization to Indoor Air The soil volatilization to indoor air inhalation pathway identifies the potential for a chemical to volatilize from soil and impact indoor air at a concentration that adversely affects human health. The RBSLs for the volatilization from soil to indoor air are the soil volatilization to indoor air inhalation criteria (SVIIC).

Currently, no structures are present on Site; however, construction of future structures may occur on the Site property. Therefore, the soil volatilization to indoor air pathway may become complete making it a relevant pathway and analytical results will be compared to SVIIC.

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Soil Volatilization to Ambient Air The soil volatilization to ambient air pathway identifies the potential for a chemical to volatilize from soil and impact ambient (outdoor) air at a concentration that adversely affects human health. The RBSLs for the soil volatilization to ambient air pathway are the volatile soil inhalation criteria (VSIC). Because the amount of the impact source influences the amount to vapors released, the DEQ has developed three criteria based on the source thickness; infinite source VSIC, finite source VSIC for five meter source thickness, and finite source VSIC for two meter source thickness.

The Site is unoccupied unrestricted property. Therefore, soil volatilization to ambient air is a pathway that is or may reasonably become complete, making it a relevant pathway. The finite source VSIC for 2 meter source thickness is the criteria for the soil volatilization to ambient air pathway relevant to the Site and will be used as the default RBSLs for comparison to the analytical results.

Soil Inhalation of Particulate Matter The soil inhalation of particulate matter pathway identifies the potential for a chemical to yield particulates at a concentration that would adversely affect human health. The RBSLs for the soil inhalation of particulate matter pathway are the particulate soil inhalation criteria (PSIC).

Soil excavation by utility and construction workers could expose occupants and workers at the site to impacted soil particulate inhalation (dust). Therefore, the soil inhalation of particulate matter is or may become complete making it a relevant pathway and analytical results will be compared to PSIC.

Soil Direct Contact Criteria The soil direct contact pathway identifies the potential for adverse health effects due to long-term ingestion of and dermal exposure to impacted soils. The RBSLs for the soil direct contact pathway are the soil direct contact criteria (SDCC).

Utility and construction workers at the site could be exposed to impacted soils. Therefore, the soil direct contact is or may become complete making it a relevant pathway and analytical results will be compared to

SDCC.

Ground Water Direct Contact The ground water direct contact pathway identifies the potential for a chemical to occur in ground water at a concentration that would cause adverse health effects resulting from dermal exposures. The RBSLs for the ground water direct contact pathway are the ground water contact criteria (GCC).

Ground water may be present in thin sand seams or utility corridors beneath the Site and utility or construction workers may reasonably come into contact with impacted water. Therefore, ground water direct contact is or may reasonably become complete making it a relevant pathway for the Site and analytical results will be compared to GCC.

Ground Water Ingestion as Drinking Water The ground water ingestion as drinking water pathway identifies the potential for a chemical in ground water to cause adverse health effects when ingested. The RBSLs for the ground water ingestion as drinking water pathway are the drinking water criteria (DWC).

Ground water was not encountered during the excavation activities and based on regional hydrogeology is not likely to be found in significant quantities. The drinking water pathway will continue to be considered relevant unless further investigation verifies shallow groundwater is not present or if present is demonstrated to be “ground water not in an aquifer”. Until the drink water pathway is demonstration to be irrelevant, ground water (if encountered) sample analytical results will be compared to DWC.

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Ground Water Volatilization to Indoor Air The ground water volatilization to indoor air pathway identifies the potential for a chemical to volatilize from ground water and impact indoor air at a concentration that adversely affects human health. The RBSLs for the ground water volatilization to indoor air pathway are the ground water volatilization to indoor air inhalation criteria (GVIIC).

Ground water may be present in thin sand seams or utility corridors beneath the site; therefore, the ground water volatilization to indoor air pathway is or may reasonably become complete making it a relevant pathway and analytical results will be compared to GVIIC.

Ground Water Venting to Surface Water The ground water venting to surface water pathway identifies the potential of a chemical in ground water to adversely affect surface waters where the ground water vents to the surface water. The RBSLs for the ground water venting to surface water pathway are the GSIC.

Ground water was not encountered during the excavation activities and based on regional hydrogeology is not likely to be found in significant quantities; however, ground water may be present in thin sand seams or utility corridors beneath the Site. The Detroit River is located approximately four miles southeast of the Site and the Detroit area is serviced by a combined storm/sanitary sewer system. Therefore, the ground water venting to surface water pathway is currently incomplete; however, if a surface water body (i.e. pond) or storm drain discharging to a surface water body was constructed, the ground water venting to surface water pathway could reasonably become complete making it a relevant pathway. Therefore, soil analytical results will be compared to GSIC.

4.3 Potential Receptors

MSG conducted an assessment to determine the potential receptors that could be exposed to chemicals impacting the Site. The potential receptor assessment included a review of the current Site conditions, the foreseeable future intended use of the Site, and foreseeable human and ecological receptors both on-site and off-site. Based on these factors, potentially exposed receptors at the Site include:

• Current and future residential inhabitants, and/or commercial/industrial workers who may be exposed to impacted subsurface soil, ground water and vapors.

• Construction and/or utility workers that are installing, maintaining or improving utilities or new construction activities in the vicinity of the Site that may be exposed to impacted subsurface soil, ground water and vapors.

• Ecological receptors (flora and fauna), that may come in direct contact with impacted soil or ground water.

4.4 Selection of Appropriate RBSLs for Analytical Data Comparison

Based on the available information, all Part 213 exposure pathways were deemed reasonable and relevant to the site. However, if further investigation demonstrates shallow ground water is not present or only present as “ground water not in an aquifer” the drinking water pathway may then be considered irrelevant and the DWPC and the DWC would no longer be applicable to the Site.

Potential receptors included residential inhabitants, commercial/industrial/construction/utility workers and ecological receptors. The Part 201/213 Generic Residential & Commercial I Cleanup Criteria is the most stringent of the land use based cleanup criteria. Therefore the Part 201/213 Generic Residential &

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Commercial I Cleanup Criteria for all of the associated relevant exposure pathways will be used as the RBSLs for comparison to the analytical results.

5.0 ANALYTICAL RESULTS

The following subsections include a discussion of pre-excavation analytical results, post remedial confirmation sample results and residual contaminant distribution from the soil sampling conducted during the 2009 IR activities. Ground water was not encountered during IR activities; therefore, laboratory analysis is limited to soils. MSG submitted a total of 25 soil samples for laboratory analysis including three soil samples collected directly beneath each of the removed USTs prior to IR soil excavation and 22 post IR excavation confirmation samples. Laboratory data sheets are contained in Appendix D, Laboratory Data Sheets.

5.1 Pre-Abatement Sample Analytical Results

MSG collected pre-abatement soil samples beneath all three USTs (C UST, N UST, and S UST) prior to soil removal activities. Laboratory analysis indicate that only the central UST (C UST) had VOC and PNA compounds detected at concentrations above their respective RBSLs; however, strong petroleum odors were noted in soils beneath all three USTs. Laboratory analysis did not detect the presence of MTBE, a common additive to unleaded gasoline since 1978, in any of the pre-abatement soil samples. Soil sample analytical results from pre-abatement activities, including the MDEQ assessment sampling, are summarized and compared to Part 213 RBSLs in Table 1 and depicted on Figure 3.

Laboratory analysis of the pre-abatement soil samples collected by DEQ detected elevated metal (antimony, arsenic, cadmium, chromium, cobalt copper, cyanide, iron, lead, mercury, molybdenum, selenium silver, vanadium and zinc) and PNAs at concentrations exceeding one or more of their respective RBSLs for DWCP, GSIP, or SDCC. Most of the DEQ sample elevated metal concentrations were detected in surface soil samples and do not appear to be associated with a release from the UST systems. Lead was detected was detected in the MSG central UST (C UST) sample above the default state background level (21,000 μg/Kg) but below all RBSLs.

Surface soils were removed and/or re-graded on the property during demolition activities conducted by the City of Detroit. Soils in the vicinity of all three UST soil samples were removed during IR excavation activities.

5.2 Confirmation Sample Results

MSG conducted IR source removal excavations from the central UST area and a southern UST/pump island area. The central UST area excavation included removal of the waste oil UST and petroleum impacted soil.

The southern UST/pump island excavation area excavation removed the two southern USTs (gasoline or diesel containing), piping run and petroleum impacted soils. Confirmations soil samples collected in and around the central UST excavation were submitted to the DEQ Laboratory for analysis of VOCs, PNAs and metals. Soil samples collected from the southern UST excavation were submitted to the DEQ Laboratory for analysis of BTEX/MTBE/TMB, PNAs, and lead. Post IR excavation soil confirmation sample results are summarized and compared to Part 213 RBSLs in Table 2 and depicted on Figure 4.

Confirmation sample analytical results exceeded Part 213 RBSLs for GSIPC and/or DWPC for one or more petroleum compound (VOCs or PNAs) at sidewall sample locations S10, S11 and S12 collected from the southern excavation. The VOC and PNAs detected during this investigation were all petroleum hydrocarbons that are common constituents of gasoline or diesel fuel. All petroleum compound concentrations detected in confirmation samples from the central UST IR soil excavation were below their respective most stringent RBSLs.

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Confirmation samples collected from the central UST (that was apparently utilized for used motor oil storage) excavation were submitted for laboratory analysis of 16 metals (see Table 2). Confirmation samples from the southern USTs/pump island (used for gasoline or diesel fuel storage/dispensing) excavation were submitted for analysis of lead. Confirmation sample analytical results from the central IR excavation exceeded RBSLs for DWPC and/or GSIPC for one or more of the metals: aluminum, cobalt, iron, manganese, and/or strontium.

The metal concentrations are similar to those detected throughout the site by DEQ. Lead concentrations did not exceed its most restrictive RBSL in any of the confirmation samples.

5.3 Distribution of Residual Soil Impacts

MSG compared soil analytical results collected during MSG’s IR activities to the applicable RBSLs as identified in Section 4.2. In areas where residual chemical concentrations exceed RBSLs, implementation of corrective action may be appropriate if the exposure pathway is not reliably restricted.

Laboratory analysis detected VOCs in soils at concentrations exceeding their respective RBSLs for GSIPC and/or DWPC in confirmation samples collected from the southern IR excavation (for the gasoline or diesel USTs, piping and pump island) in sidewall samples S10, S11 and S12. No PNAs or metals (only analyzed for lead) were exceeded by their respective RBSLs in the southern IR excavation confirmation samples.

Confirmation sample analytical results from the used motor oil UST IR excavation were below their respective RBSLs for VOCs and PNAs. However, RBSLs for one or more metals (aluminum, cobalt, iron, manganese, and/or strontium) was exceeded their respective DWPC and/or GSIPC in the used motor oil UST IR excavation confirmation samples S2, S3, S4, S5 and F2. The soil sample analytical detections are summarized and compared to RBSLs in Table 2.

6.0 SITE CLASSIFICATION

In accordance with RRD Operational Memorandum No. 3, Part 213 LUST Site Classification System (Op Memo 3), and the results of the pathway exposure evaluation, MSG has classified the abandoned gas station at 8727 Petoskey Avenue, Detroit Site as a Class 3 Site because soils are impacted at levels above the DWPC and GSIPC. Figure 5 depicts the relevant pathways, RBSLs exceeded and includes a site classification score for each pathway with criteria exceeded.

MSG believes the Site may be closed based on its knowledge of the regional geology provided DEQ concludes sufficient information is available to determine that the exceeded RBSL exposure pathways are reliably restricted to prevent receptor exposures pursuant to Part 213. Conversely, if DEQ requires further hydrogeological investigation to assess the exceeded RBSL exposure pathways, the following actions could reduce the Site Part 213 risk classification or allow for Site closure without conducting further remedial activities:

DWPC/DWC

If it can be demonstrated shallow ground water is not present or only present as “ground water not in an aquifer” the drinking water pathway could be considered incomplete and the DWPC would not be applicable.

Additionally, the DWPC/DWC would be considered “not applicable” if ground water is reliably restricted from future use. If the DWPC and DWC were no longer applicable RBSLs, the Part 213 site risk category could be lowered to a Class 4 Site Score.

GSIPC/GSIC

If surface water conduits are reliably restricted (installation of ponds or storm drains) the GSIPC would no longer be applicable to the Site’s Part 213 cleanup requirements. Alternatively, a site specific GSIPC could be developed by conducting leach testing of soils or development of site specific mixing zone based GSIC that could raise the acceptable concentration of the site specific GSIPC. If the drinking water and ground

THE MANNIK & SMITH GROUP, INC. Page 12 of 12 water surface water interface screening levels met-site specific criteria or were reliably restricted, the Site could meet the Part 213 closure requirements.

7.0 CONCLUSIONS

Based on the results of the UST system removal, soil sampling, and site restoration activities conducted on site, MSG concludes the following:

• A 525-gallon used motor oil UST was removed on October 5, 2009 and two gasoline/diesel 3,000-gallon USTs were removed on October 6, 2009.

• Approximately, 6,200 gallons of petroleum impacted water and petroleum product were removed from the gasoline/diesel UST systems.

• Approximately 1,760 cubic yards of petroleum impacted soils were removed and properly disposed of off-site at Woodland Meadows RDF in Wayne, Michigan.

• Ground water was not encountered within the excavation.

• Confirmatory soil samples from the remedial excavation were collected consistent with DEQ guidelines.

• Excavation confirmation soil samples indicate residual soil impacts exceed GSIP and DWPC RBSLs onsite and likely extend into the East Philadelphia and Oakland Street rights-of-way.

• Site restoration was completed by backfilling the excavation with clean fill and covering the fill with topsoil and hydro-seed.

• In accordance with RRD Op Memo 3, the site has been classified as a Part 213 Class 3 Site.

8.0 RECOMMENDATIONS

After reviewing the results of the IR soil excavation activities and confirmation sampling results, MSG has the following recommendations:

• MDEQ should further investigate the drinking water pathway to determine if a vulnerable aquifer is present and the relevance of the drinking water pathway (i.e. “ground water not in an aquifer”).

• MDEQ should assess what (if any) additional restrictions would be required to reliably restrict the ground water surface water pathway (i.e. prohibit the installation of a surface water body or storm drain connected to a surface water body).

• If it can be determined that the drinking water and groundwater to surface water interface receptors/ points of compliance meet site-specific criteria or are reliably restricted, MDEQ should lower the Part 213 Site Score or grant Site closure accordingly.

Table 1 Pre-Abatement Soil Impacts Analytical Detection Summary

John's Tire Repair Detroit, MI

Be nz en e n- Bu tyl be nz en e se c-B uty lbe nz en e

Ch lor ob en ze ne

Cy clo he xa ne

1,2 -D ich lor ob en ze ne

1,4 -D ich lor ob en ze ne

Et hy lbe nz en e

Iso pr op ylb en ze ne

2- Me thy na ph tha len e

Na ph tha len e n- Pr op ylb en ze ne p- Iso pr op yl tol ue ne

To lue ne

1,2 ,3-

Tr im eth ylb en ze ne

1,2 ,4-

Tr im eth ylb en ze ne

1,3 ,5-

Tr im eth ylb en ze ne

To tal

X yle ne s

NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

100 1,600 1,600 2,000 NA 14,000 1,700 1,500 91,000 57,000 35,000 1,600 NA 16,000 NA 2,100 1,800 5,600

4,000 (X) ID ID 940 NA 360 290 360 ID ID 870 NA NA 2,800 NA 570 1,100 700

2.2E+05 1.2E+05 88,000 2.6E+05 (C) NA 2.1E+05 (C) 1.4E+05 1.4E+05 (C) 3.9E+05 (C) 5.5E+06 2.1E+06 3.0E+05 NA 2.5E+05 (C) NA 1.1E+05 (C) 94,000 (C) 1.5E+05 (C)

1,600 ID ID 1.2E+05 NA 2.1E+05 (C) 19,000 87,000 3.9E+05 (C) ID 2.5E+05 ID NA 2.5E+05 (C) NA 1.1E+05 (C) 94,000 (C) 1.5E+05 (C) 13,000 ID ID 7.7E+05 NA 3.9E+07 77,000 7.2E+05 1.7E+06 ID 3.0E+05 ID NA 2.8E+06 NA 2.10E+07 1.6E+07 4.6E+07 34,000 ID ID 9.9E+05 NA 3.9E+07 77,000 1.0E+06 1.7E+06 ID 3.0E+05 ID NA 5.1E+06 NA 5.0E+08 3.8E+08 6.1E+07 79,000 ID ID 2.1E+06 NA 5.2E+07 1.1E+05 2.2E+06 2.8E+06 ID 3.0E+05 ID NA 1.2E+07 NA 5.0E+08 3.8E+08 1.3E+08

3.8E+08 ID ID 4.7E+09 NA 1.0E+11 4.5E+08 1.0E+10 5.8E+09 ID 2.0E+08 1.3E+09 NA 2.7E+10 NA 8.2E+10 8.2E+10 2.9E+11 1.8E+05 2.5E+06 2.5E+06 2.6E+05 (C) NA 2.1E+05 (C) 4.0E+05 1.4E+05 (C) 3.9E+05 (C) 8.1E+06 1.6E+07 2.5E+06 NA 2.5E+05 (C) NA 1.1E+05 (C) 94,000 (C) 1.5E+05 (C) 4.0E+05 1.0E+07 1.0E+07 2.6E+05 NA 2.1E+05 NA 1.40E+05 3.90E+05 NA NA 1.0E+07 NA 2.5E+05 NA 1.10E+05 94,000 1.5E+05

SAMPLE ID Depth SAMPLE DATE SB1 0-1' 4/12/2007 <69 <69 <69 <69 <340 <69 <69 <69 <69 <340 <340 <69 <69 <69 <69 <69 <69 <209 SB2 5-11" 4/12/2007 <77 <77 <77 <77 <380 <77 <77 <77 <77 <380 <380 <77 <77 <77 <77 <77 <77 <227

SB2 DUP 5-11" 4/12/2007 <62 <62 <62 <62 <310 <62 <62 <62 <62 <310 <310 <62 <62 <62 <62 <62 <62 <182 SB3 2.5-3.5' 4/12/2007 77 1,200 310 <64 2,300 <64 <64 1,300 670 1,600 2,400 3,200 100 <64 360 68 140 470 SB4 4-6' 4/12/2007 150 <70 300 <70 4,100 <70 <70 4,100 1,200 930 4,300 4,900 150 210 1,900 900 2,600 3,190 SB5 5-8' 4/12/2007 1,200 <60 <60 <60 890 <60 <60 <60 <60 <300 <300 <60 <60 69 <60 <60 <60 220 SB6 8-10' 4/12/2007 6,300 <68 420 <68 5,200 <68 <68 2,500 850 1,800 2,500 2,700 210 250 2,100 2,000 1,200 3,030 SB7 1-2' 4/12/2007 10,000 <2100 2,200 <2100 18,000 <2100 <2100 58,000 5,900 8,900 13,000 24,000 <2100 <2100 31,000 140,000 42,000 183,000 SB8 3-4' 4/12/2007 <72 <72 <72 <72 <360 <72 <72 <72 <72 410 <360 <72 <72 <72 <72 <72 <72 <212 SB9 1-2' 4/12/2007 <68 <68 <68 <68 <340 <68 <68 <72 <72 3,300 7,700 <68 <68 <68 <68 <68 <68 <208 SS1 0-6" 4/12/2007 <83 <83 <83 <83 <410 <83 <83 <83 <83 450 1,300 <83 <83 <83 <83 <83 <83 <253 SS2 0-5" 4/12/2007 <88 <88 <88 <88 <440 <88 <88 <88 <88 <440 <440 <88 <88 <88 <88 <88 <88 <268

SS2 DUP 0-5" 4/12/2007 NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS

SS3 0-6" 4/12/2007 <69 <69 <69 <69 <350 <69 <69 <69 <69 <350 <350 <69 <69 69 <69 <69 <69 <209 SS4 0-8" 4/12/2007 <77 <77 <77 <77 <380 <77 <77 <77 <77 <380 <380 <77 <77 <77 <77 <77 <77 <227 SS5 0-8" 4/12/2007 <91 <91 <91 <91 <450 <91 <91 <91 <91 <450 <450 <91 <91 <91 <91 <91 <91 <271 SS6 0-8" 4/12/2007 <65 <65 <65 <65 <330 <65 <65 <65 <65 <330 <330 <65 87 <65 <65 <65 <65 <195 SS7 0-5" 4/12/2007 <71 <71 <71 <71 <360 <71 <71 <71 <71 <360 <360 <71 <71 <71 <71 <71 <71 <211 SS8 0-6" 4/12/2007 <72 <72 <72 <72 <360 <72 <72 <72 <72 <360 <360 <72 <72 120 <72 110 72 273 SS9 0-9" 4/12/2007 <100 <100 <100 <100 <500 <100 <100 <100 <100 <500 <500 <100 <100 <100 <100 <100 <100 <300 SS10 0-5" 4/12/2007 <61 <61 <61 87 <300 350 83 62 <61 <300 <300 <61 <61 <61 380 490 300 360

C UST 6' 10/5/2009 <83 NA NA NA NA NA NA <83 NA NA NA NA NA <83 580 1,000 270 350

N UST 8' 10/6/2009 <72 NA NA NA NA NA NA <72 NA NA NA NA NA <72 <72 <72 <72 <212

S UST 8' 10/6/2009 <81 NA NA NA NA NA NA <81 NA NA NA NA NA <81 <81 <81 <81 <241

Notes:

Roman numerals indicate DEQ criterion number Exceeds Generic Drinking Water Protection Cleanup Criteria (XI) Exceeds Groundwater Surface Water Interface Protection Cleanup Criteria (XII) Exceeds Direct Contact Cleanup Criteria (XIX) Exceeds Generic Drinking Water Protection (XI) and Groundwater Surface Water Interface Protection (XII) Cleanup Criteria Exceeds Generic Drinking Water Protection (XI) and Soil Volatilization to Indoor Air Cleanup (XIV) Criteria Exceeds Generic Drinking Water Protection (XI) and Direct Contact Cleanup Criteria (XIX) Exceeds Generic Drinking Water Protection (XI), Ground Water Surface Water Interface Protection (XII), and Soil Volatilization to Indoor Air (XIV) Cleanup Criteria Exceeds Four or More Cleanup Criteria Equals or Exceeds Soil Saturation Concentration Screening Level (XX) NA = Not Analyzed

Particulate Soil Inhalation Criteria (XVIII)

SOIL: Part 201/213 Generic Residential & Commercial I Cleanup CriteriaRevised January 23, 2006

Units: ug/Kg

Drinking Water Protection Criteria (XI)

Infinite Source Volatile Soil Inhalation Criteria (XV) Finite Source Source Volatile Soil Inhalation Criteria (5 m) (XVI)

Soil Saturation Concentration Screening Levels (Csat) (XX)

Volatile Organic Compounds (VOCs)

Statewide Default Background Levels (X)

Groundwater Contact Protection Criteria (XIII)

Direct Contact Criteria (XIX)

Groundwater/Surface Water Interface Protection Criteria (XII)

Soil Volatilization to Indoor Air Inhalation (XIV)

Finite Source Source Volatile Soil Inhalation Criteria (2 m) (XVII)

S:\Projects\Projects K-O\MDMB0003\ADMINISTRATION\MDMB0003.MasterTable.xls Page 1 of 3

John's Tire Repair Detroit, MI

SAMPLE ID Depth SAMPLE DATE

SB1 0-1' 4/12/2007

SB2 5-11" 4/12/2007

SB2 DUP 5-11" 4/12/2007

SB3 2.5-3.5' 4/12/2007

SB4 4-6' 4/12/2007

SB5 5-8' 4/12/2007

SB6 8-10' 4/12/2007

SB7 1-2' 4/12/2007

SB8 3-4' 4/12/2007

SB9 1-2' 4/12/2007

SS1 0-6" 4/12/2007

SS2 0-5" 4/12/2007

SS2 DUP 0-5" 4/12/2007

SS3 0-6" 4/12/2007

SS4 0-8" 4/12/2007

SS5 0-8" 4/12/2007

SS6 0-8" 4/12/2007

SS7 0-5" 4/12/2007

SS8 0-6" 4/12/2007

SS9 0-9" 4/12/2007

SS10 0-5" 4/12/2007

C UST 6' 10/5/2009

N UST 8' 10/6/2009

S UST 8' 10/6/2009

Particulate Soil Inhalation Criteria (XVIII)

SOIL: Part 201/213 Generic Residential & Commercial I Cleanup CriteriaRevised January 23, 2006

Units: ug/Kg

Drinking Water Protection Criteria (XI)

Infinite Source Volatile Soil Inhalation Criteria (XV) Finite Source Source Volatile Soil Inhalation Criteria (5 m) (XVI)

Soil Saturation Concentration Screening Levels (Csat) (XX)

Statewide Default Background Levels (X)

Groundwater Contact Protection Criteria (XIII)

Direct Contact Criteria (XIX)

Groundwater/Surface Water Interface Protection Criteria (XII)

Soil Volatilization to Indoor Air Inhalation (XIV)

Finite Source Source Volatile Soil Inhalation Criteria (2 m) (XVII)

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