Miles City VA Phase 2 ESA Report -Final 122719.pdf

248 Copeland Street, Quincy, Massachusetts 02169; 617.481.6390 ph; 617.687.5990 fx www.AlaresEngineering.com

Achieving swift results

Neil B. Riley December 27, 2019 Engagement Manager Riley McGuire Partners, LLC 718 7th Street NW Washington D.C. 20001

Re: Phase II Environmental Site Assessment VA Medical Center Complex 210 South Winchester Avenue Miles City, Montana

Mr. Riley:

Alares Engineering, LLC (ALARES) was contracted by Riley McGuire Partners, LLC (RMP) to provide environmental due diligence services in support of the Department of Veterans Affairs (VA) Office of Construction and Facilities Management (OCFM) for the proposed transfer of the Miles City VA Medical Center (VAMC) property to Custer County, Montana. The environmental due diligence services provided by Alares included the validation of the findings presented in the prior Phase I Environmental Site Assessment (ESA) conducted at the Miles City VAMC in 2017, and the performance of a Phase II ESA for the validated Recognized Environmental Conditions (REC) from the earlier Phase I ESA.

This letter provides a summary of the Phase I ESA Validation that was provided under separate cover to the VA-OCFM, and further offers a summary of findings and recommendations from the Phase II ESA that was recently completed at the Miles City VAMC, which is included as an attachment to this letter report.

Phase I ESA Validation Summary

The intent of the Phase I ESA validation was to provide our professional opinion on the completeness and accuracy of the prior Phase I ESA Report, and the suitability of the identified RECs for use in the proposed follow-on Phase II ESA at the Miles City VAMC.

As detailed in our Validation Report, the Phase I ESA performed at the Miles City VAMC was successfully completed in accordance with ASTM Standard Practice for ESAs (E 1527-13), and based on a review of current environmental records, it was concluded that the identified RECs are still accurate and complete, and are therefore suitable for use in the proposed Phase II ESA at the subject property. These RECs identified by the Phase I ESA are summarized as follows:

Item Description

REC 1

Underground Storage Tanks (USTs)

a) Building 10, Boiler Plant, Fuel Storage USTs

b) Building 18, Emergency Generator, Fuel Storage UST

c) Historical USTs

REC 2 Building 7, High Bay Maintenance Shops, Middle Bay (A3) Automobile Repairs

REC 3 Building 7, Low Bay Maintenance Shops, Southeast Bays (B5/B6) Automobile Repairs

The Phase I ESA identified a “Data Gap” for historical USTs at the subject property. Archived records document a 1,000-gallon gasoline UST and a 5,000-gallon diesel UST that were previously removed in 1992.

A closure report for these USTs was not available for review, and locations could not be ascertained

Phase II ESA Report Cover VAMC, Miles City, MT

December 27, 2019 2 through a review of public or facility records, or staff interviews. This finding was not investigated during the Phase II ESA, and is continued as an unresolved REC for the subject property.

Although not specifically addressed in the Phase I ESA Report, the Contaminants of Concern (COCs) associated with the listed RECs include: a) Petroleum fuels and heating oil (UST RECs); and b) fuels, oil, lubricants, solvents and degreasers, and heavy metals (Automotive Repair RECs). These COCs are sufficiently addressed in the attached Phase II ESA Report for the Miles City VAMC.

Phase 2 ESA Findings

The intent of the Phase II ESA performed at the Miles City VAMC was to identify the Presence/Absence of COCs at the previously identified RECs associated with Building 7, Building 10 and Building 18. Based on the findings from this Phase II ESA, the RECs associated with Building 7 Automobile Repairs, and the Building 18 Emergency Generator UST have been excluded from further concern (i.e., absence of COCs in soil and groundwater). The REC associated with the Building 10 Boiler Plant USTs cannot be excluded from further concern given that petroleum fuels related COCs were identified in one of the soil borings at this location (refer to the attached Phase II Report for details).

Although evidence of localized impact from petroleum hydrocarbons was discovered at the Building 10 Boiler Plant USTs (i.e., presence of COCs), the potential vertical and lateral extent of impact cannot be ascertained from the current findings, and additional investigation may be warranted.

Please note that the findings at Building 10 Boiler Plant USTs is not believed to be resultant from current fuel storage operations, but rather residual impacts associated with historical UST activities. Further note that the presence of a concrete holding pad located below the existing USTs prevented further soil evaluation at this location.

If you have any questions or concerns with this Report, please do not hesitate to contact me directly at

(774) 272-2791 or mbundy@alaresllc.com.

Sincerely, Alares Engineering

Mike Bundy, CHMM Senior Scientist / Project Manager

Attachment: Final Phase II Environmental Site Assessment Report, VA Medical Center, Miles City, MT, 4 December 2019, Terracon Consultants, Inc. (Project No. 26197083).

Phase II Environmental Site Assessment Report

Miles City VA Medical Center

210 South Winchester Avenue

Miles City, Custer County, Montana December 4, 2019

Terracon Project No. 26197083

Prepared for:

Alares Engineering

Quincy, Massachusetts

Prepared by:

Terracon Consultants, Inc.

Billings, Montana

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TABLE OF CONTENTS

Page No.

1.0 INTRODUCTION

1.1 Site Description

1.2 Site Background

1.3 Scope of Work

1.4 Standard of Care

1.5 Additional Scope Limitations

1.6 Reliance

2.0 FIELD ACTIVITIES

2.1 Borings and Monitoring Wells

2.2 Soil and Groundwater Sampling

3.0 LABORATORY ANALYTICAL METHODS

4.0 DATA EVALUATION

4.1 Soil Samples

4.2 Groundwater Samples

5.0 FINDINGS

6.0 RECOMMENDATIONS

LIST OF APPENDICES

Appendix A: Exhibit 1 – Topographic Map Exhibit 2 – Site Diagram Exhibit 3 – Photograph Log

Appendix B: Boring Logs

Appendix C: Table 1 – Soil Analytical Summary (VPH, EPH, and VOCs) Table 2 – Soil Analytical Summary (PAHs) Table 3 – Soil Analytical Summary (RCRA Metals) Table 4 – Groundwater Analytical Summary (VPH, EPH, and RCRA Metals)

Appendix D: Laboratory Data Sheets

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PHASE II ENVIRONMENTAL SITE ASSESSMENT

Miles City VA Medical Center 8018 US Highway 93

MILES CITY, MONTANA

Terracon Project No. 26197083 December 4, 2019

1.0 INTRODUCTION

1.1 Site Description

Site Name Miles City Veterans Affairs Medical Center Site Location/Address 210 South Winchester Avenue, Miles City, Montana

General Site Description

The site consists of a 14.486-acre tract developed with twelve buildings totaling approximately 175,000 square feet and associated asphalt parking and landscaped grounds.

The site currently operates as a medical center for the U.S.

Department of Veterans Affairs. In addition, the Miles City Police Department, Montana Highway Patrol, OneHealth, Victory Insurance, Miles City Soup Kitchen, and Miles City Food Bank operate on the premises. Stevenson and Sons Funeral Home also operates a crematorium on-site.

A topographic map depicting the location of the site is included as Exhibit 1 (Appendix A), site plan depicting the site sampling locations are included as Exhibit 2 (Appendix A), and a photograph log as Exhibit 3 (Appendix A).

1.2 Site Background

Terracon Consultants, Inc. (Terracon) conducted a Phase II Environmental Site Assessment (ESA) at the Miles City VA Medical Center facility located at 210 South Winchester Avenue in Miles City, Montana (site). At your request, Terracon’s Phase II ESA was undertaken to assess the recognized environmental conditions (RECs) and/or site concerns identified in Terracon’s Phase I ESA entitled Phase I Environmental Site Assessment: Miles City VA Medical Center / 210 South Winchester Avenue, Miles City, Montana dated October 18, 2017 (Terracon Project No. 26177079).

The Phase I indicated that currently there are two 12,000-gallon diesel USTs, one 4,000-gallon diesel UST, and one temporarily out of use 2,000-gallon diesel UST on-site. Historically, there was a 1,000-gallon gasoline UST, 5,000-gallon diesel UST, and 2,500-gallon diesel UST on-site. Confirmation samples only exist for the removal of the 2,500-gallon UST. However, the sampling protocol completed at the time of the UST removal did not meet current Montana Department of Environmental Quality (MDEQ) standards. In addition, the former locations of the 1,000-gallon

Phase II Environmental Site Assessment Miles City VA Medical Center ■ Miles City, Montana December 4, 2019 ■ Terracon Project No. 26197083

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Based on the historic use of Building 7 being used for light automotive repair, observed staining of various automotive fluids, and age of the catch basins located in Building 7, the catch basins (one located on the western end of building and one located one the eastern end of building) represent additional RECs.

1.3 Scope of Work

The proposed scope of work included a total of four soil borings, which were converted to temporary monitoring wells, completed with direct push technology to an approximate depth of 25 feet below ground surface (bgs). One boring was located near the southern UST tank basin located next to the emergency generator building (Building 18 on site diagram map) and three borings were located near the northern UST tank basin next to the boiler plant (Building 10 on site diagram map). Additionally, a total of four soil borings were originally proposed to be advanced inside Building 7 using hand-auger equipment to an approximate depth of five feet bgs near the two catch basins. The ceiling height in Building 7 allowed direct push technology to be utilized for the completion of the borings near the two catch basins. The Site Diagram that includes the boring locations is Exhibit 2 included in Appendix A.

The sampling and analysis program included the collection one soil sample from each soil boring (eight soil samples total) and two groundwater samples. One groundwater sample collected from the temporary monitoring well located near the southern tank basin and one groundwater sample collected from one of the three temporary monitoring wells installed near the northern tank basin based on groundwater gradient if environmental impacts were not indicated.

The object of this Phase II ESA was to evaluate the presence of volatile petroleum hydrocarbons (VPH), extractable petroleum hydrocarbons (EPH), polycyclic aromatic hydrocarbons (PAHs), Resource Conservation and Resource (RCRA) metals, and volatile organic compounds (VOCs) in the on-site soils and groundwater at concentrations above relevant laboratory reporting limits.

Terracon’s Phase II ESA was conducted in accordance with Terracon Proposal No. P26197083, dated June 10, 2019, as authorized by Mr. Mike Bundy of Alares Engineering on October 7, 2019.

1.4 Standard of Care

Terracon’s services were performed in a manner consistent with generally-accepted practices of the profession undertaken in similar studies in the same geographical area during the same time period.

Terracon makes no warranties, either express or implied, regarding the findings, conclusions or recommendations. Please note that Terracon does not warrant the work of laboratories, regulatory agencies or other third parties supplying information used in the preparation of the report.

These services were performed in accordance with the scope of work agreed with you, our client, as set forth in our proposal and were intended to be in conformance with ASTM E1903-11.

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1.5 Additional Scope Limitations

Findings, conclusions and recommendations resulting from these services are based upon information derived from the on-site activities and other services performed under this scope of work;

such information is subject to change over time. Certain indicators of the presence of hazardous substances, petroleum products, or other constituents may have been latent, inaccessible, unobservable, nondetectable or not present during these services, and we cannot represent that the site contains no hazardous substances, toxic materials, petroleum products, or other latent conditions beyond those identified during this ESA. Subsurface conditions may vary from those encountered at specific borings or wells or during other surveys, tests, assessments, investigations or exploratory services; the data, interpretations, findings, and our recommendations are based solely upon data obtained at the time and within the scope of these services.

1.6 Reliance

This report has been prepared for the exclusive use of Alares Engineering and the U.S. Department of Veterans Affairs, and any authorization for use or reliance by any other party (except a governmental entity having jurisdiction over the site) is prohibited without the express written authorization of Alares Engineering and Terracon. Any unauthorized distribution or reuse is at the client’s sole risk. Notwithstanding the foregoing, reliance by authorized parties will be subject to the terms, conditions and limitations stated in the proposal, ESA report, and Terracon’s Terms and Conditions. The limitation of liability defined in the Terms and Conditions is the aggregate limit of Terracon’s liability to the client and all relying parties unless otherwise agreed in writing.

2.0 FIELD ACTIVITIES

2.1 Borings and Monitoring Wells

Terracon’s field activities were conducted on October 21 and 22, 2019 by Mr. Jonathan Love, a Terracon Senior Staff Hydrogeologist. As part of the approved scope of services, a total of eight soil borings (SB1 through SB8) were advanced on site with four of the borings (SB1 through SB4) converted to temporary monitoring wells. Exhibit 2 (Appendix A) is a site diagram indicating the approximate locations of the soil borings and temporary monitoring wells in relation to the pertinent structures and general site boundaries.

A total of eight soil borings were advanced utilizing direct push technology with a track-mounted drill rig. The four soil borings located near the two UST basins were completed to a depth of approximately 15 feet bgs, except boring SB3, which is located south of the northern tank basin and was completed to a depth of approximately 13 feet bgs due to refusal. The refusal encountered in boring SB3 is assumed to be concrete anchoring pad and is possibly the bottom of a tank vault.

Further investigation would be needed to determine the extent of the concrete.

Four additional soil borings were advanced to a depth of approximately 10 feet bgs near the two catch basins in Building 7. Two soil borings were completed south of Building 7 on the eastern end of the building to assess the eastern catch basin and two soil borings were completed inside Building 7 in the bay containing the western catch basin. The four borings completed at Building 7 were

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Drilling services were performed using a track-mounted drilling rig using direct push technologies under the supervision of a Terracon environmental scientist, a State of Montana licensed monitoring well constructor. Soil samples were collected using five-foot macro core barrel samplers. Drilling core-barrel samplers were cleaned using an Alconox® wash and potable water rinse prior to the beginning of the project and before collecting each soil sample. Soil samples were collected continuously and observed to document soil lithology, color, moisture content and sensory evidence of impairment. The soil samples were field-screened using a photoionization detector (PID – Ion Science PhoCheck® Tiger) to indicate the presence of VOCs.

The general soil lithology encountered during Terracon’s sample collection event consisted of variable amounts and alternating layers of clay, silt, sand, and gravels below the ground surface to the maximum depth explored of 15 feet bgs. Groundwater was encountered at depths ranging from approximately 5.5 to 10 feet bgs during drilling. Detailed lithologic descriptions are presented on the soil boring logs included in Appendix B.

Petroleum staining and odor was detected in the soil sample collected at the bottom of boring SB3 from approximately 12.75 to 13 feet bgs where refusal was encountered. There was not a sufficient amount of soil to collect a PID reading from the stained interval. PID readings ranging from 0.0 to 0.1 parts per million (ppm) were detected in soil samples collected from the eight soil borings. PID readings are included on the soil boring logs presented in Appendix B.

Subsequent to advancement, soil borings SB1, SB2, SB3, and SB4 were converted to temporary groundwater monitoring wells. The temporary monitoring wells were completed using the following methodology:

n Installation of 10 feet of 1-inch diameter, 0.010-inch machine-slotted PVC well screen with a threaded bottom cap;

n Installation of 1-inch diameter, threaded, flush-joint PVC riser pipe to the surface;

n Addition of a pre-sieved 10/20-grade annular silica sand pack from the bottom of the boring to approximately 1 foot above the top of the well screen.

The monitoring well construction details are presented on the soil boring logs for these monitoring wells, which are included in Appendix B.

Following sample collection, all temporary monitoring well casings were removed. Soil boring SB1 was backfilled with bentonite pellets and then hydrated to surface grade. Soil borings SB2 through SB8 were also backfilled with bentonite pellets, hydrated and capped with concrete at the surface.

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2.2 Soil and Groundwater Sampling

Terracon's soil sampling program involved submitting one soil sample from each soil boring for laboratory analysis. The soil samples were collected from the interval exhibiting the highest PID reading or at the capillary fringe zone. Deviations from the proposed soil sampling program were directed by Mike Bundy and include:

n One additional soil sample was collected from the bottom of soil boring SB3 and submitted for laboratory analysis due to petroleum staining observed in at the bottom of the boring.

n A soil sample was not submitted for laboratory analysis from soil boring SB8 completed near the western catch basin in Building 7. Since soil borings SB7 and SB8 were completed in the general vicinity of one another in the same bay and neither boring exhibited field screening evidence of contamination, only the downgradient soil boring (SB7) located closest to the sump was submitted for laboratory analysis.

Soil samples were labeled with the boring number and collection depth. For example, soil sample SB1/9.5 was collected from soil boring SB1 at a depth of approximately 9.5 feet bgs. Soil sample intervals for each boring are provided on the lithologic boring logs included in Appendix B.

Prior to sampling, temporary monitoring wells MW1 and MW3 were developed by surging and removing approximately three to four gallons of groundwater with a peristaltic pump until groundwater was relatively free of fine-grained sediment. The temporary monitoring wells were also allowed to recover for a minimum of three hours prior to sampling procedures. Groundwater samples were collected using low-flow sampling techniques with a YSI multi-parameter flow cell, peristaltic pump and disposable tubing. One groundwater sample was collected from the temporary monitoring well MW1 (SB1) completed near the southern tank basin and one groundwater sample was collected from temporary monitoring well MW3 (SB3) completed near the northern tank basin and submitted for laboratory analysis.

Based on the temporary nature of the temporary monitoring wells and the potential for elevated turbidity in the groundwater samples, a turbidity meter was utilized during the sampling process.

Groundwater sample Temp MW1 exhibited turbidity readings below 10 NTUs and groundwater sample Temp MW3 exhibited turbidity readings above 10 NTUs at the time of sampling. Based on the elevated turbidity readings, both groundwater samples were filtered prior to preservation and RCRA metals analysis.

Soil and groundwater samples were collected into laboratory-prepared glassware containing the appropriate preservative, labeled, and placed on ice in sample coolers.

The sample coolers and completed chain-of-custody forms were relinquished to Pace Analytical Laboratories in Billings, Montana for analysis on normal turnaround.

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3.0 LABORATORY ANALYTICAL METHODS

The eight soil samples collected from soil borings SB1 through SB7 were analyzed for VPH by the Montana-modified Massachusetts Method, EPH Screen by the Montana-modified Massachusetts Method, and RCRA Metals by Environmental Protection Agency (EPA) Method 6010. Based on the initial EPH screen results, soil sample SB3/12.75 was submitted for fractionated EPH and PAHs by EPA Method 8270D. Additionally, based on the history of vehicle maintenance performed in Building 7, the soil samples collected from borings SB5 through SB7 were also analyzed for VOC by EPA Method 8260.

The two groundwater samples collected from temporary monitoring wells were analyzed for VPH by the Montana-modified Massachusetts Method, EPH Screen by the Montana-modified Massachusetts Method, and RCRA Metals by EPA Method 6020. Laboratory results are summarized in the tables included in Appendix C and the executed chain-of-custody forms and laboratory data packages are provided in Appendix D.

4.0 DATA EVALUATION

Terracon initially compared the detected VPH, EPH Screen, PAHs, RCRA metals and VOCs chemical of concern (COC) concentrations to the Montana Tier 1 Default Risk-Based Screening Levels (RBSLs) for residential surface soil (<2 feet), less than 10 feet to groundwater from the sample depth as defined in the Montana Tier 1 Risk-Based Corrective Action Guidance for Petroleum Releases by the MDEQ, dated May 2018. If the sample was collected at a depth deeper than two feet bgs and exceeded the initial screening level, the soil samples were compared to the Montana Tier 1 RBSLs for subsurface soil (>2 feet), 10 to 20 feet to groundwater from the sample depth.

In addition to a comparison to the MDEQ RBSLs, the detected PAHs concentrations were compared to the modified EPA Regional Screening Levels (RSLs) for residential soils obtained using MDEQ parts 1 and 2 of Attachment C – Soil Screening Process and the EPA RSLs, dated April 2019 and the MDEQ Standardized Cleanup Report for Spills or Releases that Impact Soil, dated June 2015.

The detected metals concentrations in soils were also compared to their Montana Background Study Investigation (MBSI) levels, dated September 2013. In cases where the MBSI is greater than the RBSL, the action level is the MBSI.

Terracon compared the detected COCs from the groundwater samples to the MDEQ Tier 1 RBSLs for groundwater Montana Tier 1 Risk-Based Corrective Action Guidance for Petroleum Releases, by the MDEQ, dated May 2018, and the MDEQ Groundwater Human Health Standard, Circular DEQ-7, Montana Numeric Water Quality Standards, dated October 2012.

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4.1 Soil Samples

VPH Analysis

VPH compounds were not detected above the laboratory analytical reporting limits in any of the soil samples analyzed. Estimated concentrations detected above the adjusted method detection limit and below the adjusted reporting limit include: C9-C12 aliphatics in all soil samples at estimated concentrations ranging from 0.0055 milligrams per kilogram (mg/kg) to 3.1 mg/kg; C9-C10 aromatics (estimated at 1.1 mg/kg) and total petroleum hydrocarbons (estimated at 6.2 mg/kg) were detected in soil sample SB3/12.75. The results of the VPH soils analysis are summarized in Table 1 of Appendix C. The results of the VPH soils analysis are provided in Appendix D.

EPH and PAH Analysis

EPH screen concentrations in soil sample SB1/9.5 were not indicated above the laboratory analytical reporting limits. Soil samples SB2/7.5, SB4/5.5, SB5/6, SB6/6, and SB7/9 exhibited estimated concentrations ranging from 4.0 mg/kg to 5.1 mg/kg detected above the adjusted method detection limit but below the adjusted reporting limit.

The two soil samples collected from boring SB3 exhibited EPH Screen concentrations of 19.5 mg/kg in soil sample SB3/7.5 and 797 mg/kg in soil sample SB3/12.75. The EPH screen concentration detected in soil sample SB3/12.75 exceeded the EPH screening level of 200 mg/kg and was submitted for fractionation analysis with PAHs. All EPH compounds were detected above the laboratory detection limit in the fractionation analysis of soil sample SB3/12.75. The detected C9-C18 aliphatic concentration of 280 mg/kg exceeded the default Tier 1 RBSL for surface soil, less than 10 feet to groundwater (110 mg/kg) but did not exceed the Tier 1 RBSL for subsurface soil, less than 10 feet to ground water of 900 mg/kg.

After an initial review of the EPH fractionation data, soil sample SB3/12.75 was submitted for PAH analysis. Various PAH compounds were detected above the laboratory analytical reporting limit.

Dibenz(a,h)anthracene and naphthalene concentrations were detected with estimated concentrations above the method detection limit but below the laboratory analytical reporting limit. Detected PAH concentrations did not exceed their respective RBSLs or RSLs.

The results of the EPH soils analysis are summarized in Table 1 and the PAH soils analysis are summarized in Table 2 in Appendix C. The results of the EPH and PAH soils analysis are provided in Appendix D.

RCRA Metals Analysis

Various RCRA metals including arsenic, barium, cadmium, chromium, lead, mercury and selenium were detected at concentrations above their laboratory reporting limits in the soil samples collected at the site. Refer to Table 3 in Appendix C for a complete summary of the metals soil analytical results. The results of the RCRA metals soils analysis are provided in Appendix D.

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Terracon compared the metals concentrations detected in the soil samples to their applicable action levels. The metals concentrations did not exceed applicable action level, with the exception of arsenic detected in soil sample SB3/12.75. The detected concentration of arsenic (24.3 mg/kg) exceeded both the MDEQ screening level of 0.68 mg/kg and the MBSI level of 22.5 mg/kg. The detected concentration of lead (140 mg/kg) did exceed the MBSI level of 29.8 mg/kg and equaled but did not exceed the MDEQ screening level.

VOC Analysis

The three soil samples submitted for VOC analysis (SB5/6, SB6/6, and SB7/9) did not exhibit and VOC concentrations above the laboratory analytical reporting limits. The results of the VOC soils analysis are provided in Appendix D.

4.2 Groundwater Samples

VPH Analysis

VPH compounds were not detected above the laboratory analytical reporting limits in any of the groundwater samples submitted. Estimated concentrations detected above the adjusted method detection limit and below the adjusted reporting limit include: C9-C12 aliphatics in all groundwater samples at estimated concentrations ranging from 1E-10 micrograms per liter (µg/L) to 0.084 µg/L and C5-C8 aliphatics at an estimated concentration of 0.22 µg/L in groundwater sample Temp MW3.

The results of the VPH groundwater analysis are summarized in Table 4 of Appendix C. The results of the VPH groundwater analysis are provided in Appendix D.

EPH Analysis

The groundwater sample Temp MW1 collected from the only temporary monitoring well located near the southern tank basin did not exhibit an EPH screen concentration above the laboratory analytical reporting limit. An EPH screen concentration of 417 µg/L was detected in groundwater sample Temp MW3 collected near the northern tank basin; however, it did not exceed the required 1,000 µg/L for fractionation analysis. The results of the EPH groundwater analysis are summarized in Table 4 of Appendix C. The results of the EPH groundwater analysis are provided in Appendix D.

RCRA Metals Analysis

RCRA metals were not detected in any of the groundwater samples submitted at concentrations exceeding their respective Tier 1 Groundwater RBSLs and Standards, with the exception of arsenic which was detected in groundwater sample Temp MW3 at a concentration of 25.1 µg/L, exceeding the MDEQ screening level of 10 µg/L. The results of the RCRA metals groundwater analysis are summarized in Table 4 of Appendix C. The results of the RCRA metals groundwater analysis are provided in Appendix D.

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5.0 FINDINGS

The findings of this investigation are as follows:

n VPH compounds were not detected in the on-site soils in soil samples collected from soil borings at concentrations exceeding their respective Tier 1 RBSLs for subsurface soil, less than 10 feet to groundwater.

n Soil sample SB3/12.75 collected at approximately 12.75 feet bgs from soil boring SB3 near the northern tank basin was the only soil sample submitted for EPH fractionation analysis with PAHs based on a detected EPH screen concentration of 797 mg/kg. C9-C18 aliphatics concentration detected in the soil sample exceeded the Tier 1 default RBSL for surface soil, less than 10 feet to groundwater of 110 mg/kg, but did not exceed the Tier 1 RBSL for subsurface soil (>2 feet bgs), less than 10 feet to groundwater of 900 mg/kg. PAHs were not detected at concentrations exceeding their respective Tier 1 RBSLs for subsurface soil, less than 10 feet to groundwater.

n VOCs were not detected at concentrations above the laboratory analytical reporting limits in any of the soil samples submitted.

n Soil sample SB3/12.75 was the only soil sample to exhibit a RCRA metal concentration above screening levels. Arsenic was detected at a concentration of

24.3 mg/kg, exceeding the applicable action level of 22.5 mg/kg.

n VPH and EPH compounds were not detected in the groundwater samples submitted above their respective Tier 1 RBSLs for groundwater.

n The concentration of arsenic (25.1 µg/L) detected in groundwater sample Temp MW3 exceeded the MDEQ screening level of 10 µg/L. The remaining RCRA metals were not detected above the applicable MDEQ screening levels.

6.0 RECOMMENDATIONS

n The localized concentration of arsenic detected in the soil sample collected at the bottom of the boring and the groundwater sample collected from boring SB3/MW3 near the northern tank basin and Building 10 is possibly the result of concrete material encountered drilling activities when refusal occurred due to the presence of what is assumed to be a concrete tank anchor pad.

n It was stated by maintenance personnel during the on-site field activities that the existing USTs on site are gauged regularly and the data indicates that the tanks are tight and not releasing product. The localized impacts detected in boring SB3 near

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n The intent of this Phase II ESA was to identify the presence or absence of COCs for previously determined RECs identified in the Phase I ESA in the on-site soils and groundwater above the relevant laboratory reporting limits. Concluded objectives eliminated all RECs, except near boring SB3 near the northern tank basin and building 10 where suspect petroleum impacts likely associated with the historical USTs were detected. While the impacts were delineated horizontally near the northern tank basin and building 10, further contamination may remain due to the presence of the concrete tank anchor pad.

n If soils or groundwater located on the site are to be disturbed during tank removals, future excavations or construction activities, proper procedures should be followed with a soil and groundwater sampling plan; respect to worker health and safety; and any affected soil or groundwater encountered should be properly characterized, treated and/or disposed in accordance with applicable local, state or federal regulations.

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APPENDIX A

Exhibit 1 – Topographic Map

Exhibit 2 – Site Diagram

Exhibit 3 – Photograph Log

TOPOGRAPHIC MAP

Miles City VA Medical Center 210 South Winchester Avenue

Miles City, MT

TOPOGRAPHIC MAP IMAGE COURTESY OF THE U.S. GEOLOGICAL SURVEY

QUADRANGLES INCLUDE: MILES CITY, MT (1/1/1980).

2110 Overland Ave Ste 124 Billings, MT 59102-6440

26197083 Project Manager:

Drawn by:

Checked by:

Approved by:

JWL

RRS

RRS

1”=2,000’ Exhibit

Dec 2019

Project No.

Scale:

File Name:

Date:

Exhibit JWL

APPROXIMATE

SITE BOUNDARY

SITE DIAGRAM

2110 Overland Ave, Ste 124 Billings, MT 59102-6440

26197083 AERIAL PHOTOGRAPHY PROVIDED BY

GOOGLE EARTH MAPS

Miles City VA Medical Center 210 South Winchester Avenue

Miles City, MT

DIAGRAM IS FOR GENERAL LOCATION ONLY,

AND IS NOT INTENDED FOR CONSTRUCTION

PURPOSES

Project Manager:

Drawn by:

Checked by:

Approved by:

JWL

RSS

RSS

JWL

Exhibit 2

Dec 2019

Scale:

Project No.

File Name:

Date:

AS SHOWN

Exhibit

SB2

.00

SB3

.00

SB4

.00

SB1

.00

SB7

.00

SB8

.00

SB5

.00

SB6

.00

LEGEND

Catch Basin

Soil Boring w/Temporary Monitoring Well Installed

Soil Boring

Building Number

Northern Tank Basin

Southern Tank Basin

PHOTO # 2: View looking east of soil borings near northern tank basin. (10/22/19)

TRACT 40

F O R M E R Y E L LO W F R E I G H T T E R M I N A L

P E P S I

PHOTO # 1: View looking northeast during drilling activities of soil boring SB1 near the southern tank basin.

(10/21/19)

TRACT 40

P E P S I

Project No. 26197083 – Miles City VA Medical Center, Miles City, Montana

SB4

SB3

SB2

PHOTO # 4: View looking south of soil boring SB3. (10/22/19)

Project No. 26197083 – Miles City VA Medical Center, Miles City, Montana

PHOTO # 3: View looking west of soil boring SB2. (10/22/19)

SB2

SB3

PHOTO # 5: View looking east of soil boring SB4. (10/22/19)

PHOTO # 6: View looking north of soil boring SB5 and SB6 locations during drilling activities of soil boring SB5.

(10/22/19)

SB4

SB6

PHOTO # 7: View looking north of bay with catch basin and sump and soil boring SB7 and SB8 locations. (10/22/19)

SB7

SB8

APPENDIX B

Boring Logs

0.4

3.0

6.3

7.0

9.0 9.5 10.0

15.0

TOPSOIL

SANDY LEAN CLAY (CL), low plasticity, dark brown, moist, @ 2' coarse gravel clasts (~10%)

SILTY SAND (SM), fine grained, subangular, brown, moist

SANDY LEAN CLAY (CL), low to medium plasticity, brown, moist

POORLY GRADED SAND (SP), fine grained, subangular, light brown, moist

SILTY SAND (SM), fine grained, subangular, brown, moist POORLY GRADED SAND (SP), fine grained, subangular, brown, moist WELL GRADED SAND WITH GRAVEL (SW), fine to coarse grained, subangular, brown, wet, ~15% fine gravel

@ 12.5' one coarse gravel clast observed

Boring Terminated at 15 Feet

0.0

0.0 SB1/9.5

1" SCHD 40

PVC RISER

10/20 SAND

1' SCHD 40

PVC SCREEN

0.010" SLOT

LOCATION

DEPTH

The stratification lines represent the approximate transition between differing soil types and/or rock types; in-situ these transitions may be gradual or may occur at different depths than shown.

G R

AP

H

IC

L

O G See Exhibit A-2

TH

IS

B O

R

IN

G L

O G

IS

N

O T

VA

LI

D

IF

S

EP

AR

AT

ED

F

R O

M O

R

IG

IN

AL

R

EP

O R

T.

E

N

VI

R O

N M

EN

TA

L

SM

AR

T

LO

G

3_

BO

R

IN

G L

O G

S.

G

PJ

T

ER

R

AC

O

N _D

AT

AT

EM

PL

AT

E.

G D

T

1/

/1

T8N, R27E, Sec 34 Miles City, Montana

SITE:

Advancement Method:

Dircet Push

Abandonment Method:

Boring backfilled with bentonite chips upon completion.

Notes:

Project No.: 26197083

Drill Rig: Geoprobe 7822DT

Well Started: 10-21-2019

WELL LOG NO. SB1

Alares Engineering

Driller: Donnie Zier

Well Completed: 10-21-2019

Exhibit:

CLIENT:

Quincy, MA

LOGGER: Jonathan W. Love, Field Geologist Billings, MT

PROJECT: Miles City VA Clinic

B-1

MATERIAL DESCRIPTION

O

VA

/P

ID

(p pm

SA

M

PL

E

SE

N

T

TO

L

AB

(ID

N

U M

BE

R

D

EP

TH

(f t)

W

AT

ER

L

EV

EL

O

BS

ER

VA

TI

O

N S

SA

M

PL

E

TY

PE

Well Completion:

Temporary Well

INSTALLATION DETAILS

At time of drilling

WATER LEVEL OBSERVATIONS

0.7

5.0

6.5

8.0

9.0

10.0

15.0

CONCRETE

WELL GRADED GRAVEL WITH SAND (GW), fine to coarse grained, brown, moist, Possible fill material

Note: ~1.5' of recovery from 0'-5'

SILTY SAND (SM), fine grained, subangular, brown, moist

SILTY CLAYEY SAND (SC-SM), fine grained, subangular, brown, moist, @ 7.5' Dark Brown in color

SILTY SAND (SM), fine grained, subangular, light brown, wet

POORLY GRADED SAND (SP), fine to medium grained, subangular, light brown, wet

WELL GRADED SAND (SW), fine to coarse grained, subangular, dark brown, wet

Boring Terminated at 15 Feet

0.0

0.1 SB2/7.5

1" SCHD 40

PVC RISER

10/20 SAND

1' SCHD 40

PVC SCREEN

0.010" SLOT

LOCATION

DEPTH

The stratification lines represent the approximate transition between differing soil types and/or rock types; in-situ these transitions may be gradual or may occur at different depths than shown.

G R

AP

H

IC

L

O G See Exhibit A-2

TH

IS

B O

R

IN

G L

O G

IS

N

O T

VA

LI

D

IF

S

EP

AR

AT

ED

F

R O

M O

R

IG

IN

AL

R

EP

O R

T.

E

N

VI

R O

N M

EN

TA

L

SM

AR

T

LO

G

3_

BO

R

IN

G L

O G

S.

G

PJ

T

ER

R

AC

O

N _D

AT

AT

EM

PL

AT

E.

G D

T

1/

/1

T8N, R27E, Sec 34 Miles City, Montana

SITE:

Advancement Method:

Direct Push

Abandonment Method:

Boring backfilled with bentonite Surface capped with concrete

Notes:

Project No.: 26197083

Drill Rig: Geoprobe 7822DT

Well Started: 10-22-2019

WELL LOG NO. SB2

Alares Engineering

Driller: Donnie Zier

Well Completed: 10-22-2019

Exhibit:

CLIENT:

Quincy, MA

LOGGER: Jonathan W. Love, Field Geologist Billings, MT

PROJECT: Miles City VA Clinic

B-2

MATERIAL DESCRIPTION

O

VA

/P

ID

(p pm

SA

M

PL

E

SE

N

T

TO

L

AB

(ID

N

U M

BE

R

D

EP

TH

(f t)

W

AT

ER

L

EV

EL

O

BS

ER

VA

TI

O

N S

SA

M

PL

E

TY

PE

Well Completion:

Temporary Well

INSTALLATION DETAILS

0.5

13.0

CONCRETE

SANDY GRAVEL (GW), fine to coarse grained, brown, moist, Possible fill material

@ 8' Wet

@ 12.75' Black and Gray petroleum staining observed, slight petroleum odor, pieces of concrete observed Boring Refusal at 13 Feet

0.0

0.1 SB3/7.5

SB3/12.57

1" SCHD 40

PVC RISER

10/20 SAND

1' SCHD 40

PVC SCREEN

0.010" SLOT

LOCATION

DEPTH

The stratification lines represent the approximate transition between differing soil types and/or rock types; in-situ these transitions may be gradual or may occur at different depths than shown.

G R

AP

H

IC

L

O G See Exhibit A-2

TH

IS

B O

R

IN

G L

O G

IS

N

O T

VA

LI

D

IF

S

EP

AR

AT

ED

F

R O

M O

R

IG

IN

AL

R

EP

O R

T.

E

N

VI

R O

N M

EN

TA

L

SM

AR

T

LO

G

3_

BO

R

IN

G L

O G

S.

G

PJ

T

ER

R

AC

O

N _D

AT

AT

EM

PL

AT

E.

G D

T

1/

/1

T8N, R27E, Sec 34 Miles City, Montana

SITE:

Advancement Method:

Direct Push

Abandonment Method:

Boring backfilled with bentonite Surface capped with concrete

Notes:

Project No.: 26197083

Drill Rig: Geoprobe 7822DT

Well Started: 10-22-2019

WELL LOG NO. SB3

Alares Engineering

Driller: Donnie Zier

Well Completed: 10-22-2019

Exhibit:

CLIENT:

Quincy, MA

LOGGER: Jonathan W. Love, Field Geologist Billings, MT

PROJECT: Miles City VA Clinic

B-3

MATERIAL DESCRIPTION

O

VA

/P

ID

(p pm

SA

M

PL

E

SE

N

T

TO

L

AB

(ID

N

U M

BE

R

D

EP

TH

(f t)

W

AT

ER

L

EV

EL

O

BS

ER

VA

TI

O

N S

SA

M

PL

E

TY

PE

Well Completion:

Temporary Well

INSTALLATION DETAILS

0.6

2.0

4.5 5.0 5.5

12.5

13.5

15.0

CONCRETE

SILTY SAND (SM), fine to coarse grained, subangular, dark brown, moist

POORLY GRADED SAND (SP), fine to medium grained, subangular, brown, moist, Note: ~3' of recovery from 0'-5'

CLAYEY SAND (SC), fine to medium grained, subangular, dark brown, moist SANDY LEAN CLAY (CL), low plasticity, dark brown, moist SILTY SAND (SM), fine to medium grained, subangular, dark brown, wet

CLAYEY SAND (SC), fine grained, subangular, dark brown, wet

WELL GRADED SAND (SW), fine to coarse grained, subangular, dark brown, wet, @ 14' Brown in color

Boring Terminated at 15 Feet

0.1

0.0 SB4/5.5

1" SCHD 40

PVC RISER

10/20 SAND

1' SCHD 40

PVC SCREEN

0.010" SLOT

LOCATION

DEPTH

The stratification lines represent the approximate transition between differing soil types and/or rock types; in-situ these transitions may be gradual or may occur at different depths than shown.

G R

AP

H

IC

L

O G See Exhibit A-2

TH

IS

B O

R

IN

G L

O G

IS

N

O T

VA

LI

D

IF

S

EP

AR

AT

ED

F

R O

M O

R

IG

IN

AL

R

EP

O R

T.

E

N

VI

R O

N M

EN

TA

L

SM

AR

T

LO

G

3_

BO

R

IN

G L

O G

S.

G

PJ

T

ER

R

AC

O

N _D

AT

AT

EM

PL

AT

E.

G D

T

2/ 3/

T8N, R27E, Sec 34 Miles City, Montana

SITE:

Advancement Method:

Direct Push

Abandonment Method:

Boring backfilled with bentonite Surface capped with concrete

Notes:

Project No.: 26197083

Drill Rig: Geoprobe 7822DT

Well Started: 10-22-2019

WELL LOG NO. SB4

Alares Engineering

Driller: Donnie Zier

Well Completed: 10-22-2019

Exhibit:

CLIENT:

Quincy, MA

LOGGER: Jonathan W. Love, Field Geologist Billings, MT

PROJECT: Miles City VA Clinic

B-4

MATERIAL DESCRIPTION

O

VA

/P

ID

(p pm

SA

M

PL

E

SE

N

T

TO

L

AB

(ID

N

U M

BE

R

D

EP

TH

(f t)

W

AT

ER

L

EV

EL

O

BS

ER

VA

TI

O

N S

SA

M

PL

E

TY

PE

Well Completion:

Temporary Well

INSTALLATION DETAILS

5.0

6.5

10.0

CONCRETE

SILTY SAND WITH GRAVEL (SM), fine grained, subangular, brown, moist, ~15% fine gravel

@ 4' Silt amount increasing

SANDY LEAN CLAY (CL), low plasticity, light brown, moist

SILTY SAND (SM), fine grained, subangular, light brown, wet

Boring Terminated at 10 Feet

0.0

0.0 SB5/6

LOCATION

DEPTH

The stratification lines represent the approximate transition between differing soil types and/or rock types; in-situ these transitions may be gradual or may occur at different depths than shown.

G R

AP

H

IC

L

O G See Exhibit A-2

TH

IS

B O

R

IN

G L

O G

IS

N

O T

VA

LI

D

IF

S

EP

AR

AT

ED

F

R O

M O

R

IG

IN

AL

R

EP

O R

T.

E

N

VI

R O

N M

EN

TA

L

SM

AR

T

LO

G

3_

BO

R

IN

G L

O G

S.

G

PJ

T

ER

R

AC

O

N _D

AT

AT

EM

PL

AT

E.

G D

T

1/

/1

T8N, R27E, Sec 34 Miles City, Montana

SITE:

Advancement Method:

Direct Push

Abandonment Method:

Boring backfilled with bentonite Surface capped with concrete

Notes:

Project No.: 26197083

Drill Rig: Geoprobe 7822DT

Boring Started: 10-22-2019

BORING LOG NO. SB5

Alares Engineering

Driller: Donnie Zier

Boring Completed: 10-22-2019

Exhibit:

CLIENT:

Quincy, MA

LOGGER: Jonathan W. Love, Field Geologist Billings, MT

PROJECT: Miles City VA Clinic

B-5

MATERIAL DESCRIPTION

O

VA

/P

ID

(p pm

SA

M

PL

E

SE

N

T

TO

L

AB

(ID

N

U M

BE

R

D

EP

TH

(f t)

W

AT

ER

L

EV

EL

O

BS

ER

VA

TI

O

N S

SA

M

PL

E

TY

PE

2.0

3.0

10.0

CONCRETE

SILTY SAND WITH GRAVEL (SM), fine grained, subangular, dark brown, moist, ~15% fine gravel

SANDY LEAN CLAY (CL), low plasticity, light brown, moist

SILTY SAND (SM), fine grained, subangular, brown, moist, @ 4' Light Brown in color

@ 6.5' Wet

Boring Terminated at 10 Feet

0.0

0.1 SB6/6

LOCATION

DEPTH

The stratification lines represent the approximate transition between differing soil types and/or rock types; in-situ these transitions may be gradual or may occur at different depths than shown.

G R

AP

H

IC

L

O G See Exhibit A-2

TH

IS

B O

R

IN

G L

O G

IS

N

O T

VA

LI

D

IF

S

EP

AR

AT

ED

F

R O

M O

R

IG

IN

AL

R

EP

O R

T.

E

N

VI

R O

N M

EN

TA

L

SM

AR

T

LO

G

3_

BO

R

IN

G L

O G

S.

G

PJ

T

ER

R

AC

O

N _D

AT

AT

EM

PL

AT

E.

G D

T

1/

/1

T8N, R27E, Sec 34 Miles City, Montana

SITE:

Advancement Method:

Direct Push

Abandonment Method:

Boring backfilled with bentonite Surface capped with concrete

Notes:

Project No.: 26197083

Drill Rig: Geoprobe 7822DT

Boring Started: 10-22-2019

BORING LOG NO. SB6

Alares Engineering

Driller: Donnie Zier

Boring Completed: 10-22-2019

Exhibit:

CLIENT:

Quincy, MA

LOGGER: Jonathan W. Love, Field Geologist Billings, MT

PROJECT: Miles City VA Clinic

B-6

MATERIAL DESCRIPTION

O

VA

/P

ID

(p pm

SA

M

PL

E

SE

N

T

TO

L

AB

(ID

N

U M

BE

R

D

EP

TH

(f t)

W

AT

ER

L

EV

EL

O

BS

ER

VA

TI

O

N S

SA

M

PL

E

TY

PE

0.7

2.0

3.0

4.0

7.5 8.0

9.0

10.0

CONCRETE

FILL - GRAVEL (GW), fine to coarse grained SILTY SAND WITH GRAVEL (SM), fine to coarse grained, subangular, brown, moist

SANDY LEAN CLAY (SC), low plasticity, brown, moist

SILTY SAND (SM), fine grained, subangular, brown, moist

WELL GRADED SAND (SW), fine to coarse grained, subangular, light brown, moist, ~10% fine gravel

SILTY SAND (SM), fine grained, subangular, brown, moist WELL GRADED SAND (SW), fine to coarse grained, subangular, brown, moist

SILTY SAND (SM), fine grained, subangular, brown, moist, @ 9.5' Wet

Boring Terminated at 10 Feet

0.0

0.0 SB7/9

LOCATION

DEPTH

The stratification lines represent the approximate transition between differing soil types and/or rock types; in-situ these transitions may be gradual or may occur at different depths than shown.

G R

AP

H

IC

L

O G See Exhibit A-2

TH

IS

B O

R

IN

G L

O G

IS

N

O T

VA

LI

D

IF

S

EP

AR

AT

ED

F

R O

M O

R

IG

IN

AL

R

EP

O R

T.

E

N

VI

R O

N M

EN

TA

L

SM

AR

T

LO

G

3_

BO

R

IN

G L

O G

S.

G

PJ

T

ER

R

AC

O

N _D

AT

AT

EM

PL

AT

E.

G D

T

1/

/1

T8N, R27E, Sec 34 Miles City, Montana

SITE:

Advancement Method:

Direct Push

Abandonment Method:

Boring backfilled with bentonite Surface capped with concrete

Notes:

Project No.: 26197083

Drill Rig: Geoprobe 7822DT

Boring Started: 10-22-2019

BORING LOG NO. SB7

Alares Engineering

Driller: Donnie Zier

Boring Completed: 10-22-2019

Exhibit:

CLIENT:

Quincy, MA

LOGGER: Jonathan W. Love, Field Geologist Billings, MT

PROJECT: Miles City VA Clinic

B-7

MATERIAL DESCRIPTION

O

VA

/P

ID

(p pm

SA

M

PL

E

SE

N

T

TO

L

AB

(ID

N

U M

BE

R

D

EP

TH

(f t)

W

AT

ER

L

EV

EL

O

BS

ER

VA

TI

O

N S

SA

M

PL

E

TY

PE

0.5

2.5

4.8

7.0

8.0

10.0

CONCRETE

FILL - GRAVEL , fine to coarse grained SILTY SAND (SM), fine grained, subangular, dark brown, moist

POORLY GRADED SAND (SP), fine grained, subangular, light brown, moist

WELL GRADED SAND (SW), fine to coarse grained, subangular, light brown, moist

SILTY SAND (SM), fine grained, subangular, light brown, moist

WELL GRADED SAND (SW), fine to coarse grained, subangular, light brown, moist, @ 9.5' Wet

Boring Terminated at 10 Feet

0.1

0.1

LOCATION

DEPTH

The stratification lines represent the approximate transition between differing soil types and/or rock types; in-situ these transitions may be gradual or may occur at different depths than shown.

G R

AP

H

IC

L

O G See Exhibit A-2

TH

IS

B O

R

IN

G L

O G

IS

N

O T

VA

LI

D

IF

S

EP

AR

AT

ED

F

R O

M O

R

IG

IN

AL

R

EP

O R

T.

E

N

VI

R O

N M

EN

TA

L

SM

AR

T

LO

G

3_

BO

R

IN

G L

O G

S.

G

PJ

T

ER

R

AC

O

N _D

AT

AT

EM

PL

AT

E.

G D

T

1/

/1

T8N, R27E, Sec 34 Miles City, Montana

SITE:

Advancement Method:

Direct Push

Abandonment Method:

Boring backfilled with bentonite Surface capped with concrete

Notes:

Project No.: 26197083

Drill Rig: Geoprobe 7822DT

Boring Started: 10-22-2019

BORING LOG NO. SB8

Alares Engineering

Driller: Donnie Zier

Boring Completed: 10-22-2019

Exhibit:

CLIENT:

Quincy, MA

LOGGER: Jonathan W. Love, Field Geologist Billings, MT

PROJECT: Miles City VA Clinic

B-8

MATERIAL DESCRIPTION

O

VA

/P

ID

(p pm

SA

M

PL

E

SE

N

T

TO

L

AB

(ID

N

U M

BE

R

D

EP

TH

(f t)

W

AT

ER

L

EV

EL

O

BS

ER

VA

TI

O

N S

SA

M

PL

E

TY

PE

APPENDIX C

Table 1 – Soil Analytical Summary (VPH, EPH, and VOCs)

Table 2 – Soil Analytical Summary (PAHs)

Table 3 – Soil Analytical Summary (RCRA Metals)

Table 4 – Groundwater Analytical Summary (VPH, EPH, and RCRA Metals)

Project No. 26197083 Miles City VA Clinic

Table 1: Soil Analytical Summary (VPH, EPH, and VOCs)

Terracon Consultants, Inc.

Extractable Petroleum Hydrocarbons (EPH)

Screen (mg/kg)

M et hy l t er t-b ut yl e th er

(M

TB

E)

B en ze ne

To lu en e

Et hy lb en ze ne

To ta l X yl en es

N ap ht ha le ne

C to C

A ro m at ic s

C to C

A lip ha tic s

C to C

A lip ha tic s

To ta l P ur ge ab le

H yd ro ca rb on s (T

PH

To ta l E xt ra ct ro ca rb on s

(T

EH

(S cr ee n)

To ta l E xt ra ct ro ca rb on s

(F ra ct io ns

C to C

A lip ha tic s

C to C

A lip ha tic s

C to C

A ro m at ic s

0.078 0.07 21 6.4 72 4.3 130 52 77 --- --- --- 110 24,000 370 ---

0.078 0.07 21 26 320 12 130 220 640 --- --- --- 900 200,000 370 ---

--- --- --- --- --- --- --- --- --- --- 200 --- --- --- --- ---

SB1/9.5 10/21/2019 <0.012 <0.0094 <0.0059 <0.0064 <0.024 <0.067 <0.0057 <2.6 0.087J <2.2 <3.5 NA NA NA NA ND

SB2/7.5 10/22/2019 <0.013 <0.011 <0.0067 <0.0072 <0.027 <0.075 <0.0064 <3.0 0.028J <2.4 4.7J NA NA NA NA ND SB3/7.5 10/22/2019 <0.0094 <0.0076 <0.0048 <0.0052 <0.019 <0.054 <0.0046 <2.1 0.031J <1.8 19.5 NA NA NA NA ND

SB3/12.75 10/22/2019 <0.010 <0.0083 <0.0053 <0.0057 <0.021 <0.059 1.1J <2.4 3.1J 6.2J 797 549 280 123 146 ND SB4/5.5 10/21/2019 <0.0093 <0.0075 <0.0047 <0.0051 <0.019 <0.053 <0.0045 <2.1 0.025J <1.7 4.9J NA NA NA NA ND

SB5/6 10/22/2019 <0.011 <0.0089 <0.0056 <0.0061 <0.022 <0.063 <0.0054 <2.5 0.022J <2.1 5.1J NA NA NA NA ND SB6/6 10/22/2019 <0.0098 <0.0079 <0.0050 <0.0054 <0.020 <0.056 <0.0048 <2.2 0.016J <1.8 4.0J NA NA NA NA ND

SB7/9 10/22/2019 <0.011 <0.0085 <0.0054 <0.0058 <0.021 <0.060 <0.0052 <2.4 0.0055J <2.0 4.4J NA NA NA NA ND All concentrations are reported in milligrams per killogram (mg/kg)

Bolded values indicate that the analyte was detected at a concentration above the laboratory's reporting limit.

Bolded and highlighted values indicate the reported concentration exceeds the default soil screening level.

J - Estimated concentration above the adjusted method detection limit and below adjusted reporting limit.

NA - Not analyzed ND - Not detected above the laboratory analytical reporting limit ---- - Not Applicable

Vo la til e

O rg an ic

C om po un ds (V

O C s)

(m g/ kg

MDEQ Subsurface RBSL²

EPH Screen Result Requiring Fractionation

2MDEQ - Risk-Based Screening Level - Tier 1 Risk-Based Screening Levels for Subsurface Soil (>2 feet [ft]), <10 feet to groundwater from the sample depth. Montana Tier 1 Risk-Based Corrective Action Guidance for Petroleum Releases, May 2018.

1Montana Department of Environmental Quality (MDEQ) - Default Risk-Based Screening Level - Tier 1 Risk-Based Screening Levels for Surface Soil (<2 feet [ft]), <10 feet to groundwater from the sample depth. Montana Tier 1 Risk-Based Corrective Action Guidance

Souhtern UST Basin Samples

Northern UST Basin Samples

East Catch Basin Samples

West Catch Basin Samples

EPH Fraction Analysis (mg/kg)

Sample ID Date

Volatile Petroleum Hydrocarbons (VPH) (mg/kg)

MDEQ Default RBSL1

Table 2: Soil Analytical Summary (PAHs)

Terracon Consultants, Inc.

A ce na pt he ne

A ce na ph th yl en e

A nt hr ac en e

B en zo (a

)a nt hr ac en e

B en zo (a

)p yr en e

B en zo (b

)fl uo ra nt he ne

B en zo (g

,h ,i) pe ry le ne

B en zo (k

)fl uo ra nt he ne

C hr ys en e

D ib en z( a, h) an th ra ce ne

Fl uo ra nt he ne

Fl uo re ne

In de no (1

,2 ,3

-c d) py re ne

N ap ht ha le ne

Ph en an th re ne

Py re ne

27 --- 2,200 1.3 0.13 1.3 --- 13 130 0.13 85 35 1.3 4.3 --- 83

27 --- 2,600 6.8 2.3 23 --- 230 690 7.5 85 35 77 12 --- 83

360 --- 1,800 1.1 0.11 1.1 --- 11 110 0.11 240 240 1.1 3.8 --- 180

SB1/9.5 10/21/2019 NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

SB2/7.5 10/22/2019 NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA

SB3/7.5 10/22/2019 NA NA NA NA NA NA NA NA NA NA…