Attachment Three.Summary Report of Supplemental Site Investigation.pdf

May 3, 2022 Project #18687

Mr. Lee Delcore Hydrogeologist – Remediation and Redevelopment Program Wisconsin Department of Natural Resources 1155 Pilgrim Rd, PO Box 408 Plymouth, WI 53073-0408

RE: Summary Report of Supplemental Site Investigation – PZ-03 Area Moss American Superfund Site

8716 N. Granville Rd., Milwaukee, WI

BRRTS # 02-41-529585; FID # 241378280

Dear Mr. Delcore:

The Sigma Group, Inc. (Sigma) has prepared this report to document additional environmental investigation activities completed in the area of monitoring well PZ-03 at the Former Moss-American Facility located at 8716 N. Granville Road in Milwaukee, Wisconsin (hereinafter referred to as the “site”, refer to Figure 1). The activities were performed to further evaluate the relatively high groundwater impacts and free product identified in the vicinity of this well during post-remediation quarterly groundwater monitoring and the additional site investigation activities performed in 2021. The additional investigation activities were completed as described in the Scope of Work1 submitted to the Wisconsin Department of Natural Resources (WDNR) on May 5, 2021.

BACKGROUND

The additional site investigation was warranted based on the results of the post-remediation groundwater monitoring conducted beginning in October 2019 and additional site investigation activities performed in 2021. Review of the quarterly groundwater monitoring data indicate that the contaminant concentrations within most of the monitoring wells are less than the laboratory limits of detection (LODs) or levels less than the Wisconsin Administrative Code (WAC) Chapter (ch.) NR 140 Enforcement Standards (ESs) or Preventive Action Limits (PALs). However, concentrations of naphthalene (a fingerprint constituent of creosote which was historically used at the site) were detected within samples from three monitoring wells (MW-33S, PZ-02, and PZ-03) at relatively high concentrations. Specifically, concentrations of naphthalene within monitoring well PZ-03 have been found to exceed the ch. NR 140 ES by a factor of 40 on several occasions. Concentrations of naphthalene within monitoring wells MW-33S and PZ-02 have also increased on several occasions and exceeded both the ch. NR 140 PAL and ES by a factor of two. The relatively high concentration of naphthalene in groundwater is an indication of the likely presence of creosote mass (free phase product) in the vicinity of these wells. In order to evaluate if free phase product was still present in the vicinity of these wells, additional investigation activities were performed in March 2021.

The additional site investigation activities included the advancement of 26 soil borings (GP-100 thru GP-

125) including the collection and laboratory analysis of 39 soil samples for benzene, toluene, 1 Scope of Work for Supplemental Site Investigation- PZ-03 Area, Former Moss-American Facility, 8716 N.

Granville Rd., Milwaukee, WI, FID # 241378280 by Sigma (dated May 5, 2021).

Wisconsin Department of Natural Resources Moss-American Superfund Site May 3, 2022

I:\Wisconsin Dept of Natural Resources\18687 - Moss-American Closure\090 Reports\2022.04_PZ-03 Area Investigation\Working Docs\2022.04_PZ-03 Area Investigation_18687.docx ethylbenzene, and xylenes (BTEX), and polycyclic aromatic hydrocarbons (PAHs), the installation of ten monitoring wells (PZ-03A thru PZ-03E, MW-33SA thru MW-33SC, PZ-02A, and PZ-02B), development of the new monitoring wells, and the collection of one round of groundwater samples from the new monitoring well network for laboratory analysis of BTEX and PAHs. The additional investigation activities were described in more detail in the Summary Report2 submitted to the WDNR on May 5, 2021.

Results of the investigation in the vicinity of monitoring wells MW-33S and PZ-02 indicated groundwater contamination was limited in extent and that no free product was observed in the vicinity of these wells.

Naphthalene impacts within soil were limited to four locations at concentrations slightly higher than the

ch. NR 720 groundwater pathway Residual Contaminant Level (RCL). Detection of naphthalene impacts within groundwater were present at concentrations greater than the ch. NR 140 PAL and ES.

In contrast, results of the investigation in the vicinity of monitoring well PZ-03 indicated high concentrations of naphthalene in both soil and groundwater samples, and free phase product was observed at several boring locations. Elevated naphthalene impacts were identified in the approximate depth interval of 7.5 to 13 feet below ground surface (bgs) and the data correlated well with the presence of free product observed in the field; however, the lateral extent of this free product was not defined.

Sigma recommended the completion of supplemental site investigation activities to further define the degree and extent of subsurface soil and groundwater naphthalene impacts in the area and the lateral extent of free product.

INVESTIGATION ACTIVITIES

Soil Boring Installation – On January 20-21, 2022, a total of nine direct push soil borings were advanced with a track-mounted Geoprobe® hydraulic drill rig in the vicinity of monitoring well PZ-03, as shown on Figure 2. Initially eight soil borings were planned, but due to the presence of free product, an additional soil boring was completed in an attempt to define the extent of the free product area. Each soil boring was completed to a depth of approximately 15 feet bgs where a relatively tight clay layer was encountered. At each location the soil borings were sampled continuously, screened in the field for volatile vapors with a calibrated photo-ionization detector (PID) and visually inspected for oily sheen or free phase product.

Sample Collection – Soil samples were collected with a hydraulically driven 2.5-inch diameter by five-foot long MacroCore® sampler and described on the basis of color, texture, grain size, plasticity, presence of free product or oily sheen, and logged in general accordance with the Unified Soil Classification System (USCS). Samples were screened in the field with a calibrated PID to measure for the presence of volatile organic vapors. Soil classifications, descriptions, specific sampling intervals, and PID readings are presented on the soil boring logs (WDNR Form 4400-122) included in Attachment 1.

A total of 16 soil samples (two samples per boring with the exception of soil boring SGP-127) were containerized and submitted for laboratory analysis of BTEX and PAHs. Soil boring SGP-127 was not sampled due to the presence of free product. Soil boring SGP-128 was added to the south of SGP-127 and sampled to delineate the horizontal extent of free product. Additionally, the deeper sample from

2 Summary Report of Additional Site Investigation, Former Moss-American Facility, 8716 N. Granville Rd., Milwaukee, WI, FID # 241378280 by Sigma (dated May 5, 2021).

I:\Wisconsin Dept of Natural Resources\18687 - Moss-American Closure\090 Reports\2022.04_PZ-03 Area Investigation\Working each soil boring was also submitted for laboratory analysis of diesel range organics (DRO) and gasoline range organics (GRO) to ensure all petroleum derived constituents are evaluated. Soil samples were placed in laboratory-supplied containers (BTEX and GRO samples were preserved with methanol; PAH and DRO samples do not require field preservation) and transported in coolers with ice to the project laboratory with a completed chain of custody (COC) document. For quality assurance / quality control (QA/QC) purposes, one methanol blank was transported with the cooler of soil samples and analyzed for BTEX to determine if volatile organic compound (VOC) contaminants infiltrated the samples during transportation.

Following advancement of the soil borings, and completion of sampling, the soil borings not selected for installation of monitoring wells were abandoned with hydrated bentonite chips to ground surface in accordance with ch. NR 141. The soil boring abandonment forms are included in Attachment 2.

Monitoring Well Installation – Three ch. NR 141-compliant monitoring wells PZ-03F, PZ-03G, and PZ-03H were installed in the vicinity of monitoring well PZ-03. The locations of the new monitoring wells were positioned based on the presence of free product encountered in the soil borings, other indications of impacts such as odor, PID screening data, and to complete the lateral delineation within the investigation area. Following completion of the Geoprobe soil borings, hollow stem augers (4 ¼-inch inside diameter with 8 ¼-inch outside diameter) were used to over drill the Geoprobe soil borings to a depth of approximately 15 feet bgs. Each monitoring well was constructed with a 10-foot length of two-inch diameter PVC screen (0.010-inch machine slotted) connected to an appropriate length of two-inch diameter PVC riser pipe. Each monitoring well was protected with a stickup steel protective casing. The monitoring well construction details are documented on WDNR form 4400-113A and included in Attachment 3.

Monitoring Well Development – The new monitoring wells were developed on January 31, 2022, in accordance with ch. NR 141 regulations to remove fine sediment from the bottom of the well casing and establish a hydraulic connection with the saturated soils surrounding the well screen. The well development activities are documented on the WDNR forms presented in Attachment 4.

Groundwater Sampling – The three new groundwater monitoring wells as well as the six existing wells in the vicinity of the PZ-03 monitoring well were sampled on February 1-2, 2022, for field parameters including water level, dissolved oxygen, oxidation-reduction (redox) potential, pH, temperature, turbidity, and specific conductance using a Solinst Water Level Indicator, a YSI Professional Plus Multiparameter meter, and a Hach 2100Q portable turbidimeter. The groundwater monitoring wells were then purged using disposable bailers (two-inch diameter wells) or a peristaltic pump (one-inch diameter well). Following the existing project protocols recommended in the October 2019 Quarterly Monitoring Report, each groundwater monitoring well was sampled approximately 24 hours after purging in order to minimize the possibility of drawing fine sediments into the samples. Samples were collected with disposable bailers at each well and the samples were submitted for laboratory analysis of BTEX (Environmental Protection Agency [EPA] Method 8260B), and PAHs (EPA Method M8270C).

QA/QC samples included one duplicate sample collected at monitoring well PZ-03F and one equipment blank.

Survey – The soil boring and monitoring well locations and elevations were surveyed on January 21 and February 2, 2022, with a Trimble® R8 GPS unit. The elevation data was referenced to a local United Stated Geological Survey (USGS) datum in feet above mean sea level (MSL).

I:\Wisconsin Dept of Natural Resources\18687 - Moss-American Closure\090 Reports\2022.04_PZ-03 Area Investigation\Working

Investigative Waste Disposal – Four drums of soil investigative waste and 17 drums of groundwater investigative waste generated during the investigation activities were staged on site and picked up by Veolia, Inc. under the existing project contract on February 11, 2022, for disposal as hazardous waste.

The investigative waste manifests are included in Attachment 5.

INVESTIGATION RESULTS

The following discussions of geology, hydrogeology, soil quality, and groundwater quality are based on the results of the additional investigation.

Geology – The soil conditions encountered during the investigation were consistent with historically reported soil conditions. Generally, the site surface consists of a layer of topsoil and / or gravelly clay ranging in depths of approximately three to six feet bgs. The remainder of the investigated depth ranged widely from silty clay to well graded sand. Traces of free phase product were observed in soil borings installed in the vicinity of monitoring well PZ-03 and at depths ranging from six to 10 feet bgs in soil borings GP-127 and GP-134. Soil classifications, descriptions, specific sampling intervals, and PID readings are presented on the soil boring logs (WNDR Form 4400-122) included in Attachment 1. A geologic cross section location map is included as Figure 3 and geologic cross sections A-A’ and B-B’ are included as Figure 4 and Figure 5, respectively.

Hydrogeology – Static water level elevations measured on February 1, 2022, ranged from 718.10 to

718.29 feet MSL in the vicinity of monitoring well PZ-03. The depth to groundwater ranged from 2.0 to

3.2 feet bgs in the vicinity of monitoring well PZ-03. The water level elevations are summarized in Table 1.

Free Product – The soil borings advanced in the vicinity of PZ-03 were inspected for visual signs of free product during soil boring advancement and sampling. Of the nine soil borings advanced in January 2022, free phase product was identified in soil borings GP-127 (from six to nine feet bgs) and GP-134 (from 9.75 to 10 feet bgs). Free product indicators including staining and petroleum odors were also noted in soil boring GP-130; however, no free phase product was observed. The vertical extent of free product is shown on the geologic cross sections included as Figure 4 and Figure 5 and the aerial extent of free product is shown on the soil quality map and groundwater quality map included as Figure 6 and Figure 7, respectively. Photographs of soil samples including select soil samples with observed free product are included in Attachment 6.

The thickness of free product was measured on April 1, 2022, within the monitoring wells located near the monitoring well PZ-03. Free phase product was identified at the bottom of the water column in only one of the monitoring wells (PZ-03E) and strong petroleum odors were noted in monitoring well PZ-03H.

No other obvious signs of free product were identified within the other sampled monitoring wells.

Groundwater In-Situ Measurements – Groundwater in-situ measurements including dissolved oxygen, oxidation-reduction potential (redox), pH, electrical conductivity, temperature, and turbidity were collected from all nine monitoring wells sampled in February 2022. The in-situ readings are summarized in Table 2.

Soil Quality Results – A total of 16 soil samples were submitted for laboratory analysis of BTEX and PAHs and eight soil samples were submitted for laboratory analysis of DRO and GRO. The analytical results are summarized in Table 3, and the soil analytical report is included in Attachment 7. The results are

I:\Wisconsin Dept of Natural Resources\18687 - Moss-American Closure\090 Reports\2022.04_PZ-03 Area Investigation\Working compared to ch. NR 720 RCLs for the groundwater pathway, non-industrial direct contact, and industrial direct contact. The soil quality results for the new soil borings advanced in the vicinity of monitoring well PZ-03 are summarized in Figure 6 and discussed below.

• BTEX: No BTEX compounds were detected within 14 of the 16 soil samples collected from PZ-03 area soil borings. The remaining two soil samples contained concentrations of toluene, ethylbenzene, and xylenes less than ch. NR 720 RCLs.

• PAHs: Select PAH compounds were reported in all but one of the 16 soil samples analyzed.

Several PAH compounds were detected at moderate to high concentrations within five of the remaining 15 soil samples collected from the PZ-03 area. Of the detected PAH compounds, naphthalene was present within five of the 15 samples with the detected concentrations ranging from less than 1 milligram per kilogram (mg/kg) to 21.4 mg/kg. A positive correlation between the presence of free product observed during field screening and high naphthalene concentrations in soil samples is also evident.

Groundwater Quality Results – As part of the supplemental site investigation activities, one round of groundwater samples was collected from the three newly installed groundwater monitoring wells and the existing PZ-03 area monitoring wells and submitted for laboratory analysis of BTEX and PAHs. The results are summarized in Table 4 and in Figure 7, and the groundwater laboratory analytical report is included in Attachment 8. The analytical results for BTEX were compared to ESs and PALs in both ch.

NR 140 and the EPA Record of Decision (ROD) for the site are discussed below.

• BTEX: Benzene was detected at concentrations greater than its EPA ROD and ch. NR 140 ES within monitoring well PZ-03E. Benzene was detected at a concentration greater than its EPA ROD PAL and less than its ch. NR 140 PAL within monitoring well PZ-03H. Benzene was not detected within the remaining monitoring wells. Ethylbenzene, toluene, and xylenes were detected in select monitoring wells but at concentrations less than their respective ROD and ch.

NR 140 PALs.

• PAHs: Several PAH compounds were detected within each of the groundwater samples collected from the monitoring wells at concentrations greater than laboratory limits of detection (LODs).

Select PAHs were reported at concentrations above ch. NR 140 ESs and / or PALs within seven of the nine monitoring wells sampled. Naphthalene was reported at concentrations above its

ch. NR 140 ES within monitoring wells PZ-03B, PZ-03D, PZ-03E, and PZ-03H. The detected concentrations of naphthalene range between 0.193 µg/L and 3,500 µg/L. The highest concentration of naphthalene (3,500 micrograms per liter [ug/L]) was detected at PZ-03E where free product was also identified. Similarly, relatively high concentrations were detected at PZ- 03H (900 ug/L) where the presence of free product was observed in soil samples. The groundwater quality data appears to correlate well with soil quality data and free product observations.

SUMMARY AND CONCLUSIONS

In 2021 and 2022, a total of 35 soil borings (GP-100 thru GP-134) were advanced and a total of 13 monitoring wells (PZ-03A thru PZ-03H, MW-33SA thru MW-33SC, PZ-02A, and PZ-02B) were installed in the vicinity of MW-33S, PZ-02, and PZ-03 to investigate the source and extent of elevated naphthalene impacts identified in groundwater samples collected from MW-33S, PZ-02, and PZ-03. A total of 70 soil

I:\Wisconsin Dept of Natural Resources\18687 - Moss-American Closure\090 Reports\2022.04_PZ-03 Area Investigation\Working samples were collected and submitted from the soil borings for laboratory analysis of BTEX and PAHs while one to two rounds of groundwater samples were collected from the newly installed monitoring wells and submitted for laboratory analysis of BTEX and PAHs. The following sections present a summary of the investigation results:

MW-33S and PZ-02

• Results of the investigation in the vicinity of monitoring wells MW-33S and PZ-02 indicate groundwater impacts are limited in extent and that no free product was observed.

• Naphthalene impacts within soil are limited to four locations at concentrations slightly higher than the ch. NR 720 groundwater pathway RCL.

• Although naphthalene impacts within groundwater were identified at concentrations greater than the ch. NR 140 PAL and ES in the vicinity of monitoring wells MW-33S and PZ-02, the detected concentrations do not indicate the presence of free phase creosote in the subsurface.

PZ-03 Area

• Results of the additional site investigation activities conducted in the vicinity of PZ-03 identified two zones of relatively high naphthalene impacted soil which roughly correlate with two areas of free phase product identified in the soil (Figure 4, Figure 5, and Figure 6).

• One of the free product areas is located to the west and south of PZ-03 and includes soil borings GP-104, GP-106, GP-107, GP-111, GP-113, GP-114, and GP-127.

• The second area is located to the northwest of PZ-03 and includes soil boring GP-134.

• Detection of naphthalene within soil in the southern area are greater than other areas evaluated with the highest concentration of 1,230 mg/kg and free product at depths of six to 13 feet bgs.

• The greatest naphthalene concentration in the northern investigation area was 21.4 mg/kg and free product was only present at depths of 9.75 to 10 feet bgs.

• Review of the groundwater quality data collected at monitoring well PZ-03 since 2013 confirms the presence of relatively high concentrations of naphthalene in the subsurface at this location.

• Although the latest sampling data indicates a decrease in naphthalene concentration from 4,000 µg/L to less than 10 µg/L, the results are not likely a true representation of the subsurface condition within monitoring well PZ-03. Considering free phase creosote product is heavier than water and accumulates at the bottom of the well, i is suspected that groundwater samples typically collected from the mid-screen depth (typical procedure for groundwater monitoring) may not have captured the product, if present in the well.

• In the most recent rounds of groundwater sampling, naphthalene concentrations within monitoring wells PZ-03B, PZ-03D, PZ-03E, and PZ-03H were greater than in PZ-03 with the highest concentration (4,100 µg/L) reported in PZ-03E.

• Relatively high groundwater naphthalene concentrations correlate well with high soil quality impacts as well as the presence of free product.

• The degree and extent of groundwater naphthalene impacts in the vicinity of monitoring well PZ-03 is well defined in all directions as presented in Figure 7.

In conclusion, based on a review of the historical groundwater quality data and the recently collected soil data, the presence of free product in the subsurface appears to be limited to two isolated areas:

• In the vicinity of monitoring well PZ-03H as documented in the soil sample and strong petroleum odor observed during groundwater sampling.

I:\Wisconsin Dept of Natural Resources\18687 - Moss-American Closure\090 Reports\2022.04_PZ-03 Area Investigation\Working

• Measurable free product at PZ-03E and relatively high concentrations of naphthalene in groundwater samples.

Due to the high concentrations of naphthalene identified in the vicinity of monitoring well PZ-03 and the presence of free product was observed, active remedial measures would be required to meet the conditions of the EPA ROD. A Remedial Action Options Matrix is prepared and included as Table 5.

Pending your review, the information included in the report and the potential remedial options discussed in the attached options matrix (Table 5) please give us a call to discuss the investigation results and potential remedial options to address the limited free product are at the site.

Sincerely, THE SIGMA GROUP, INC.

Steven Kikkert, P.E. Mafizul Islam, P.E.

Staff Engineer Senior Project Manager

Enclosures:

Table 1 – Water Level Elevations Table 2 – Groundwater In-Situ Measurements Table 3 – Soil Analytical Results Table 4 – Groundwater Analytical Results Table 5 – Remedial Action Options Matrix

Figure 1 – Site Location Map Figure 2 – Borehole Location Map Figure 3 – Geologic Cross Section Location Map Figure 4 – Geologic Cross Section A-A’ Figure 5 – Geologic Cross Section B-B’ Figure 6 – Soil Quality Map Figure 7 – Groundwater Quality Map

Attachment 1 – Soil Boring Logs Attachment 2 – Borehole Abandonment Forms Attachment 3 – Groundwater Monitoring Well Construction Forms Attachment 4 – Monitoring Well Development Forms Attachment 5 – Investigative Waste Disposal Manifests Attachment 6 – Free Product Photographs Attachment 7 – Soil Laboratory Analytical Report Attachment 8 – Groundwater Laboratory Analytical Report

TABLES

Table 1 Water Level Elevations - PZ-03 Area Investigation

Moss American - 8716 N. Granville Road, Milwaukee, Wisconsin Sigma Project No. 18687

PZ-03

Ground Elev.: 719.1 (feet MSL) Screen Interval: 1.4 to 11.4 (feet bgs) TOC Elev.: 722.50 (feet MSL) 717.6 to 707.6 (feet MSL)

Date Depth to

Groundwater Well Depth

Water Column

Water Column Difference

Groundwater Elevation

Depth to Groundwater

Physical Observations

(feet TOC) (feet TOC) (feet) (feet) (feet MSL) (feet bgs)

4/4/13 4.60 14.85 10.25 --- 717.90 1.2

10/8/19 4.65 14.61 9.96 0.05 717.85 1.2 Good recovery.

1/8/20 4.57 14.61 10.04 -0.08 717.93 1.2 Duplicate #2

3/31/20 4.54 14.60 10.06 -0.03 717.96 1.1 Good recovery, dup #2.

7/13/20 5.88 14.68 8.80 1.34 716.62 2.5 Good recovery, dup #4.

10/8/20 5.72 14.66 8.94 -0.16 716.78 2.3 Good recovery, dup #4.

1/8/21 4.99 14.65 9.66 -0.73 717.51 1.6 Good recovery.

4/1/21 4.48 14.65 10.17 -0.51 718.02 1.1 Good recovery.

2/1/22 6.31 14.94 8.63 1.83 716.19 2.9 Good recovery.

PZ-03A

Ground Elev.: 718.7 (feet MSL) Screen Interval: 5.2 to 15.2 (feet bgs) TOC Elev.: 721.26 (feet MSL) 713.5 to 703.5 (feet MSL)

Date Depth to

Groundwater Well Depth

Water Column

Water Column Difference

Groundwater Elevation

Depth to Groundwater

Physical Observations

(feet TOC) (feet TOC) (feet) (feet) (feet MSL) (feet bgs) 3/9/21 2.65 17.74 15.09 --- 718.61 0.1 Well development.

3/11/21 2.81 17.74 14.93 0.16 718.45 0.2 Good recovery, no odor 2/1/22 5.03 17.60 12.57 2.22 716.23 2.4 Turbid, petroleum odor, good recovery.

PZ-03B

Ground Elev.: 719.2 (feet MSL) Screen Interval: 5.1 to 15.1 (feet bgs) TOC Elev.: 721.90 (feet MSL) 714.1 to 704.1 (feet MSL)

Date Depth to

Groundwater Well Depth

Water Column

Water Column Difference

Groundwater Elevation

Depth to Groundwater

Physical Observations

(feet TOC) (feet TOC) (feet) (feet) (feet MSL) (feet bgs) 3/9/21 3.22 17.84 14.62 --- 718.68 0.5 Well development.

3/11/21 3.41 17.84 14.43 0.19 718.49 0.7 Good recovery, no odor 2/1/22 5.65 17.83 12.18 2.24 716.25 2.9 Turbid, petroleum odor, good recovery.

PZ-03C

Ground Elev.: 719.2 (feet MSL) Screen Interval: 4.7 to 14.7 (feet bgs) TOC Elev.: 721.75 (feet MSL) 714.5 to 704.5 (feet MSL)

Date Depth to

Groundwater Well Depth

Water Column

Water Column Difference

Groundwater Elevation

Depth to Groundwater

Physical Observations

(feet TOC) (feet TOC) (feet) (feet) (feet MSL) (feet bgs) 3/8/21 3.05 17.26 14.21 --- 718.70 0.5 Well development.

3/11/21 3.18 17.26 14.08 0.13 718.57 0.7 Good recovery, no odor 2/1/22 5.47 17.28 11.81 2.29 716.28 2.9 Turbid, petroleum odor, good recovery.

PZ-03D

Ground Elev.: 719.0 (feet MSL) Screen Interval: 5.0 to 15.0 (feet bgs) TOC Elev.: 721.37 (feet MSL) 714.0 to 704.0 (feet MSL)

Date Depth to

Groundwater Well Depth

Water Column

Water Column Difference

Groundwater Elevation

Depth to Groundwater

Physical Observations

(feet TOC) (feet TOC) (feet) (feet) (feet MSL) (feet bgs) 3/8/21 2.58 17.38 14.80 --- 718.79 0.2 Well development.

3/11/21 2.74 17.38 14.64 0.16 718.63 0.3 Good recovery, petroleum odor 2/1/22 5.08 17.41 12.33 2.34 716.29 2.7 Good recovery.

PZ-03E

Ground Elev.: 719.0 (feet MSL) Screen Interval: 4.7 to 14.7 (feet bgs) TOC Elev.: 721.27 (feet MSL) 714.3 to 704.3 (feet MSL)

Date Depth to

Groundwater Well Depth

Water Column

Water Column Difference

Groundwater Elevation

Depth to Groundwater

Physical Observations

(feet TOC) (feet TOC) (feet) (feet) (feet MSL) (feet bgs) 3/9/21 2.62 16.95 14.33 --- 718.65 0.4 Well development.

3/11/21 2.81 16.95 14.14 0.19 718.46 0.6 Good recovery, petroleum odor 2/1/22 5.06 17.29 12.23 2.25 716.21 2.8 Product presence, good recovery.

PZ-03F

Ground Elev.: 718.4 (feet MSL) Screen Interval: 5.5 to 15.5 (feet bgs) TOC Elev.: 720.69 (feet MSL) 712.9 to 702.9 (feet MSL)

Date Depth to

Groundwater Well Depth

Water Column

Water Column Difference

Groundwater Elevation

Depth to Groundwater

Physical Observations

(feet TOC) (feet TOC) (feet) (feet) (feet MSL) (feet bgs) 1/21/22 4.49 17.82 13.33 --- 716.20 2.1 Well installation.

1/31/22 4.59 17.63 13.04 0.10 716.10 2.2 Well development.

2/1/22 4.41 17.38 12.97 -0.18 716.28 2.1 Good recovery.

PZ-03G

Ground Elev.: 718.2 (feet MSL) Screen Interval: 5.5 to 15.5 (feet bgs) TOC Elev.: 720.53 (feet MSL) 712.7 to 702.7 (feet MSL)

Date Depth to

Groundwater Well Depth

Water Column

Water Column Difference

Groundwater Elevation

Depth to Groundwater

Physical Observations

(feet TOC) (feet TOC) (feet) (feet) (feet MSL) (feet bgs) 1/21/22 4.11 17.84 13.73 --- 716.42 1.8 Well installation.

1/31/22 4.41 17.75 13.34 0.30 716.12 2.1 Well development.

2/1/22 4.28 17.79 13.51 -0.13 716.25 2.0 Good recovery.

PZ-03H

Ground Elev.: 719.3 (feet MSL) Screen Interval: 5.5 to 15.5 (feet bgs) TOC Elev.: 721.60 (feet MSL) 713.8 to 703.8 (feet MSL)

Date Depth to

Groundwater Well Depth

Water Column

Water Column Difference

Groundwater Elevation

Depth to Groundwater

Physical Observations

(feet TOC) (feet TOC) (feet) (feet) (feet MSL) (feet bgs) 1/21/22 5.43 17.79 12.36 --- 716.17 3.1 Well installation.

1/31/22 5.63 17.63 12.00 0.20 715.97 3.3 Well development.

2/1/22 5.50 17.55 12.05 -0.13 716.10 3.2 Good recovery, petroleum odor.

Notes:

2. feet MSL = feet above Mean Sea Level

3. feet bgs = feet below ground surface Data entered / updated by: SVK Date: 3/17/2022

4. feet TOC = feet below top of casing Data checked by: DBC Date: 3/20/2022

1. All montioring wells surveyed by The Sigma Group, Inc. on March 2 & 3, 2021 with Trimble GPS receiver.

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Table 2 Groundwater In Situ Measurements

Moss American - 8716 N. Granville Road, Milwaukee, Wisconsin Sigma Project No. 18687

Dissolved Redox Specific Ferrous Oxygen (mg/L)

Potential (mV) pH (S.U.)

Conductivity (mS/cm)

Temperature (°C)

Turbidity

(NTU)

Conductance (mmhos/cm)

Iron (mg/L)

PZ-03 9/29/10 NS NS NS NS NS NS NS NS

4/4/13 0.95 -20.0 7.20 NS 6.8 NA NA 4.0

10/8/19 2.84 342.6 6.93 1.70 16.5 172.0 2.028 3.4 1/8/20 0.86 117.6 7.00 0.99 6.8 86.7 1.518 2.4 3/31/20 3.20 252.7 7.16 0.46 5.0 66.0 0.746 2.4 7/13/20 2.25 135.2 7.18 1.04 16.1 77.9 1.253 4.8 10/8/20 0.15 -176.1 6.93 1.04 16.5 14.9 1.242 1.4 1/8/21 0.38 -132.3 7.44 0.61 5.3 33.3 0.978 1.0 4/1/21 0.53 92.6 7.53 0.61 8.2 18.9 0.898 3.6 2/2/22 0.37 -90.4 7.16 0.65 3.7 9.5 1.10 0.0

PZ-03A 3/11/21 1.68 157.7 6.92 0.69 7.0 too turbid 1.052 0.0

2/2/22 0.70 -83.2 7.30 0.58 4.1 41.7 0.965 NA

PZ-03B 3/11/21 1.38 173.8 6.93 0.71 7.1 too turbid 1.079 0.8

2/2/22 1.23 -95.6 7.46 0.65 4.4 62.6 1.072 NA

PZ-03C 3/11/21 0.98 157.5 6.93 0.79 8.3 too turbid 1.160 0.8

2/2/22 0.46 -55.7 6.95 0.76 7.3 91.2 1.148 NA

PZ-03D 3/11/21 1.22 139.2 6.87 0.75 9.0 too turbid 1.080 1.2

2/2/22 0.65 -35.9 7.00 0.69 7.1 12.0 1.048 NA

PZ-03E 3/11/21 1.33 137.7 7.03 0.64 7.3 too turbid 0.967 0.0

2/2/22 NA NA NA NA NA NA NA NA

PZ-03F 2/2/22 0.49 -40.9 7.19 0.59 4.0 13.8 0.985 NA

PZ-03G 2/2/22 0.88 -55.2 7.18 0.63 4.0 12.8 1.052 NA

PZ-03H 2/2/22 NA NA NA NA NA 20.6 NA 0.0

Notes:

1. ° C = degrees Celcius

2. mg/L = milligrams per liter (equivalent to parts per million, ppm)

3. mV = millivolts Data entered / updated by: SVK Date: 2/11/2022

4. NA = not analyzed Data checked by: DBC Date: 3/2/2022

Well Identification

Date

In Situ Measurements

Page 1 of 1 I:\Wisconsin Dept of Natural Resources\18687 - Moss-American Closure\095 Data\18687_Groundwater Data Table

Table 3 Soil Analytical Results - PZ-03 Area Investigation

Moss American - 8716 N. Granville Road, Milwaukee, Wisconsin Sigma Project No. 18687

Soil Sample Location:

Monitoring Well (if applicable):

Sample Collection Date:

Sample Depth (feet bgs): 2-4 10-12 2-4 6-8 8-10 12-14 8-10 10-12 2-4 8-10 0-2 10-12 4-6 10-12 4-6 10-12

Depth to Groundwater (feet bgs):

Free Product : -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- FP Unsat (U) or Saturated (S): S S S S S S S S S S S S S S S S

Photoionization Detector ppm 1.5 0.5 0.6 1.1 2.9 2.0 1.8 2.0 2.5 1.8 7.4 2.3 1.4 1.6 2.2 13.0 NS NS NS

Gasoline Range Organics mg/kg NA <10 NA <10 NA 15.1 NA <10 NA <10 NA NA NA <10 NA NA NS NS NS

Diesel Range Organics mg/kg NA <10 NA <10 NA <10 NA <10 NA <10 NA NA NA <10 NA NA NS NS NS

VOCs Benzene mg/kg <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 0.0051 1.6 7.07 Ethylbenzene mg/kg <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 0.044 J 1.57 8.02 35.4 Toluene mg/kg <0.025 <0.025 0.033 J <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 1.1072 818 818 Xylenes (total) mg/kg <0.075 <0.075 0.099 J <0.075 <0.075 <0.075 <0.075 <0.075 <0.075 <0.075 <0.075 <0.075 <0.075 <0.075 <0.075 0.047 J 3.96 260 260 PAHs

Acenaphthene mg/kg <0.011 <0.011 1.58 0.088 <0.011 4.60 <0.011 0.048 <0.011 2.02 <0.011 0.0232 J <0.011 <0.011 0.34 33.0 NS 3,590 45,200 Acenaphthylene mg/kg 0.0303 J <0.009 19.2 0.09 <0.009 0.05 J 0.0097 J <0.009 0.0189 J 0.052 <0.009 <0.009 <0.009 <0.009 0.131 0.34 J NS NS NS Anthracene mg/kg 0.05 0.0241 J 49.0 0.044 <0.0071 1.55 0.0196 J 0.0116 J 0.04 0.52 0.0081 J 0.0124 J <0.0071 0.0123 J 0.295 8.80 196.9492 17,900 100,000 Benzo(a)anthracene mg/kg 0.0243 J 0.0305 J [ 10.2 ] <0.0139 <0.0139 0.69 0.047 J 0.0261 J 0.043 J 0.55 <0.0139 0.053 J <0.0139 0.0263 J 0.132 [ 4.70 ] NS 1.14 20.8 Benzo(a)pyrene mg/kg 0.043 J 0.0258 J {[ 33.0 ]} 0.045 J <0.0143 [ 0.213 ] 0.036 J <0.0143 0.035 J [ 0.33 ] <0.0143 0.0195 J <0.0143 0.0155 J [ 0.70 ] [ 1.26 ] 0.47 0.115 2.11 Benzo(b)fluoranthene mg/kg 0.067 0.047 {[ 44.0 ]} 0.0081 J <0.008 0.34 0.056 0.0212 J 0.069 0.50 0.0142 J 0.035 <0.008 0.0228 J 0.51 [ 2.00 ] 0.4781 1.15 21.1 Benzo(ghi)perylene mg/kg 0.057 0.0174 J 78.0 0.036 J <0.0125 0.071 J 0.04 J <0.0125 0.076 0.205 0.0146 J <0.0125 <0.0125 0.018 J 0.71 0.38 J NS NS NS Benzo(k)fluoranthene mg/kg 0.027 J 0.0261 J 5.30 <0.0076 <0.0076 0.155 0.0197 J 0.0093 J 0.03 0.162 <0.0076 0.0154 J <0.0076 0.012 J 0.108 0.96 NS 11.5 211 Chrysene mg/kg 0.0303 J 0.058 8.40 <0.0124 <0.0124 0.73 0.049 J 0.02 J 0.059 0.56 <0.0124 0.055 <0.0124 0.0205 J 0.162 4.50 0.1442 115 2,110 Dibenzo(a,h)anthracene mg/kg <0.0136 <0.0136 {[ 12.0 ]} <0.0136 <0.0136 <0.0272 <0.0136 <0.0136 <0.0136 0.039 J <0.0136 <0.0136 <0.0136 <0.0136 [ 0.119 ] <0.272 NS 0.115 2.11 Fluoranthene mg/kg 0.064 0.146 23.3 0.0083 J 0.0198 J 4.40 0.171 0.091 0.081 3.13 0.0142 J 0.128 <0.008 0.062 0.35 32.0 88.8778 2,390 30,100 Fluorene mg/kg <0.0091 <0.0091 2.07 0.083 <0.0091 3.60 <0.0091 0.0275 J <0.0091 1.41 <0.0091 0.0176 J <0.0091 <0.0091 0.199 28.7 14.8299 2,390 30,100 Indeno(1,2,3-cd)pyrene mg/kg 0.06 0.0217 J {[ 91.0 ]} 0.034 J <0.0152 0.102 J 0.048 J <0.0152 0.073 0.262 <0.0152 <0.0152 <0.0152 0.0186 J 0.89 0.50 J NS 1.15 21.1 1-Methylnaphthalene mg/kg 0.0134 J <0.0118 1.13 0.0302 J <0.0118 1.39 <0.0118 <0.0118 <0.0118 0.031 J <0.0118 <0.0118 <0.0118 <0.0118 0.125 12.3 NS 17.6 72.7 2-Methylnaphthalene mg/kg <0.0186 <0.0186 2.29 <0.0186 <0.0186 2.55 <0.0186 <0.0186 <0.0186 0.0231 J <0.0186 <0.0186 <0.0186 <0.0186 0.192 14.2 NS 239 3,010 Naphthalene mg/kg <0.0201 <0.0201 [ 6.70 ] <0.0201 <0.0201 4.50 <0.0201 <0.0201 <0.0201 0.061 J <0.0201 <0.0201 <0.0201 <0.0201 0.86 [ 21.4 ] 0.6582 5.52 24.1 Phenanthrene mg/kg 0.042 0.0135 J 18.4 0.0303 J <0.0089 9.00 0.0151 J 0.0256 J 0.044 0.309 0.0107 J 0.033 J <0.0089 <0.0089 0.315 76.0 NS NS NS Pyrene mg/kg 0.055 0.115 19.5 0.0249 J 0.0256 J 3.00 0.131 0.073 0.083 2.15 0.0117 J 0.111 <0.007 0.067 0.299 21.6 54.5455 1,790 22,600 Notes:

1. Unsaturated/smear zone versus saturated soil conditions based on soil moisture conditions recorded on soil boring logs during drilling.

2. Analytical units: mg/kg = milligrams per kilogram (equivalent to parts per million, ppm)

3. NA = not analyzed NS = no standard established

7. Laboratory flags: "J" = Analyte detected between Limit of Detection and Limit of Quantitation

8. Methanol blank results: 03/01/2021: All VOCs reported below laboratory detection limits.

01/20/2022: All VOCs reported below laboratory detection limits.

9. Exceedances: BOLD = Concentration exceeds Groundwater Pathway RCL

[ ] = Concentration exceeds Non-Industrial Direct Contact RCL (any depth) { } = Concentration exceeds Industrial Direct Contact RCL (any depth) Data entered / updated by: SJB Date: 2/7/2022

10. "FP" indicated if free product was visually identified within soil samples Data checked by: SVK Date: 2/28/2022

6. Industrial Direct Contact RCL = Residual Contaminant Level for protection of direct contact at an industrial property as presented on the WDNR's RCL Spreadsheet (dated December 2018) with default input parameters as referenced in WDNR guidance document PUB-RR-890 "Soil Residual Contaminant Level Determinations Using the US EPA Regional Screening Level Web Calculator", dated June 2014.

5. Non-Industrial Direct Contact RCL = Residual Contaminant Level for protection of direct contact at a non-industrial property as presented on the WDNR's RCL Spreadsheet (dated December 2018) with default input parameters as referenced in WDNR guidance document PUB-RR-890 "Soil Residual Contaminant Level Determinations Using the US EPA Regional Screening Level Web Calculator", dated June 2014.

4. Groundwater Pathway RCL = Residual Contaminant Level for protection of groundwater (dilution factor of 2) as presented on the WDNR's RCL Spreadsheet (dated December 2018) referenced in WDNR guidance document PUB-RR-890 "Soil Residual Contaminant Level Determinations Using the US EPA Regional Screening Level Web Calculator", dated June 2014.

Non-Industrial Direct Contact

RCL 5

Industrial Direct Contact

RCL 6

Groundwater Pathway

RCL 4

PZ-03F-- -- -- --

GP-132 GP-133 GP-134

PZ-03HPZ-03G--

GP-126 GP-128 GP-129 GP-130 GP-131

1/20/22 1/20/22 1/20/22

0.7 0.7 0.7 0.7 0.7 0.7 0.7 0.7

1/20/22 1/20/22 1/20/22 1/20/22 1/20/22

Page 1 of 1 The Sigma Group, Inc. I:\Wisconsin Dept of Natural Resources\18687 - Moss-American Closure\095 Data\18687_Soil Data Table

Table 4 Groundwater Analytical Results - PZ-03 Area Investigation

Moss American - 8716 N. Granville Road, Milwaukee, Wisconsin Sigma Project No. 18687

Well Location: PZ-03G PZ-03H

Date: 4/4/13 10/9/19 1/8/21 4/2/21 2/2/22 3/12/21 2/2/22 3/12/21 2/2/22 3/12/21 2/2/22 2/2/22 3/12/21 2/2/22 2/2/22 2/2/22

Water Elevation* (feet MSL): 717.49* 717.64* 717.72* DUP #2 717.75* DUP #2 716.41 DUP #4 716.57 DUP #4 Synergy Pace 717.30 717.81* 716.19 718.26* 716.23* 718.32* 716.25* 718.42* 716.28* 718.45* DUP 716.29* 718.38* 716.21* 716.28* DUP 716.25* 716.10*

BTEX

Benzene µg/L [ 0.44 J ] {[ 2.02 ]} {[ 1.45 ]} {[ 1.38 ]} {[ 2.31 ]} {[ 2.27 ]} {[ 1.33 ]} {[ 1.14 ]} {[ 1.27 ]} {[ 1.11 ]} NA NA <0.33 <0.38 <0.38 <0.37 <0.38 {[ 0.95 J ]} <0.38 <0.37 <0.38 [ 0.43 J ] [ 0.55 J ] <0.38 {[ 1.68 ]} {[ 2.35 ]} <0.38 <0.38 <0.38 [ 0.44 J ] 0.67 0.067 5 0.5

Ethylbenzene µg/L 2.68 10.7 54 53 61 60 42 37 1.53 1.39 NA NA 0.8 J 0.75 J <0.37 <0.41 <0.37 7.4 <0.37 0.76 J <0.37 2.18 2.14 0.50 J 60 53 <0.37 <0.37 <0.37 4.4 1360.0 272.0 700 140

Toluene µg/L 1.92 J 34.1 68.9 68.3 86 84.5 56.5 48.9 20.4 19.7 NA NA 4.15 2.01 J <0.42 0.58 J <0.42 0.54 J <0.42 1.08 J <0.42 0.98 J 0.53 J <0.42 5.1 9.3 <0.42 <0.42 <0.42 <0.42 343.0 68.6 800 160

Xylenes, Total µg/L <0.8 1.01 1.36 1.37 2.09 2.21 1.2 1.27 0.47 J 0.61 J NA NA <0.26 <0.42 <1.21 <1.49 <1.21 19.1 4.74 J 2.87 J <1.21 5.91 5.61 1.69 J 85.8 93 <1.21 <1.21 <1.21 5.95 J 620.0 124.0 2,000 400

PAHs

Acenaphthene µg/L 116.0 154 350 NA 316 350 291 320 131 171 191 149 870 56 53.0 15.8 22.3 147 98.0 205 67.0 269 293 64.0 680 590 0.38 NA 0.25 314 NS NS NS NS

Acenaphthylene µg/L 0.99 J <4.68 <9.36 NA <31.2 <31.2 <15.6 <7.8 5.7 7.1 <7.8 1.2 J 0.81 J 0.61 0.52 J 0.11 0.13 J 0.92 J <0.78 1.19 J 0.71 3.30 J 4.50 J <3.12 <7.80 <7.80 0.039 J NA <0.0156 <3.12 NS NS NS NS

Anthracene µg/L 2.37 <4.5 <9 NA <30 <30 <15 <7.5 0.64 J <0.75 <7.5 <2.1 1.27 J 0.49 0.65 J 0.85 0.42 3.04 0.99 J 20.9 8.30 20.3 34 8.00 J 82.0 69.0 0.058 NA 0.041 J 16.6 NS NS 3,000 600

Benzo(a)anthracene µg/L 2.03 <3.93 <12 NA <40 <40 <20 <10 1.28 J <1 <10 <1.5 <1 <0.2 <0.40 0.245 0.172 J <1.00 <1.00 1.49 J 0.37 J <4.00 7.90 J <4.00 27.7 J 24.9 J 0.0289 J NA <0.02 <4.00 NS NS NS NS

Benzo(a)pyrene µg/L 0.71 J <5.01 <10.02 NA <33.4 <33.4 <16.7 <8.35 0.38 J <0.835 <8.35 <2.1 <0.835 <0.167 <0.334 0.082 J 0.171 J <0.835 <0.835 <0.835 <0.167 <3.34 4.00 J <3.34 <8.35 <8.35 <0.0167 NA <0.0167 <3.34 NS NS 0.2 0.02

Benzo(b)fluoranthene µg/L 1.45 <4.8 <9.6 NA <32 <32 <16 <8 1.22 <0.8 <8 <1.1 <0.8 <0.16 <0.32 0.134 0.16 J <0.80 <0.80 <0.80 <0.16 <3.20 6.90 J <3.20 10.9 J 8.90 J <0.016 NA <0.016 <3.20 NS NS 0.2 0.02

Benzo(ghi)perylene µg/L <0.46 <4.26 <8.52 NA <28.4 <28.4 <14.2 <7.1 0.49 J <0.71 <7.1 <1.4 <0.71 <0.142 <0.284 0.037 J 0.215 J <0.71 <0.71 <0.71 <0.142 <2.84 4.60 J <2.84 <7.10 <7.10 <0.0142 NA <0.0142 3.03 J NS NS NS NS

Benzo(k)fluoranthene µg/L <0.54 <4.38 <8.76 NA <29.2 <29.2 <14.6 <7.3 0.7 J <0.73 <7.3 <1.5 <0.73 <0.146 <0.292 0.047 J 0.152 J <0.73 <0.73 <0.73 <0.146 <2.92 6.80 J <2.92 <7.30 <7.30 <0.0146 NA <0.0146 <2.92 NS NS NS NS

Chrysene µg/L 1.47 <4.71 <9.42 NA <31.4 <31.4 <15.7 <7.85 0.85 J <0.785 <7.85 <2.6 <0.785 <0.157 <0.314 0.219 0.128 J <0.785 <0.785 1.18 J 0.34 J <3.14 10.1 <3.14 25.1 18.9 J 0.0229 J NA <0.0157 <3.14 NS NS 0.2 0.02

Dibenzo(a,h)anthracene µg/L <0.46 <5.19 <10.38 NA <34.6 <34.6 <17.3 <8.65 <0.346 <0.865 <8.65 <2 <0.865 <0.173 <0.346 <0.0346 0.178 J <0.865 <0.865 <0.865 <0.173 <3.46 <3.46 <3.46 <8.65 <8.65 <0.0173 NA <0.0173 <3.46 NS NS NS NS

Fluoranthene µg/L 10.7 <2.64 <5.28 NA <17.6 <17.6 <8.8 <4.4 1.64 <0.44 <4.4 <2.1 <0.44 0.43 0.53 J 2.03 0.47 6.90 1.58 20.5 8.80 21.6 49.0 9.30 188 147 0.26 NA 0.116 11.3 NS NS 400 80

Fluorene µg/L 33 57 110 NA 102 115 121 116 34 48 62 44.9 29.6 18.5 19.9 4.90 5.10 28.9 17.1 121 46.0 136 160 41.0 320 316 0.106 NA 0.065 156 NS NS 400 80

Indeno(1,2,3-cd)pyrene µg/L <0.54 <3.63 <7.26 NA <24.2 <24.2 <12.1 <6.05 0.48 J <0.605 <6.05 <3.5 <0.605 <0.121 <0.242 0.034 J 0.18 J <0.605 <0.605 <0.605 <0.121 <2.42 5.00 J <2.42 <6.05 <6.05 <0.0121 NA <0.0121 <2.42 NS NS NS NS

1-Methylnaphthalene µg/L NA NA NA NA NA NA NA NA NA NA NA NA NA NA 20.1 0.67 <9.55 28.4 45.0 110 24.5 158 175 29.2 380 350 0.084 NA 0.069 248 NS NS NS NS

2-Methylnaphthalene µg/L NA NA NA NA NA NA NA NA NA NA NA NA NA NA <0.372 <0.0372 <0.093 <0.93 <0.93 190 24.5 225 243 12.4 380 490 0.058 J NA 0.054 J 151 NS NS NS NS

Naphthalene µg/L 47.0 1620 4000 NA 3600 3800 3010 3150 4.9 9.4 1680 1310 360 13.3 4.30 0.90 <0.15 113 148 121 9.00 1090 1190 172 4100 3500 0.193 NA 0.212 990 NS NS 100 10

Phenanthrene µg/L 1.87 11 J 37 NA 45 J 51 J 43 J 44 3.7 0.9 J 19.3 J 12.8 J 6.6 2.7 2.77 1.98 0.313 5.60 1.68 J 157 63.0 158 218 58.0 560 490 0.033 J NA 0.036 J 138 NS NS NS NS

Pyrene µg/L 7.1 <3.63 <7.26 NA <24.2 <24.2 <12.1 <6.05 1.9 <0.605 <6.05 <1.5 <0.605 0.277 J 0.4 J 1.33 0.32 4.00 0.95 J 12.4 5.10 12.5 32.0 5.40 J 128 99.0 0.191 NA 0.096 6.20 J NS NS 250 50

Notes:

1. NR 140 ES = Wisconsin Administrative Code, Chapter NR 140 Enforcement Standard

2. NR 140 PAL = Wisconsin Administrative Code, Chapter NR 140 Preventive Action Limit

3. NS = no standard NA = Not Analyzed

4. µg/L = micrograms per liter (equivalent to parts per billion, ppb)

5. Laboratory flags: "J" = Analyte detected between Limit of Detection and Limit of Quantitation.

6. Trip blank results: 03/12/2021: All VOCs reported below laboratory detection limits.

7. Equipment blank results: 03/12/2021: All VOCs reported below laboratory detection limits.

02/02/2021: All VOCs reported below laboratory detection limits.

8. Detections = Analyte detected

9. Exceedances BOLD = Concentration exceeds NR 140 ES

ITALICS = Concentration exceeds NR 140 PAL { } = Concentration exceeds EPA ROD ES [ ] = Concentration exceeds EPA ROD PAL Data entered / updated by: SVK Date: 2/11/2022

10. Special notes: * = monitoring well screen submerged below water table Data checked by: DBC Date: 3/2/2022

PZ-03 PZ-03CPZ-03BPZ-03A

NR 140

ES

1/8/20 3/31/20 7/14/20 10/9/20 10/29/20

NR 140

PAL

3/12/21

EPA ROD

ES

EPA ROD

PAL

PZ-03E PZ-03F

2/2/22

PZ-03D

Page 1 of 1 The Sigma Group, Inc. I:\Wisconsin Dept of Natural Resources\18687 - Moss-American Closure\095 Data\18687_Groundwater Data Table]

REMEDIAL ACTION OPTIONSREMEDIAL TECHNOLOGIES PROCESS OPTIONS COMMENTS

No Action ---- --- Not viable considering the site conditions - included as a baseline to evaluate viable options.

Institutional Controls Soil & Groundwater GIS Registry Regulatory Reporting Viable part of closure strategy - will be used for residual soil & groundwater impacts after remediation is completed.

Containment Physical Barriers Slurry Wall Potentially feasible for GW impacts, but cost prohibitive given degree of impacts.

Sheet Piling Existing sheet pile along the river provides the necessary containment.

Grout Curtains Potentially feasible for GW impacts, but cost prohibitive given degree of impacts.

Surface Soil Cap Viable option for direct contact risk mitigation. Majority of the site is proposed to be capped after closure.

Soil Remediation Excavation & Treatment or Not viable - cost prohibitive.

Disposal Potentially feasible for highly impact soil, but not viable because of time constraints and likely cost prohibitive.

Not very effective for creosote free product mixed with PAH compounds.

Mixing with Chemical Oxidants Viable for treating free product impacted soil.

Landfill Viable part of soil management strategy for excavated soil, particularly for free product and associated impacted soil. Excavated soil will be managed as hazardous waste and disposed at a hazardous waste landfill.

In Situ Remediation Viable strategy for in-situ treatment. May require multiple injection events and relatively long time to treat the soil compared to other technologies.

Viable strategy for in-situ treatment of free product impacted soil.

Potentially feasible for free product impacts, prolonged treatment time and relatively high cost.

Not Viable for the type of free product present.

Potentially feasible for free product impacts; cost prohibitive.

Heated Soil Vapor Extraction Not effective for the type of free product impacted soil.

Soil Flushing Potentially feasible for free product impacts, prolonged treatment time and relatively high cost.

Phytoremediation Viable as a long-term remedy for residual impacts following free product removal/treatment.

Groundwater Extraction & Treatment or Extraction Wells Potentially feasible, but cost prohibitive based on degree of impacts.

Remediation Discharge Biological Treatment Potentially feasible, but cost prohibitive based on degree of impacts.

Photolysis/Oxidation Potentially feasible, but cost prohibitive based on degree of impacts.

Screening/Filtration Not viable for the type of impacts.

Air Stripping Not viable for the type of impacts.

Activated Carbon Adsorption Potentially feasible, but cost prohibitive based on degree of impacts.

POTW Discharge Feasible if groundwater extraction would be necessary, likely cost prohibitive.

Surface Water/Storm Water Potentially feasible if groundwater extraction and treatment would be necessary, likely cost prohibitive.

In Situ Remediation Viable option for type of impacts in groundwater near PZ-03, especially given the limited spatial extent of impacts above ch. NR 141 ES for PAH compounds.

Viable option for PAH impacts in groundwater near PZ-03, especially given the limited spatial extent of impacts above ch. NR 141 ES for

PAH compounds.

Potentially feasible, but cost prohibitive based on degree of impacts.

Potentially feasible, but cost prohibitive based on degree of impacts.

Steam Stripping Potentially feasible, but cost prohibitive based on degree of impacts.

Viable as a long-term remedy for residual impacts following free product removal/treatment.

Monitored Natural Attenuation Viable following free product removal/treatment.

Air Sparging

Phytoremediation

Groundwater Monitoring

Steam Enhanced Vapor/Product

Extraction

Enhanced Bioremediation

Vapor Extraction

In Situ Chemical Oxidation (ISCO)

Enhanced Bioremediation

Bioaugmentation

In-place Chemical Oxidants Mixing

Table 5

Remedial Action Options Matrix

8716 N. Granville Road, Milwaukee, Wisconsin

MAY 2022

Chemical Oxidants Injection

Former Moss-American Site

Thermal

Above Ground Biological Treatment

Above Ground Vapor Extraction

Sigma Project No. 18687

The Sigma Group, Inc. 5/3/2022 I:\Wisconsin Dept of Natural Resources\18687 - Moss-American Closure\090 Reports\2022.04_PZ-03 Area Investigation\Working Docs\REVISED_Rremedial Action Options Matrix.xlsx\Overview

FIGURES