Exhibit C - Phase II.pdf

Former Cabot Station 2427 West Little Kanawha Highway Grantsville, West Virginia 26147

Triad Project No. 04-15-0248

Prepared For:

West Virginia Department of Environmental Protection on behalf of:

Calhoun County Solid Waste Authority 2427 West Little Kanawha Highway Grantsville, West Virginia 26147

Prepared By:

Triad Engineering Inc.

10541 Teays Valley Road Scott Depot, West Virginia 25560

June 20, 2017

SAMPLING AND ANALYSIS PLAN

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TABLE OF CONTENTS

COVER SHEET

TRANSMITTAL LETTER

TABLE OF CONTENTS

LIST OF FIGURES

LIST OF TABLES

LIST OF APPENDICES

1.0 PROJECT MANAGEMENT

1.1 Site Location and Description

1.2 Previous Investigations

1.2 Project Description

1.3 Project Time Line

1.4 Measurement Quality Indicators

2.0 MEASURMENT/DATA ACQUISITION

2.1 Sampling Design

2.1.1 Surface Soil

2.1.2 Subsurface Soil

2.1.3 Groundwater

2.2 Sampling Methods Requirements

2.3 Analytical Methods Requirements

3.0 DATA VALIDATION AND USABILITY

3.1 Reconciliation with User Requirements

3.1.1 Precision

3.1.2 Accuracy

3.1.3 Representativeness

3.1.4 Completeness

3.1.5 Comparability

FIGURES

Figure 1, Site Location Map Figure 2, Conceptual Site Model Figure 3, Sample Location Map

TABLES

Table 1, Project Timeline Table 2, Measurement Quality Indicators Table 3, Sampling and Analysis Summary Table 4, Field and Matrix QC Samples Table 5, Sampling and Analytical Methods Requirements

APPENDICES

Appendix 1, ALS Environmental Quality Assurance Manual Appendix 2, Health and Safety Plan Appendix 3, Standard Operating Procedures Appendix 4, Analytical Method Information

Sampling and Analysis Plan – Rev.0 Triad Engineering, Inc.

Former Cabot Station Triad Project No: 04-15-0248 June 20, 2017 Page 1

1.0 PROJECT MANAGEMENT

1.1 Site Location and Description

Triad Engineering, Inc. (Triad) has prepared this Sampling and Analysis Plan (SAP) for the

West Virginia Department of Environmental Protection (WVDEP) and the Calhoun County Solid

Waste Authority (CCSWA) for the Former Cabot Station property (the Site) located at 2427

West Little Kanawha Highway in Grantsville, Calhoun County, West Virginia. This SAP describes the assessment activities to be performed at the Site to investigate the recognized environmental conditions (RECs) that were identified during the Phase I Environmental Site

Assessment (ESA) (Triad, July 5, 2016).

The Former Cabot Station Site consists of approximately 7.59 acres identified on the Center

District 1, Tax Map 13, as Parcels 44 and 45, currently owned by Dominion Transmission, Inc.

The location of the Site is depicted on the attached Figure 1, Site Location Map on the

Grantsville, W.VA. 7.5-minute topographic quadrangle map.

The Site was undeveloped until construction of the carbon black manufacturing facility in 1898, which operated through the 1920’s. During the 1920’s, a natural gas compressor station operated at the Site until an explosion occurred in the mid to late 1940’s. A new compressor station was constructed in the 1950’s and operated through the mid 1980’s. The Site remained vacant until sometime during the 1990’s, at which time an entrepreneur began transforming the

Site into a manufacturing facility; however, the type of manufacturing planned for the Site is unknown and operations never began. The CCSWA currently occupies the Site and has operated as a recycling collection facility since 2002.

1.2 Previous Investigations

A Phase I ESA, dated July 5, 2016, was prepared by Triad. The following RECs were identified:

The Site was the location of a carbon black manufacturing facility from the time of Site development in 1898 through the 1920’s. Specific activities, chemicals used, and waste management practices are unknown.

A natural gas compressor station operated at the Site from the 1920’s through the mid to late 1940’s, at which time an explosion occurred. The Site was reconstructed during the

1950’s and operated as a compressor station through the mid 1980’s. The reconstructed compressor station also included a machine shop and mercury meter

June 20, 2017 Page 2 workshop. Specific activities, chemicals used, and waste management practices are unknown.

Based on historic uses of the Site, volatile organic compounds (VOC), polynuclear aromatic hydrocarbons (PAH), and RCRA 8 metals may be present in surface soil, subsurface soil, and/or groundwater throughout the Site. The range of potential contamination is currently unknown. Contaminant migration would likely be through surface runoff and subsurface migration to the southeast towards the Little Kanawha River, which borders the Site to the east-southeast. Potential contamination exposure pathways are illustrated on the attached Figure 2, Conceptual Site Model.

1.3 Project Description

The Site assessment activities described in this SAP will consist of the collection of surface soil, subsurface soil, and groundwater samples that will be analyzed for VOC, PAH, and RCRA 8 metals. The analytical data will then be compared to the current West Virginia de minimis risk based standards (West Virginia Voluntary Remediation Program Table 60-3B, June 2017) for residential soil, groundwater, and migration to groundwater values to determine the presence of environmental contamination at the Site. If no West Virginia de minimis value exists for a detected compound, the data will be compared to the most recent EPA residential soil and tap water Regional Screening Levels (RSLs).

The Phase II ESA activities will determine if residual environmental contamination is present at the Site and if remedial actions are warranted. If analytical results are below their respective

West Virginia de minimis risk standards then no further actions will be taken. If analytical results exceed their respective de minimis risk standards then further environmental assessments and/or remedial action may be required at the Site.

The selection of sample locations, analyses, and media were based on current and historic conditions at the Site, future land-use as industrial use, the contaminants of potential concern

(COPC), and identification of potential contaminant exposure pathways that could be associated with human health or ecological risk.

June 20, 2017 Page 3

1.4 Project Time Line

The progress of this project will be tracked from its inception through implementation to ensure all sampling and analytical activities are performed in a correct and cost effective manner. Each step in this process will be scheduled in an objective and realistic time frame to assure that adequate attention is devoted to the minimization of effort and the maximization of information.

The attached Table 1, Project Timeline provides a project time line for this project.

1.5 Measurement Quality Indicators

The measurement quality indicators for this project are included in the attached Table 2, Measurement Quality Indicators and Appendix 4, Analytical Method Information.

June 20, 2017 Page 4

2.0 MEASURMENT/DATA ACQUISITION

2.1 Sampling Design

During site characterization activities, Triad will utilize a direct-push technology (DPT) drilling unit to install approximately 12 borings throughout the Site. Due to a natural gas compressor station historically operating at the Site, underground gas line locations are unknown.

Therefore, the borings will be hand cleared prior to using the DPT drilling unit with a soil vacuum excavator. All boring locations will be documented using a hand-held global positioning system

(GPS). The DPT unit will collect continuous subsurface soil samples in clear acetate sample liners from the ground surface down to a boring termination depth that will be determined based on field observations. The field observations used to determine the depth of boring termination could include staining, odor, depth to groundwater, or results from field screening using a photoionization detector (PID). Five of the borings will be advanced until groundwater is encountered and temporary monitoring wells will be installed for groundwater collection using the DPT unit. If no significant observations are noted on the remaining seven borings, they will be terminated at approximately 15 feet below ground surface (bgs). Triad will screen the contents of each sample liner using a PID to check for the presence of VOC. An environmental boring log will be prepared for each boring location, which will include soil descriptions, PID results, and other pertinent observations. At the conclusion of each soil boring, the borehole will be backfilled with bentonite chips. Triad will manage all investigative derived waste following the procedures outlined in the Investigative Derived Waste (IDW) SOP included on Page 23 of

Appendix C, Standard Operating Procedures.

2.1.1 Surface Soil

Triad will collect approximately seven surface soil samples from the following locations:

Three samples in the area of the former mercury meter workshop (SS-1, SS-2, and SS-

3).

Four samples from the former pipe storage yard located on the southern portion of the

Site (SS-4, SS-5, SS-6, and SS-7).

All of the surface soil samples will be analyzed for VOC, PAH, and RCRA 8 metals.

2.1.2 Subsurface Soil

Triad will collect approximately 12 subsurface soil samples from throughout the Site. The

June 20, 2017 Page 5 subsurface soil samples will be collected at depths to be determined based on field observations, which could include staining, odor, depth to groundwater, or results from field screening using a PID, etc. In the absence of significant field observations, the subsurface soil samples will be collected at approximately 8 to 10 feet bgs. The borings will be advanced in the following locations:

Three samples in the area of the former mercury meter workshop (SB-1, SB-2, and SB-

3).

Four samples from the former pipe storage yard located on the southern portion of the

Site (SB-4, SB-5, SB-6, and SB-7).

One sample from the loading/unloading area on the southern side of the main structure

(SB-8).

One sample on the western side of the main structure (SB-9).

One sample near the concrete collection basin located on the western side of the main structure (SB-10).

One sample on the eastern side of the main structure and west of the former steam boiler room (SB-11).

One sample on the eastern side of the main structure and loading/unloading area (SB-

12).

All of the subsurface soil samples will be analyzed for VOC, PAH, and RCRA 8 metals.

2.1.3 Groundwater

Triad will collect approximately five groundwater samples from the following preliminary locations:

One sample near the former mercury meter workshop (GW-1).

One sample in the southeastern portion of the former pipe storage yard (GW-2).

One sample near the concrete collection basin located on the western side of the main structure (GW-3).

One sample on the eastern side of the main structure and west of the former steam boiler room (GW-4).

One sample on the eastern side of the main structure and loading/unloading area (GW-

5).

All of the groundwater samples will be analyzed for VOC, PAH, and dissolved RCRA 8 metals.

June 20, 2017 Page 6

The sample type, number, and required analysis are summarized on the attached Table 3, Sampling and Analysis Summary and are depicted on the attached Figure 4, Sample

Location Map.

2.2 Sampling Methods Requirements

The sampling procedures are identified on the attached Table 5, Sampling and Analytical

Methods Requirements and included in Appendix 3, Standard Operating Procedures. Field

QC samples will be collected during the work to assess sampling precision, potential cross-contamination, and matrix effect as summarized in Table 4, Field and Matrix QC Samples. All samples will be collected and preserved in accordance with procedures found in Table 1, Sample Containers, Preservation and Holding Times of the QAPP. Field and sample matrix quality control (QC) will be performed as detailed in the QAPP.

2.3 Analytical Methods Requirements

Information about the analytical methods (including any extraction or digestion methods) being used for this project are included in Table 5, Sampling and Analytical Methods

Requirements. Additional information about analytical methods requirements (MDL, PQL, etc.), laboratory quality control requirements and laboratory equipment calibration procedures can be found in the attached Appendix 1, ALS Environmental Quality Assurance Manual and Appendix 4, Analytical Method Information.

June 20, 2017 Page 7

3.0 DATA VALIDATION AND USABILITY

3.1 Reconciliation with User Requirements

To ensure that measurement data generated when performing this Brownfield investigation are of an appropriate quality, 100% of the data will be validated. All data from this project will be validated in accordance with the IM1 and M2 level of data validation found in the Region III

Innovative Approaches to Data Review Guidance Document.

It is important to note that the level of detail and data quality needed will vary with the intended use of the data, specified as user requirements. Data Quality Objectives (DQOs) are typically assessed by evaluating Precision, Accuracy, Representativeness, Completeness, and

Comparability (PARCC) of all aspects of the data collection process. Generally, data that does not meet the established acceptance criteria may be probably cause for re-sampling and re-analysis. However, in some cases, data that did not meet the acceptance criteria are usable with specified limitations. Data that are marked as usable with limitations will be included in the project reports, but will be clearly marked as having limited usability. PARCC is defined and calculated as:

3.1.1 Precision

Precision is a measure of the reproducibility of analyses under a given set of conditions.

Precision examines the spread of data about their mean. The spread presents how different the individual reported values are from the average reported values. Precision is thus a measure of the magnitude of errors and will be expressed as the relative percent difference (RPD) or the relative standard deviation (RSD). The lower these values are, the more precise that data.

These quantities are defined as follows:

RPD (%) = 100 x (S - D) (S + D)/2

OR

RPD (%) = 100 x 2 (S – D) 2 (S + D) where S = Analyte or compound concentration in a sample

D = Analyte or compound concentration in a duplicate sample

June 20, 2017 Page 8

Or when there are more than two measurements:

RSD (%) = 100 (s) X

Where s = Standard deviation of replicate measurements x = Mean of replicate measurements

The duplicate samples utilized to evaluate precision include laboratory matrix duplicate (MD), matrix spike (MS), matrix spike duplicate (MSD), and field duplicate samples. The goal is to maintain a level of analytical and sampling precision consistent with the objectives of the sampling event. To maximize precision, consistent sampling and analytical procedures are to be followed as presented in the QAPP. The control limit for field duplicate sample analyses is

40%. Control limits for laboratory MS, MSD, and MD sample analyses are determined by the laboratory’s internal QA plan (refer to Appendix 1, ALS Environmental Quality Assurance

Manual).

3.1.2 Accuracy

Accuracy is a measure of the bias that exists in a measurement system. Accuracy measures the average or systematic error of a measurement method or sampling method. This measure is defined as the difference between the average of reported values and the actual value.

Accuracy will be expressed as the percent bias for standard reference samples. The closer this value is to zero, the more accurate the data. This quantity is defined as follows:

Bias (%) = (MC – SC) x 100

SC

Where SC = Known analyte or compound (i.e. spike) concentration

MC = Measured analyte or compound concentration

In cases where accuracy is determined from spiked samples, such as the laboratory control sample (LCS) or surrogate compounds, accuracy is expressed as the percent recovery. The closer the value is to 100, the more accurate the data. Recovery is calculated as follows:

June 20, 2017 Page 9

Recovery (%) = (MC) x 100

Matrix spike percent recovery will be calculated as follows:

Recovery (%) = (MC – USC) x 100

USC = Unspiked sample concentration

For investigations conducted in accordance with QAPP, accuracy is also defined as the percent recovery of QA/QC samples that are spiked with a known concentration of an analyte of interest. The QA/QC samples used to evaluate analytical accuracy include instrument calibration, internal standards, ICP serial dilution analysis, laboratory control samples, MS/MSD samples, and surrogate compound recoveries. Control limits for instrument calibration, internal standards, ICP serial dilution analysis, laboratory control samples, MS/MSD samples, and surrogate compound recoveries are provided in the applicable USEPA approved methods or determined by the laboratory’s internal QA plan.

3.1.3 Representativeness

Representativeness expresses the degree to which data accurately and precisely represent the environmental condition. Representativeness is accomplished by maintaining sample integrity with appropriate preservation and meeting technical holding times. Those data from samples either inappropriately preserved or failing to meet technical holding times will be qualified per the current USEPA Region III data validation guidelines.

3.1.4 Completeness

Completeness is the measurement of the amount of valid data obtained from a measurement system compared to the amount that was expected to be obtained under “normal” conditions.

Completeness establishes whether a sufficient number of valid measurements were obtained.

June 20, 2017 Page 10

The closer this value is to 100, the more complete the measurement process. The minimum level of completeness expected for any project is 90%. Data rejected, whether due to sampling design error or measurement error, during the data validation process will be considered an invalid measurement. Completeness will be calculated as follows:

Completeness (%) = V x 100

P

Where V = Number of valid measurements

P = Number of planned measurements

3.1.5 Comparability

Comparability expresses the confidence with which one set of data can be compared to another. It is a quantitative measurement to ensure sampling and analytical procedures are consistent within and between data sets. When traceable standards are used, such as single blind performance evaluation samples, the analytical results can be compared to the known concentration and its acceptable range. If the laboratory reports any standard outside the acceptance range, there is no confidence in the result and the result should be qualified.

Analytical comparability can also be made with split samples sent to a secondary laboratory. At the discretion of WVDEP, the collection of split samples may also be performed at a frequency of 10 percent. Any RPD of 40 or greater should be investigated further by either data validation or an audit of the laboratory quality system. A third analytical comparability can be made by comparing field screening data with confirmatory results. Any RPD of 40 or greater should result in the qualification of the field screening data.

Sampling procedure comparability can be made by collecting field duplicate samples. The control limit for field duplicate sample results is 40 RPD. An RPD of 40 or greater should result in the qualification of all data collected by the same methodology.

To assess if environmental monitoring measurements are of an appropriate quality, the general

PARCC requirements above and any Site-specific measurements for precision, accuracy and completeness will be compared to the quality objectives and measurement performance criteria.

FIGURES

Figure 1, Site Location Map Figure 2, Conceptual Site Model Figure 3, Sample Location Map

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TABLES

Table 1, Project Timeline Table 2, Measurement Quality Indicators

Table 3, Sampling and Analysis Summary Table 4, Field and Matrix QC Samples

Table 5, Sampling and Analytical Methods Requirements

Activity Start Date

Activity End Date

Preparation of SAP 6/14/2017 6/20/2017

WVDEP Review of SAP 6/21/2017 7/21/2017

Revisions to SAP (if required) 7/21/2017 7/28/2017

Conduct field investigation 8/2/2017 8/3/2017

Laboratory Analytical Testing 8/4/2017 8/18/2017

Perform Data Validation 8/18/2017 9/18/2017

Preparation of Draft Phase II ESA Report 8/18/2017 9/18/2017

WVDEP Review of Draft Phase II ESA Report 9/19/2017 10/19/2017

Revisions to Phase II ESA Report 10/19/2017 10/25/2017

Table 1. PROJECT TIMELINE

Former Cabot Station

USEPA Property ID 216361

Dates Activities

Grantsville, Calhoun County, West Virginia

Triad Engineering, Inc. Page 1 of 8

Residential Soil (mg/kg)

Groundwater (ug/L)

Migration to Groundwater

(mg/kg)

1,1,1-Trichloroethane 640 200 0.7 40% * Refer to Appendix D >/= 90% 1,1,2,2-Tetrachloroethane 0.64 0.76 0.00030 40% * Refer to Appendix D >/= 90% 1,1,2-trichloro-1,2,2-trifluoroethane 910 57,000 140 40% * Refer to Appendix D >/= 90% 1,1,2-Trichloroethane 1.2 5 .0016 40% * Refer to Appendix D >/= 90% 1,1-Dichloroethane 3.8 2.8 0.001 40% * Refer to Appendix D >/= 90% 1,1-Dichloroethene 240 7 0.0025 40% * Refer to Appendix D >/= 90% 1,2,3-Trichlorobenzene NA NA NA 40% * Refer to Appendix D >/= 90% 1,2,4-Trichlorobenzene 24 70 2.0 40% * Refer to Appendix D >/= 90% 1,2-Dibromo-3-Chloropropane 0.0057 2.0 0.000087 40% * Refer to Appendix D >/= 90% 1,2-Dibromoethane 0.039 0.5 0.000014 40% * Refer to Appendix D >/= 90% 1,2-Dichlorobenzene 380 600 0.58 40% * Refer to Appendix D >/= 90% 1,2-Dichloroethane 5 5 0.0014 40% * Refer to Appendix D >/= 90% 1,2-Dichloropropane 1.1 5 0.0017 40% * Refer to Appendix D >/= 90% 1,3-Dichlorobenzene NA NA NA 40% * Refer to Appendix D >/= 90% 1,4-Dichlorobenzene 2.8 75 0.072 40% * Refer to Appendix D >/= 90% 2-Butanone 28,000 5,600 1.2 40% * Refer to Appendix D >/= 90% 4-Methyl-2-Pentanone 3,400 1,200 0.28 40% * Refer to Appendix D >/= 90% Acetone 61,000 14,000 2.9 40% * Refer to Appendix D >/= 90% Benzene 1.2 5 0.0026 40% * Refer to Appendix D >/= 90% Bromochloromethane NA NA NA 40% * Refer to Appendix D >/= 90% Bromodichloromethane 0.31 0.13 0.000036 40% * Refer to Appendix D >/= 90% Bromoform 20 3.3 0.00087 40% * Refer to Appendix D >/= 90% Bromomethane 7.3 7.5 0.0019 40% * Refer to Appendix D >/= 90% Carbon Disulfide 740 810 0.24 40% * Refer to Appendix D >/= 90% Carbon Tetrachloride 7 5 0.0019 40% * Refer to Appendix D >/= 90% Chlorobenzene 290 100 0.068 40% * Refer to Appendix D >/= 90% Chloroethane 2,100 21,000 5.9 40% * Refer to Appendix D >/= 90% Chloroform 0.34 0.22 0.000061 40% * Refer to Appendix D >/= 90%

Table 2. MEASUREMENT QUALITY INDICATORS

Former Cabot Station

Grantsville, Calhoun County, West Virginia

Volatile Organic Compounds (VOC)

Action Limit 1

USEPA Property ID 216361

Compound Precision Accuracy Completeness

Triad Engineering, Inc. Page 2 of 8

Groundwater (ug/L)

Migration to Groundwater

(mg/kg)

Table 2. MEASUREMENT QUALITY INDICATORS

Former Cabot Station

Grantsville, Calhoun County, West Virginia

Action Limit 1

USEPA Property ID 216361

Compound Precision Accuracy Completeness

Chloromethane 120 190 0.049 40% * Refer to Appendix D >/= 90% cis-1,2-Dichloroethene 17 70 0.021 40% * Refer to Appendix D >/= 90% cis-1,3-Dichloropropene 1.90 0.470 0.00017 40% * Refer to Appendix D >/= 90% Cyclohexane 120 13,000 13 40% * Refer to Appendix D >/= 90% Dibromochloromethane 8.3 0.87 0.00023 40% * Refer to Appendix D >/= 90% Ethylbenzene 6.2 700 0.78 40% * Refer to Appendix D >/= 90% Isopropylbenzene 270 450 0.74 40% * Refer to Appendix D >/= 90% Methyl Acetate 23,000 5,300 1.1 40% * Refer to Appendix D >/= 90% Methyl N-Butyl Ketone NA NA NA 40% * Refer to Appendix D >/= 90% Methylcyclohexane NA NA NA 40% * Refer to Appendix D >/= 90% Methylene chloride 58 5 0.0013 40% * Refer to Appendix D >/= 90% Methyl-Tert-Butyl Ether 50 14 0.0032 40% * Refer to Appendix D >/= 90% o-Xylene NA NA NA 40% * Refer to Appendix D >/= 90% Styrene (Monomer) 870 100 0.11 40% * Refer to Appendix D >/= 90% Tetrachloroethene 25 5 0.0023 40% * Refer to Appendix D >/= 90% Toluene 820 1,000 0.69 40% * Refer to Appendix D >/= 90% Total Xylenes 260 10,000 9.9 40% * Refer to Appendix D >/= 90% trans-1,2-Dichloroethene 130 100 0.031 40% * Refer to Appendix D >/= 90% trans-1,3-Dichloropropene 1.9 0.47 0.00017 40% * Refer to Appendix D >/= 90% Trichloroethene 5 5 0.0018 40% * Refer to Appendix D >/= 90% Trichlorofluoromethane 790 1,100 0.73 40% * Refer to Appendix D >/= 90% Vinyl Chloride 0.06 2 0.00069 40% * Refer to Appendix D >/= 90%

1-Methylnaphthalene 24 1.1 0.06 40% * Refer to Appendix D >/= 90% 2-Methylnaphthalene 310 36 0.19 40% * Refer to Appendix D >/= 90% Acenaphthene 4,100 240 2.5 40% * Refer to Appendix D >/= 90% Acenaphthylene 4,200 320 3.3 40% * Refer to Appendix D >/= 90% Anthracene 23,000 1,800 58 40% * Refer to Appendix D >/= 90% Benzo(a)anthracene 0.21 0.012 0.0042 40% * Refer to Appendix D >/= 90%

Polynuclear Aromatic Hydrocarbons (PAH)

Triad Engineering, Inc. Page 3 of 8

Groundwater (ug/L)

Migration to Groundwater

(mg/kg)

Table 2. MEASUREMENT QUALITY INDICATORS

Former Cabot Station

Grantsville, Calhoun County, West Virginia

Action Limit 1

USEPA Property ID 216361

Compound Precision Accuracy Completeness

Benzo(a)pyrene 0.016 2 0.23 40% * Refer to Appendix D >/= 90% Benzo(b)fluoranthene 0.16 0.034 0.041 40% * Refer to Appendix D >/= 90% Benzo(g,h,i)perylene 1,800 600 2,300 40% * Refer to Appendix D >/= 90% Benzo(k)fluoranthene 1.6 0.34 4 40% * Refer to Appendix D >/= 90% Chrysene 16 3.4 1.2 40% * Refer to Appendix D >/= 90% Dibenzo(a,h)anthracene 0.016 0.0034 0.013 40% * Refer to Appendix D >/= 90% Fluoranthene 2,400 800 89 40% * Refer to Appendix D >/= 90% Fluorene 2,900 150 2.7 40% * Refer to Appendix D >/= 90% Indeno(1,2,3-cd)pyrene 0.16 0.034 0.13 40% * Refer to Appendix D >/= 90% Naphthalene 4.1 0.17 0.00054 40% * Refer to Appendix D >/= 90% Phenanthrene 23,000 6,000 200 40% * Refer to Appendix D >/= 90% Pyrene 2,300 79 8.6 40% * Refer to Appendix D >/= 90%

Arsenic 0.43 10 0.29 40% * Refer to Appendix D >/= 90% Barium 15,000 2,000 82 40% * Refer to Appendix D >/= 90% Cadmium 37 5 0.38 40% * Refer to Appendix D >/= 90% Chromium III 120,000 22,000 40,000,000 40% * Refer to Appendix D >/= 90% Lead 400 15 14 40% * Refer to Appendix D >/= 90% Mercury, Total 3.1 2 1 40% * Refer to Appendix D >/= 90% Selenium 390 50 0.26 40% * Refer to Appendix D >/= 90% Silver 390 94 0.8 40% * Refer to Appendix D >/= 90%

1 West Virginia Voluntary Remediation Program Table 60-3B, June 1, 2017.

NA No value available

* If not otherwise specified in Appendix A, Quality Assurance Manual.

RCRA 8 Metals

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Environmental Media

VOC PAH

Surface soil In the area of the former mercury meter workshop 3 3 3

Former pipe storage yard located on the southern portion of the Site 4 4 4

Subsurface Soil In the area of the former mercury meter workshop 3 3 3

Former pipe storage yard located on the southern portion of the Site 4 4 4

Loading/unloading area on the southern side of the main structure 1 1 1 Western side of main structure 1 1 1 Near the concrete collection basin located on the western side of main structure 1 1 1 Eastern side of the main structure and west of the former steam boiler room 1 1 1 Eastern side of the main structure and loading/unloading area 1 1 1

Groundwater Near the former mecury meter workshop 1 1 1 Southeastern portion of the former pipe storage yard 1 1 1 Near the concrete collection basin located on the western side of the main structure 1 1 1 Eastern side of the main structure and west of the former steam boiler room 1 1 1 Eastern side of the main structure and loading/unloading area 1 1 1

Total 24 24 24

Table 3. SAMPLING AND ANALYSIS SUMMARY Former Cabot Station

Grantsville, Calhoun County, West Virginia USEPA Property ID 216361

RCRA 8

Metals

Environmental Media VOC PAH RCRA 8 Metals

Soil surface soil 7 7 7 subsurface soil 12 12 12

Subtotal 19 19 19

Aqueous groundwater 5 5 5

Subtotal 5 5 5

Total 24 24 24

Table 3. SAMPLING AND ANALYSIS SUMMARY (continued) Former Cabot Station

Grantsville, Calhoun County, West Virginia USEPA Property ID 216361

Number of Samples Collected and Analyses

Number of Samples Field Samples QC Samples

QC

Sample Aqueous Soil Aqueous Soil

Field QC Samples:

a.) Field Duplicate

VOC 5 19 1 1 2

PAH 5 19 1 1 2

Metals 5 19 1 1 2 b.) Equipment Blank (Rinsate) Geoprobe N/A 12 1 N/A 2

Matrix QC Samples a.) Matrix Spike and Matrix Spike Duplicate (MS/MSD)

VOC 5 19 1 1 2

PAH 5 19 1 1 2

b.) Matrix Spike and Matrix Duplicate (MS/DUP) Metals 5 19 1 1 2

TOTAL 14

Notes:

Number of field QC samples to be collected based on the following:

Field duplicate based on 1 QC sample per 20 field samples per environmental media.

Equipment blank based on 1 QC sample per 20 field samples per environmental media.

1 sample container containing water will be placed in each cooler as a temperature blank.

Former Cabot Station Grantsville, Calhoun County, West Virginia

USEPA Property ID 216361

Total QC Samples Collected

Table 4. FIELD AND MATRIX QC SAMPLES

Matrix Parameter Number of Samples Sampling Procedure 1

Sample Preparation/Extraction

Method Number

Analytical Method Number

Soil 19 Surface Soil Collection Pages 1-5; Direct-Push Subsurface Soil Collection Pages 6-10; Method

5035 Sample Collection Pages 11-13 5035 8260B

Aqueous 5 Direct-Push via Check Valve Groundwater

Collection Pages 14-15; Aqueous VOC and GRO Sample Collection Pages 18-19

5030B 8260B

Soil 19 Surface Soil Collection Pages 1-5; Direct-Push

Subsurface Soil Collection Pages 6-10 3550B 8270C

Aqueous 5 Direct-Push via Check Valve Groundwater

Collection Pages 14-15

3510C 8270C/SIM

Soil RCRA 8 Metals 19 Surface Soil Collection Pages 1-5; Direct-Push

Subsurface Soil Collection Pages 6-10 3051A/6010/7471 6010B/7471A

Aqueous RCRA 8 Metals 5 Direct-Push via Check Valve Groundwater

Collection Pages 14-15; Dissolved Metals in Groundwater Collection Pages 16-17

3010A/6010/7470 6010B/7471A

1 SOPs are included in Appendix 3.

NA Not applicable

PAH

Table 5. SAMPLING AND ANALYTICAL METHOD REQUIREMENTS

Former Cabot Station

Grantsville, Calhoun County, West Virginia

VOC

USEPA Property ID 216361

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Appendix 1 ALS Environmental Quality Assurance Manual

QUALITY ASSURANCE MANUAL

ALS Environmental – South Charleston Facility 1740 Union Carbide Drive

South Charleston, WV, 25303 304-356-3168 304-205-6262 www.alsglobal.com

ALS-SC-QAM, Rev. 02 Effective: 08/01/2016 Page ii of iii

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TABLE OF CONTENTS

1) Introduction and Scope

2) Organization

3) Management

4) Document Control

5) Review of Requests, Tenders and Contracts

6) Subcontracting of Tests

7) Purchasing Services and Supplies

8) Service to the Client

9) Complaints

10) Facilities and Equipment

11) Sample Management

12) Analytical Procedures

13) Measurement Traceability and Calibration

14) Assuring the Quality of Results

15) Control of Non-Conforming Environmental Testing Work

16) Corrective Action, Preventive Action, and Improvement

17) Control of Records

18) Audits

19) Management Review

20) Personnel

21) Reporting of Results

22) Summary of Changes and Document History

23) References for Quality System Standards, External Documents, Manuals, and Test Procedures APPENDIX A – Glossary APPENDIX B – Organization Charts and Key Personnel Qualifications APPENDIX C – Ethics and Data Integrity Employee Agreement APPENDIX D – Laboratory Floor Plan APPENDIX E – Analytical Equipment APPENDIX F – Containers, Preservation and Holding Times APPENDIX G – Standard Operating Procedures* APPENDIX H – Data Qualifiers APPENDIX I – Master List of Controlled Documents APPENDIX J – Laboratory Accreditations

Page iii of iii

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QA MANUAL CROSS REFERENCE TABLE

ALS QAM and/or SOP ISO 17025:2005 Section

TNI Vol 1 2009 Module/Section

2 4.1 2/4.1 3 4.2 2/4.2

4 / SC-QS-014 4.3 2/4.3

5 / SC-GEN-006 4.4 2/4.4

6 / SC-GEN-007 4.5 2/4.5

7 / SC-GEN-010 4.6 2/4.6

8 4.7 2/4.7

9 / SC-ADM-004 4.8 2/4.8

15 / SC-GEN-005 4.9 2/4.9

16.6 4.10 2/4.10

16 / SC-QS-003 4.11 2/4.11

16.5 4.12 2/4.12

17 / SC-QS-014 4.13 2/4.13

18 4.14 2/4.14

19 / SC-QS-017 4.15 2/4.15

2, 12, 13, 14 5.1 2/5.1

20 5.2 2/5.2 10 5.3 2/5.3

12, 13 5.4 2/5.4 10 5.5 2/5.5 13 5.6 2/5.6 11 5.7 2/5.7 11 5.8 2/5.8 14 5.9 2/5.9 21 5.10 2/5.10

R I G H T S O L U T I O N S | R I G H T P A R T N E R

Quality Assurance Manual

1) Introduction and Scope

The Quality Assurance Manual (QAM) outlines the quality system used at the South Charleston laboratory of ALS Environmental (ALS Group USA Corp. dba ALS Environmental). This manual defines the policies, procedures, and documentation that: (1) assure analytical services meet a defined standard of quality, (2) provide data of known documented quality, and (3), where applicable, demonstrates regulatory compliance.

The QAM sets the standard under which all laboratory operations are performed including the laboratory's organization, objectives, and operating philosophy. The QAM has been prepared to assure compliance with the 2009 TNI Environmental Laboratory Sector Standard, Volume 1, Management and Technical Requirements for Laboratories Performing Environmental Analysis (EL-V1-M1 through M7-ISO-2009), which is consistent with the ISO/IEC 17025:2005 requirements that are relevant to environmental testing services. In addition, the policies and procedures outlined are established to be compliant with the various accreditation and certification programs listed in Appendix J.

1.1 Scope of Testing

ALS Environmental is a professional analytical service laboratory providing analytical services for a variety of matrices including, but not limited to, aqueous, solid, hazardous waste, and air. Analytical services are based upon EPA approved methods and/or other promulgated protocols. Refer to Appendix J for a list of analytical capabilities and corresponding accreditation status.

1.2 Management of the Quality Assurance Manual

The Quality Assurance Manager is responsible for maintaining the QAM. The QAM is reviewed annually by the QA Manager and laboratory personnel to ensure it still reflects current practices and meets the requirements of any applicable regulations or client specifications.

The QAM is considered confidential within the ALS Environmental and may not be altered in anyway except by approval of the Laboratory Director and QA Manager. If it is distributed to external users, it is for the purpose of reviewing the management system and may not be used for any other purpose without written permission.

1.3 A list of commonly used definitions and acronyms used in this manual is included in Appendix A.

2) Organization

The ALS Environmental South Charleston facility is a commercial laboratory located at 1740 Union Carbide Drive, South Charleston, WV and performs a variety of testing services and activities to meet the needs of laboratory clients. The laboratory systems are designed to also meet the requirements of applicable certification and accreditation bodies.

2.1 Laboratory Organizational Structure

The laboratory is a legally identifiable organization, and a division of a publicly owned corporation, ALS Group USA Corp. dba ALS Environmental. The US tax ID number is available upon request. ALS Group USA Corp. is a wholly owned subsidiary of ALS Limited (ASX: ALQ), formerly A Campbell Brothers Limited Company.

2.2 Avoiding Conflict of Interest through Organizational Structure

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2.2.1 Through application of the policies and procedures outlined in this QAM and use of a defined organizational structure, the laboratory assures that it is impartial and that personnel are free from undue commercial, financial, or other undue pressures that might influence their technical judgment.

2.2.2 Policies are in place to prevent outside pressures or involvement in activities that may affect competence, impartiality, judgment, operational integrity, or the quality of the work performed at the laboratory.

2.2.3 Management and technical personnel have the authority and resources to carry out their duties and have procedures to identify and correct departures from the laboratory’s management system.

2.2.4 Personnel understand the relevance and importance of their duties as related to the maintenance of the laboratory’s management system. Ethics and data integrity procedures ensure that personnel do not engage in activities that diminish confidence in the laboratory’s capabilities. Procedures and policies are also established to ensure confidentiality is maintained.

2.3 An organization chart is provided in Appendix B that shows the operational structure and reporting relationships in the laboratory. Additional information regarding responsibilities, authority and interrelationship of personnel who manage, perform or verify testing is included in Section 3 of this QAM.

3) Management

3.1 Quality Policy Statement

The laboratory's Quality System is documented in this manual and the associated Standard Operating Procedures (SOPs). Together they describe the policies, objectives, principles, organizational authority, responsibilities, accountability, and means of implementation for ensuring quality in the work processes, products, and services.

The objective of the quality system is to generate data of known and documented quality that meets specified requirements and provide for its continuous improvement.

The laboratory’s policy in support of this objective is to: (1) utilize good laboratory practices, (2) maintain documented quality standards, (3) uphold the highest level of service, and (4) comply with applicable Standards of accreditation (e.g. TNI). The laboratory ensures that personnel are free from any commercial, financial, or other undue pressures that might adversely affect the quality of work. This policy is implemented and enforced through the management’s commitment to the principles and practices outlined in this manual. The primary responsibility for quality rests with each individual within the laboratory organization. Accordingly, every laboratory employee must ensure that the generation and reporting of quality analytical data is a fundamental priority. Every laboratory employee is required to familiarize him or herself with the quality documentation and to implement the policies and procedures in their work. All employees are trained annually on the ethical principles and procedures surrounding the generation of data. The laboratory maintains a strict policy of client confidentiality and holds all employees to this policy.

3.2 Management Requirements

Laboratory management ensures that the laboratory’s policies and objectives for quality are documented by reference or by inclusion in the QAM, and that the QAM is:

(a) communicated to, (b) made available to, (c) understood by, and (d) implemented by, R I G H T S O L U T I O N S | R I G H T P A R T N E R all personnel concerned. Where the QAM documents specific laboratory requirements, a separate SOP or policy is not required.

3.3 Quality Assurance Manual

The Quality Assurance Manual is maintained current and up-to-date by the quality assurance department. All employees must complete a read-receipt form stating they

1) have read the Quality Assurance Manual, 2) understand the contents, and 3) will adhere to the stated policies. The completed read-receipt form is kept on file by the quality assurance department.

3.4 Management Responsibility and Authority

3.4.1 The laboratory management team includes the Laboratory Director, Laboratory Supervisor(s), and the Quality Assurance Manager. This group has overall responsibility for technical operations and the authority needed to generate/maintain the defined level of quality stated in the Quality Policy (above) and is upheld through the application of documented policies and procedures.

3.4.2 Management is responsible for the assignment of responsibilities, authorities, and interrelationships of the personnel who manage, perform, or verify work affecting the quality of environmental tests. Management is responsible for defining the minimal level of education, qualifications, experience, and/or skills necessary for completion of the assigned responsibilities.

3.4.3 Management bears specific responsibility for maintenance of the Quality System. This includes defining roles and responsibilities of personnel, approving documents, and providing training.

3.4.4 Management ensures technical competence of personnel operating equipment, performing tests, evaluating results, and signing reports by limiting authority to those who are appropriately trained and/or supervised. Training is kept up to date as described in Section 20 of this document.

3.4.5 Laboratory management must make available all necessary equipment required for the correct performance of the scope of environmental testing presented in this QAM. Only trained and authorized personnel can operate equipment.

3.4.6 Management also bears responsibility for ensuring that audit findings and/or corrective actions are addressed and completed within required time frames.

Designated alternates are appointed by management during the absence of the Laboratory Director, Operations Manager, or the Quality Assurance Manager, and always if the absence is more than 15 days.

3.5 Job Descriptions and Qualifications (qualifications of key personnel are given in Appendix B)

3.5.1 Laboratory Director

The Laboratory Director is responsible for all laboratory activities as the highest-level manager. He/she provides administrative, operational, and Technical leadership through planning, allocation, management of personnel, and management of resources. He/she approves the QAM, provides resources for implementation of the QA program, and serves as Technical Director. The Laboratory Director position requires a BS or BA degree in Science, Engineering, or Management with five years supervisory experience in environmental laboratory operations.

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3.5.2 Lab Supervisor

The Laboratory Supervisor reports directly to the Laboratory Director and is responsible for day-to-day supervision of laboratory operations. He/she assures production of reliable data through the monitoring of analytical procedures, corroborating analysis performed, and approving staff capability. He/she certifies that personnel with appropriate educational and/or Technical background perform all tests for which the lab is accredited according to SOP specifications. He/she reviews, schedules, and oversees the implementation of new methodologies. In the absence of the Operations Manager, the Laboratory Director or Quality Assurance Manager must maintain these duties. The Operations Manager position requires a BS or BA degree in Science, Engineering, or Management with five years experience in environmental laboratory operations.

3.5.3 Quality Assurance Manager

The Quality Assurance (QA) Manager is responsible for ensuring that the quality system is documented, implemented, and adhered to in the course of laboratory operations. He/she has direct access to the Laboratory Director and is independent of daily laboratory operations. He/she is tasked with:

Day-to-day implementation of the quality program, oversight of quality control processes, including establishing control limits, maintaining the Quality Assurance Manual, maintaining quality assurance records, acquiring and maintaining laboratory accreditations.

evaluating data, performing assessments without managerial influence, conducting internal audits, arranging for external audits, monitoring corrective actions, and notifying management of any deficiencies and/or opportunities for improvement in laboratory operations.

The QA Manager performs or coordinates a QA Management System review annually according to SOP SC-QS-017, QA Management Review. He/she has the authority to place a stop work order on any non-compliant work area. In the absence of the QA Manager, the QA Deputy or Operations Manager must maintain these duties. The QA Manager position requires a BS or BA degree in Science, Engineering, or Management with a minimum of five years experience in environmental laboratory operations and two years experience in quality system management.

3.5.4 Project Manager(s)

Project Managers (PM) are responsible for ensuring that analyses performed by the laboratory meet all project, contract, and/or client-specified requirements.

The PM is tasked with 1) relaying project requirements to the staff, 2) review of sample log-in information, 3) monitoring/communicating project progress, and

4) reviewing/issuing final reports to the client. In the absence of the Project Manager, the Project Manager Supervisor (or designate) must maintain these duties. The PM position requires a BS or BA in Science, Engineering, or Management with five years applicable experience.

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3.5.5 Safety Manager

The Safety Manager reports to the Laboratory Director and is responsible for administration of the laboratory’s safety program. He/she is tasked with 1) implementing safety policies, 2) reviewing accidents and/or incidents, 3) monitoring hazardous waste disposal, and 4) conducting routine safety inspections. In the absence of the Safety Officer, the Laboratory Director (or designate) must maintain these duties. The Safety Officer position requires a high school diploma and two years applicable laboratory experience.

(Note: In lieu of formal education requirements, three years experience can be considered equivalent to one year formal education.)

3.6 Data Integrity System

Management functions include implementation of a data integrity system. The data integrity system employed at ALS Environmental is an integrated approach designed to ensure the production of defensible and quality data. The overall system consists of a three-tier approach as documented in laboratory SOP SC-QS-015, Data Integrity System.

The ALS Environmental policies and requirements for Ethics and Data Quality are described in the corporate SOP CE-GEN-001, Laboratory Ethics and Data Integrity. The employee Ethics and Data Quality Agreement from the SOP is provided in Appendix C.

System policy is based upon criteria specified by ISO 17025, US EPA, TNI, and (if required) project specific criteria. System programs to support this policy include approved Standard Operating Procedures, employee training, internal/external assessments, and annual management review. Within each system program, critical components of data integrity are employed. These components include defined data quality objectives, data generation procedures, data verification, and data validation.

Specifics of these components are detailed in individual documents. Prior to final release, validated data is compared to data quality objectives in order to assure its worthiness.

The laboratory has the resources and authority to operate a management system that is capable of identifying departures from that system and from procedures during testing, and initiates actions to minimize or prevent departures.

3.7 Client Confidentiality

As a function of managing client projects and conducting testing, it is recognized that the laboratory will obtain, or be provided, information which may be confidential in nature. Management ensures that each area of client interaction is treated as confidential according to following criteria.

3.7.1 The laboratory confidentiality policy is to not divulge or release any information to a third party without proper authorization.

3.7.2 All electronic data are kept confidential, based on technology and laboratory limits, as required…