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Home My WebLink About027 Environmental ReportSPR SUBMITTAL BG MILL | NORTHERN PACIFIC ADD, S07, T02 S, R06 E, LOT 1, PLAT C-23-A11 | BOZEMAN, MT, 59715 REPORTS BG MILL||13.06 ([SDQGHG3KDVH,(QYLURQPHQWDO6LWH$VVHVVPHQW(0HQGHQKDOO6WUHHW 3URSHUW\%R]HPDQ:*03URMHFW1XPEHU &OLHQW %RXQGDU\'HYHORSPHQW6HSWHPEHU (DVW%URDGZD\0LVVRXOD07,2)),&(,(0$,/ZJP#ZJPJURXSFRP ENVIRONMENTAL SITE ASSESSMENT 027 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment REPORT DATE: September 30, 2021 AUTHOR: Tyler Etzel Senior Geologist WGM Group, Inc. 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment REGULATORY AND TECHNICAL ACRONYMS AAI All Appropriate Inquiry ACBM Asbestos-Containing Building Materials ASTM American Society for the Testing and Materials AST Aboveground Storage Tank AULs Activity and Use Limitations CECRA Comprehensive Environmental Cleanup and Responsibility Act CERCLA Comprehensive Environmental Response, Compensation and Liability Act CERCLIS Comprehensive Environmental Response, Compensation and Liability Information System CORRACTS Corrective Action Report under RCRA CREC Controlled Recognized Environmental Condition DEQ Department of Environmental Quality EPA U.S. Environmental Protection Agency ERNS Emergency Response Notification System ESA Environmental Site Assessment HREC Historical Recognized Environmental Condition LBP Lead-Based Paint LLP Landowner Liability Protection LUST Leaking Underground Storage Tank MDT Montana Department of Transportation MSD Minimum Search Distance MSL Mean Sea Level NFRAP No Further Remedial Action Planned under CERCLA NPL National Priorities List PCB Polychlorinated Biphenyl REC Recognized Environmental Conditions RCRA Resource Conservation and Recovery Act TSDF Treatment, Storage or Disposal Facility for Hazardous Waste USGS United States Geological Survey UST Underground Storage Tank VCRA Voluntary Cleanup and Redevelopment Act WQA Water Quality Act 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment EXECUTIVE SUMMARY In accordance with WGM Group, Inc.’s (WGM) August 31, 2021, contract, WGM performed an expanded Phase I Environmental Site Assessment (ESA) of 714 E Mendenhall Street Property (Subject Property) in Bozeman, Montana. This ESA is certified for Edge Trullinger of Boundary Development (Client) and was conducted in accordance with Standard E 1527-13, Environmental Site Assessments: Phase I Environmental Site Assessment Process, issued by the American Society for Testing and Materials (ASTM) and conforms to the U.S. Environmental Protection Agency’s (EPA) Standards and Practices for All Appropriate Inquiries (AAI) - Final Rule, published November 6, 2013. In addition to the Phase I ESA outlined above, additional tasks were requested by the client and were conducted in general accordance with ASTM Standard E 1903-11, Environmental Site Assessments: Phase II Environmental Site Assessment Process; additional tasks included collection of four surface soil samples from selected areas of the Subject Property with laboratory analysis of the surface soil samples for chemicals of potential concern (COPCs). The purpose of this ESA is to identify Recognized Environmental Conditions (RECs), if any, in connection with the Subject Property. A REC, as defined by ASTM Standard E 1527-13, is the presence or likely presence of any hazardous substances or petroleum products in, on, or at a property: (1) due to any release to the environment; (2) under conditions indicative of a release to the environment; or (3) under conditions that pose a material threat of a future release to the environment. Environmental conditions determined to be de minimis are not RECs. No RECs, as defined by ASTM Standard E 1527-13, were identified for the Subject Property during this ESA. However, additional soil sampling was conducted to assess the potential for impacts to surface soil from historical use on and adjacent to the Subject Property. The surface soil sampling detected Resource Conservation and Recovery Act (RCRA) metals above residential direct contact screening levels at two locations (SS-3 and SS-4). Both these locations are immediately adjacent to the abandoned railroad spur line located on the Subject Property; the detection of these metals is likely related to the historical use of this area as a railroad spur. Analysis of surface soil samples SS-3 and SS-4 also detected chlorinated herbicides but at concentrations below EPA regulatory screening levels. Although the Phase I ESA did not identify any RECs (as defined by ASTM Standard E 1527-13) associated with the Subject Property, the additional sampling identified RCRA metals (barium and mercury) in surface soil adjacent to the abandoned rail spur located on the Subject Property. These 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment metals are present at concentrations slightly above EPA residential direct contact screening levels. Based on the findings of this ESA, WGM suggests if future development or redevelopment of the Subject Property includes residential use, then surface soil associated with the abandoned rail spur should be either removed and property disposed according to regulatory requirements, or further analyzed to evaluate risk. If future development will be commercial or industrial use only, then no additional action is recommended, as the concentrations detected were below initial screening levels for industrial/commercial use. 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment CONTENTS 1.0 INTRODUCTION ............................................................................................................................. 1 1.1 PURPOSE .................................................................................................................................... 2 1.2 SIGNIFICANT ASSUMPTIONS ................................................................................................... 2 2.0 LIMITATIONS OF ASSESSMENT ................................................................................................... 5 3.0 RECORDS REVIEW ........................................................................................................................ 7 3.1 PHYSICAL SETTING INFORMATION ......................................................................................... 7 3.2 PREVIOUS ENVIRONMENTAL REPORTS ................................................................................. 9 3.3 LIENS AND/OR USE LIMITATIONS ............................................................................................ 9 3.4 HISTORICAL USE INFORMATION ............................................................................................. 9 3.5 REGULATORY REVIEW ........................................................................................................... 12 4.0 SITE RECONNAISSANCE ............................................................................................................ 18 4.1 SITE OBSERVATIONS .............................................................................................................. 18 4.2 ADJOINING PROPERTIES OBSERVATIONS .......................................................................... 19 4.3 INTERVIEWS ............................................................................................................................. 20 4.4 ADDITIONAL INVESTIGATION ................................................................................................. 20 5.0 DISCUSSION AND FINDINGS ...................................................................................................... 23 5.1 DATA GAPS .............................................................................................................................. 23 5.2 RECS ......................................................................................................................................... 23 5.3 DE MINIMIS CONDITIONS ........................................................................................................ 24 5.4 ANALYTICAL RESULTS ABOVE REGULATORY SCREENING LEVELS ............................... 24 6.0 CONCLUSIONS ............................................................................................................................ 25 6.1 OPINION AND RECOMMENDATIONS ..................................................................................... 25 7.0 ENVIRONMENTAL PROFESSIONAL STATEMENT .................................................................... 26 8.0 REFERENCES .............................................................................................................................. 27 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment APPENDICES A – EXHIBITS B – RECORDS REVIEW DOCUMENTATION C - SITE VISIT PHOTOS D – RESUMES E – QUESTIONNAIRE F – FIELD NOTES G – ANALYTICAL LABORATORY REPORT H - TABLES 1 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment 1.0 INTRODUCTION In accordance with WGM Group, Inc.’s (WGM) August 31, 2021, contract, WGM performed an expanded Phase I Environmental Site Assessment (ESA) of 714 E Mendenhall Street Property (Subject Property) in Bozeman, Montana. This ESA is certified for Edge Trullinger of Boundary Development (Client) and was conducted in accordance with Standard E 1527-13, Environmental Site Assessments: Phase I Environmental Site Assessment Process, issued by the American Society for Testing and Materials (ASTM) and conforms to the U.S. Environmental Protection Agency’s (EPA) Standards and Practices for All Appropriate Inquiries (AAI) - Final Rule, published November 6, 2013. In addition to the Phase I ESA outlined above, additional tasks were requested by the client and were conducted in general accordance with ASTM Standard E 1903-11, Environmental Site Assessments: Phase II Environmental Site Assessment Process; additional tasks included collection of four surface soil samples from selected areas of the Subject Property with laboratory analysis of the surface soil samples for chemicals of potential concern (COPCs). The Subject Property is located in the town of Bozeman, Gallatin County, Montana on the corner of East Mendenhall Street and North Broadway Avenue near the eastern edge of downtown Bozeman. According to Montana Cadastral, the Subject Property is a single parcel, 0.512 acres in size, and is currently owned by BG Mill LLC. There is a complex of structures on the property that includes four grain silos and a large grain elevator with ancillary structures. The main elevator structure is located at the western edge of the parcel. Vacant office space is located to the east of the grain silos and several other additions are attached north and west of the main elevator complex. A small, unimproved parking area services the complex and is accessed via East Mendenhall Street and sits just north of the east building. The Geocode for the Subject Property is 06-0799-07-1-12-10-0000 and it is located in Section 07 of Township 02 South, Range 06 East per the Montana Public Land Survey System. A location map, site map, and topographic map are included in Appendix A. A Montana Cadastral Property Record Card is included in Appendix B. The purpose of this ESA is to identify Recognized Environmental Conditions (RECs), if any, in connection with the Subject Property. A REC, as defined by ASTM Standard E 1527-13, is the presence or likely presence of any hazardous substances or petroleum products in, on, or at a property: (1) due to any release to the environment; (2) under conditions indicative of a release to the environment; or (3) under conditions that pose a material threat of a future release to the environment. Environmental conditions determined to be de minimis are not RECs. 2 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment A review of regulatory records was obtained from Environmental Data Research, LLC (EDR) and is included in Appendix B. A site visit was completed by WGM staff, Melissa Matassa-Stone, PE and Michelle Pond under the supervision of Tyler Etzel. Tyler is an Environmental Professional per ASTM Standard E 1527-13. The site reconnaissance and existing conditions are discussed in Section 4.0 and site photos are included in Appendix C. 1.1 PURPOSE The purpose of this ESA is to identify current and historical RECs regarding the Subject Property. ASTM Standard E 1527-13 states that: “This practice is intended for use on a voluntary basis by parties who wish to assess the environmental condition of commercial real estate considering commonly known and reasonably ascertainable information. While use of this practice is intended to constitute all appropriate inquiry for the purposes of landowner liability protection, it is not intended that its use be limited to that purpose. This practice is intended primarily as an approach to conduct an inquiry designed to identify recognized environmental conditions in connection with a property.” 1.2 SIGNIFICANT ASSUMPTIONS WGM assumes that all information obtained from others regarding the Subject Property is correct and complete, that the Client and the current owner of the property have provided WGM with all reasonably ascertainable prior environmental information concerning the property, and that this report will be read in its entirety. This report is an instrument of service of WGM and includes limited research, a review of specified and reasonably ascertainable listings, and site reconnaissance to identify RECs in general accordance with ASTM Standard E 1527-13; however, this investigation may reflect additional or reduced services or service enhancements requested or authorized by the Client. WGM’s Phase I ESA was performed in accordance with generally accepted practices of the profession undertaken in similar studies at the same time and in the same geographical area, and WGM observed that degree of care and skill generally exercised by the profession under similar circumstances and conditions. This report is not a comprehensive site characterization or regulatory compliance audit and should not be construed as such. The opinions presented in this report are based upon findings derived from site reconnaissance, a review of specified records, and sources and comments made by interviewees. Specifically, WGM does not and cannot represent that the Subject Property contains no hazardous or toxic materials, products, or other latent conditions beyond that observed by WGM during its site 3 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment assessment. Further, the services herein shall in no way be construed, designed, or intended to be relied upon as legal interpretation or advice. 1.2.1 RECS RECs are defined under the ASTM standard as: “the presence or likely presence of any hazardous substances or petroleum products on a site under conditions that indicate an existing release, a past release, or a material threat of release of any hazardous substances or petroleum products into structures on the property or into the ground, groundwater or surface water of the property. The term is not intended to include de minimis conditions that generally do not present a threat to human health or the environment and that generally would not be the subject of an enforcement action if brought to the attention of appropriate governmental agencies.” 1.2.2 HRECS Historical Recognized Environmental Conditions (HRECs) are defined under the ASTM standard as “a past release of any hazardous substances or petroleum products that has occurred in connection with the property and has been addressed to the satisfaction of the applicable regulatory authority or meeting unrestricted use criteria established by a regulatory authority, without subjecting the property to any required controls (for example, property use restrictions, activity and use limitations, institutional controls, or engineering controls).” An HREC may or may not be determined to be a REC for a Subject Property at the time of the investigation. 1.2.3 CRECS Controlled Recognized Environmental Conditions (CRECs) are RECs resulting from a past release of hazardous substances or petroleum products that have been addressed to the satisfaction of the applicable regulatory authority (for example, as evidenced by the issuance of a no further action letter or equivalent, or meeting risk-based criteria established by regulatory authority), with hazardous substances or petroleum products allowed to remain in place subject to the implementation of required controls (for example, property use restrictions, activity and use limitations, institutional controls, or engineering controls). CRECs are considered to be RECs for a Subject Property at the time of the investigation. 4 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment 1.2.4 DATA GAPS A data gap is a lack of or inability to obtain information required by ASTM Standard E 1527-13 despite good faith efforts by the environmental professional to gather such information. Data gaps may result from incompleteness in any of the activities required by ASTM Standard E 1527-13, including, but not limited to site reconnaissance (for example, an inability to conduct the site visit), and interviews (for example, an inability to interview the key site manager, regulatory officials, etc.). 5 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment 2.0 LIMITATIONS OF ASSESSMENT This ESA was conducted solely for the Client and is nontransferable. The Client may not assign, transfer, or convey this ESA to another person or entity without the prior written consent of WGM. No person or entity who is not a party to this contract may rely on this ESA for any purpose. There are inherent limitations associated with ESAs. For example, this ESA did not include any inquiry with respect to radon, methane, asbestos, mold, lead in drinking water, or other services or potential conditions or features not specifically identified and discussed herein. WGM is providing information about some of the limitations inherent with this ESA solely to assist the Client with identifying and thereby managing some of the risks. These risks can potentially be mitigated—but never completely eliminated— through additional research. WGM will, upon the Client’s request, advise the Client of the additional research which the Client may want to consider and the associated costs. If the Client does not request the additional research or if the Client does not ask about the additional research that can be done, then WGM will not do the additional research. In those instances where additional services or service enhancements are included in the report as requested or authorized by the Client, some of the specific limitations attendant to those services are presented in the text of the report itself. Per the ASTM Phase II Standard, Phase II ESAs do not generally require an exhaustive assessment of environmental conditions on a property. There is a point at which the cost of information obtained and the time required to obtain it outweigh the benefit of the information and, in the context of private transactions and contractual responsibilities, may become a material detriment to the orderly conduct of business. If the presence of target analytes is confirmed on a property, the extent of further assessment is a function of the degree of confidence required and the degree of uncertainty acceptable, in relation to the objectives of the assessment. The findings and opinions conveyed via this ESA report are based upon information obtained at a particular date from a variety of sources enumerated herein, and which WGM believes are reliable. Nonetheless, WGM cannot and does not warrant the authenticity or reliability of the information sources it has relied upon. This report represents WGM’s service to the Client as of the report date. In this regard, the report constitutes WGM’s final document, and the text of the report may not be altered in any manner after final issuance of the same. Opinions relative to environmental conditions given in this report are based upon 6 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment information derived from the most recent site reconnaissance date and from other activities described herein. The Client is herewith advised that the conditions observed by WGM are subject to change. Certain indicators of the presence of hazardous materials may have been latent or not present at the time of the most recent site reconnaissance and may have subsequently become observable. In a similar manner, the research effort conducted for a Phase I investigation is limited. Accordingly, it is possible that WGM Group’s research, while fully appropriate for an ESA and in compliance with the scope of services, may not include other important information sources. Assuming such sources exist, their information could not have been considered in the formulation of our findings and conclusions. This report is not a comprehensive site characterization or regulatory compliance audit and should not be construed as such. The opinions presented in this report are based upon findings derived from site reconnaissance, limited surface soil sampling, a review of specified records, and sources and comments made by interviewees. Specifically, WGM does not and cannot represent that the Subject Property contains no hazardous or toxic materials, products, or other latent conditions beyond that observed by WGM during its site assessment. Further, the services herein shall in no way be construed, designed, or intended to be relied upon as legal interpretation or advice. 7 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment 3.0 RECORDS REVIEW WGM obtained and reviewed historical records to assist in identification of RECs regarding the Subject Property. 3.1 PHYSICAL SETTING INFORMATION The Subject Property is located in Bozeman, Gallatin County, Montana. It is a single parcel, 0.512 acres in size. Currently, there is a complex of structures on the property that include four grain silos and a large grain elevator with ancillary structures. The main elevator structure is located near the western edge of the parcel. Sanborn Fire Insurance Maps (see Section 3.4.1) indicate the original structure was erected on the Subject Property in 1928. Vacant office space is located to the east of the grain silos and several other additions are attached north and west of the main elevator complex. A small, unimproved parking area services the complex and is accessed via East Mendenhall Street and sits just north of the east building. The Subject Property lies approximately 100 feet west of Story Ditch and approximately 1,500 east of Bozeman Creek, both of which flow north to the East Gallatin River located 1.3 miles north of the Subject Property. The Subject Property is currently owned by BG Mill LLC. A location map, site map, topographic map, and site visit map are included in Appendix A. The physical setting of the Subject Property and adjoining properties were observed during a site visit on September 15, 2021, by WGM staff Melissa Matassa-Stone, PE and Michelle Pond. Published reports and maps containing information related to topography, soil conditions, and geologic features were also reviewed by Mr. Tyler Etzel. This information was used to predict potential contaminant movement in the environment. 3.1.1 TOPOGRAPHY Bozeman is located in the eastern portion of the Gallatin Valley, which is a broad intermontane basin (Kendy and Tresch 1996). The elevation of Bozeman is approximately 4,800 feet above mean sea level (ft amsl). Gallatin Valley ranges in elevation from 4,100 ft amsl where the Gallatin River leaves the valley on the west side to about 6,000 ft amsl along the southeast boundary. The Gallatin and Bridger Mountain ranges are the most prominent near Bozeman, with summits to nearly 10,000 ft amsl. 8 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment A topographic map for the Subject Property and nearby vicinity was obtained from Montana Digital Library. The Subject Property is flat at an elevation of approximately 4,804 ft amsl. A Topographic Map of the Subject Property is included in Appendix A. 3.1.2 REGIONAL AND SITE GEOLOGY/HYDROGEOLOGY The Gallatin Valley (Valley) is framed by exposed bedrock mountain ranges on the north, south, east, and southwest. The Valley is an east-tilted graben (a down-dropped fault block). The mountains surrounding the basin are composed of metamorphic, sedimentary, and igneous bedrock. The Precambrian bedrock on the floor of the Valley is generally less permeable than the unconsolidated basin sediments, although fractures or carbonate dissolution features create significant local flow conduits. The majority of the basin is filled with Tertiary sedimentary rocks, over which younger Quaternary alluvium was deposited. The most productive aquifer of the Gallatin Valley is the West Gallatin Alluvium which is comprised of sand, gravel, and cobbles deposited by the river on top of the valley bedrock. The aquifer extends from the Gallatin Canyon (south of Gallatin Gateway) to Manhattan, Montana. Alluvium sediments of sand and gravels can be up to 400 feet thick. Generally, groundwater flows from southeast to northwest across the Gallatin Valley (SWDAR, 2001 and 2005) No site-specific information is available about the direction of groundwater flow at the Subject Property, however, based on the local topography and the orientation and influence of the Gallatin River, shallow groundwater flow at the Subject Property is assumed to be west to north-northwest. Well logs from nearby wells (< ¼ mile) are included in Appendix B and show groundwater levels ranging from 8 to 19 ft below ground surface (bgs), with an average static water level (SWL) of approximately 14 ft bgs. 3.1.3 SOIL CONDITIONS The majority (90%) of the Subject Property is classified as urban land, and 10% is classified as Blackmore Silt Loam and described as farmland of statewide importance that is well-drained. A Custom Soil Resource Report was generated from the Natural Resources Conservation Service (NRCS) United States Department of Agriculture (USDA) database and is included in Appendix B. Well logs from nearby properties indicate sand and gravel predominate down to 17 ft bgs with varying silt, sand, and gravel below 17 ft bgs. Depth to water in nearby wells ranges from 14 to 18 ft bgs. 9 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment 3.2 PREVIOUS ENVIRONMENTAL REPORTS No previous ESA reports associated with the Subject Property were identified; however, two reports related to the Subject Property were provided by Larry Pearson and Josh Barr with Pearson Design Group. They include an Asbestos Inspection Report (Environmental Solutions, 2019) and a Historical Inventory Report (Architecture Trio, 2017). The asbestos inspection report identified asbestos containing material (ACM) in building materials that will need to be removed by an accredited abatement contractor prior to renovation or demolition of buildings on the Subject Property. Both documents are included in Appendix B of this ESA. 3.3 LIENS AND/OR USE LIMITATIONS No environmental liens or activity and use limitations were identified by EDR with respect to the Subject Property. 3.4 HISTORICAL USE INFORMATION Historical use information for the Subject Property and adjoining properties was obtained by reviewing reasonably available and ascertainable historical sources including but not limited to: • Interviews, • Sanborn maps, • City directories, • Previous studies, and • Additional sources listed below. This information is used to identify the likelihood that historical uses may have led to potential RECs in connection with the Subject Property. 3.4.1 SANBORN FIRE INSURANCE MAPS From 1867 to the 1970s, the Sanborn Map Company produced maps to aid in the assessment of fire insurance liability for urbanized commercial and industrial districts in the United States. The maps included property boundaries, building locations, street names and natural features, and have become a valuable resource for historical research. EDR searched the Sanborn Map 10 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment database for this report. Sanborn Maps for the following years were reviewed for this investigation: 1891, 1904, 1912, 1927, 1943, 1951, and 1969. The 1891 and 1904 Sanborn Maps show no development or parcel creation for the Subject Property. In 1891, a road that adjoins the western edge of the Subject Property is called “Story” and in the 1904 map the same road is called “Ida Av N.” The 1912 Sanborn Map continues to show no development on the Subject Property, but more dwellings are shown on parcels north and west of the Subject Property. The 1912 map also shows property to south and southwest with five Northern Pacific Railroad (NPRR) Freight tracks that join into one or two tracks just south of the property. Southwest of the railroad freight tracks, a large NPRR Freight House is shown. The 1927 Sanborn Map shows that the street formerly call Ida Av N is now called “Broadway.” There is one unlabeled structure on the Subject Property, and one NPRR spur track along the southern boundary of the Subject Property that enters from the western end and exits the eastern end of the property. Much more development is shown south of the Subject Property related to commercial/industrial railroad use including several coal bins adjacent-south and southwest of the Subject Property. The property to the South shows more detail with four NPRR spurs that join and exit towards the northeast. A Chicago Milwaukee St Paul & Pacific Railroad (CM St P RR) Gallatin Valley Branch track bends upward from the south and exits towards the east of the Map. Approximately 200 feet south of the Subject Property, an Oil Warehouse is shown with a pump house and gas & oils. The 1943 Sanborn Map shows the first significant structure improvements of the Subject Property that are labeled “Montana Elevator Co – Grain Elevator, built 1928, Capacity 45,000 BU” (bushels). The structures on the Subject Property are further labeled with the round grain silos labeled “Steel Grain Tanks” and to the left of the silos, “Grain Cleaner Roller,” with offices and warehouses adjacent-north of these structures. More development south of the Subject Property can be seen with the Oil Warehouse structures called “The California Company” across the railroad tracks; “Russell Oil Co” across Broadway St (including numerous oil and gas tanks); and “Continental Oil Co” and “Standard Oil Co” even further south, across E Main St, with both including Oil Warehouses and multiple steel petroleum tanks. The 1951 Sanborn Map shows similar development to the 1943 map. The 1969 Sanborn Map shows more adjoining structures have been built on the Subject Property; these appear to be related to warehouse storage and a coal bin. The surrounding properties appear to show relatively the same use and development as the previous 1951 Sanborn Map. 11 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment The Sanborn Maps indicate that the primary specific use for the Subject Property since 1928 has been as a commercial grain elevator. Commercial and industrial railroad use has occurred within the southern boundary of the Subject Property and to a larger scale on the adjoining southern property, with numerous rail spurs and accompanying fueling operations. All of the historical uses and releases related to these historical uses on the adjoining properties described above have been determined as “Resolved” by the Montana Department of Environmental Quality (DEQ); as described in Sections 3.5.4 through 3.5.7, below. Since these adjoining property historical uses are listed as resolved by DEQ, they do not represent RECs for the Subject Property. 3.4.2 CITY DIRECTORIES City Directories from 1963 through 2017 for the Subject Property and the area surrounding the Subject Property were reviewed to evaluate the past uses and activities over time as well as the potential for RECs. The Subject Property and adjacent properties with listings that have or had potential past uses that may indicate the presence or likely presence of hazardous substances or petroleum product releases to the environment are shown below. Copies of the City Directory images are provided in Appendix B. East Main Street 606 E Main St – Chicago Milwaukee St Paul & Pacific Railroad Freight Depot: 1974, 1969 626 E Main St – Pacific Steel Hides-Furs Recycling: 1984, 1979, 1974, 1969, 1963 711 E Main St – Chevron Oil Wholesale Distributor / California Oil Co: 1979, 1974, 1969, 1963 716 E Main St – Badgley Distributor (wholesale gasoline) / Standard Oil-American Oil: 1989, 1974, 1969 803 E Main St – Conoco Town Pump / O’Neil’s Phillips 66 Service: 2017, 2014, 2010, 2005, 2000, 1989, 1984, 1979, 1974, 1969, 1963 915 E Main St – East End Husky Gas Station / East End Standard / Dave’s Standard Service: 1989, 1984, 1979, 1969, East Mendenhall Street 712 E Mendenhall St (Subject Property) – Cargill Grain Elevator / Montana Elevator Co: 1974, 1969, 1963 714 E Mendenhall St (Subject Property) – B-G Grain Co: 1994, 1989, 1984 715 E Mendenhall St – Manseau Auto Clinic: 2000, 1994, 1989, 1984, 1979 12 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment Seven parcels adjacent and/or hydraulically upgradient to the Subject Property have past uses that could potentially indicate the presence or likely presence of hazardous substances or petroleum product releases to the environment. Uses on these parcels included industrial/ commercial railroad use; industrial/commercial recycling; automotive service and repair; fueling stations; and petroleum bulk plants. All of the historical uses and releases related to these historical uses on the adjoining properties described above have been determined as “Resolved” by the DEQ; as described in Sections 3.5.4 through 3.5.7, below. Since these adjoining property historical uses are listed as resolved by DEQ, they do not represent RECs for the Subject Property. 3.4.3 AERIAL PHOTOS Aerial images of the Subject Property and vicinity were reviewed to evaluate the Subject Property over time and the potential for RECs. Aerial photographs from 1995 through 2017 were reviewed. Copies of these aerial photographs are provided in Appendix B. All the historical aerial photos show the Subject Property in very similar condition to present circumstances, with the exception of the photograph from 1995. Although the quality of the 1995 aerial photograph does not allow evaluation of specific details, examination of the property located to the south of the Subject Property suggests that development occurred between the 1995 photograph and the 2003 photograph. The parking lot that can be readily seen in the 2003 photograph appears to contain remnants of railroad spur lines and a rail yard in the 1995 photograph. WGM’s review of aerial photographs indicates that the general layout and characteristics of the Subject Property and adjoining properties have not changed significantly since at least 2003, and no RECs were identified during the review of aerial photographs. 3.5 REGULATORY REVIEW The purpose of the regulatory records review is to assess reasonably available records that help identify potential RECs in connection with the Subject Property. In Montana, these records are chiefly maintained by the EPA and the DEQ. Records do not pertain only to the Subject Property, but also to properties within specified approximate search distances in order to help assess the likelihood of potential environmental concerns from migrating hazardous substances or petroleum products. Unless stated otherwise, the approximate minimum search distances used are specified in ASTM E 1527-13. 13 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment A search of available federal and state environmental records was completed using the sources cited in Section 8.0, including the specific government records searched by EDR (included in Appendix B) and the online-accessible EPA, DEQ, and local databases. As shown in the table below, several facilities were identified within the standard search distances noted in ASTM E 1527-13. DATABASE REVIEW: REGULATED FACILITIES IN VICINITY OF SUBJECT PROPERTY Search Radius Facility Quantity1 0.5 mile Federal CERCLIS 1 1.0 mile NPL Sites, including delisted NPL Sites 1 0.5 mile Federal CERCLIS NFRAP Sites (SEMS-ARCHIVE) 2 1.0 mile State and Tribal Equivalent NPL 3 0.5 mile State and Tribal Equivalent CERCLIS 1 0.5 mile State and Tribal LUST Sites 85 Property and Adjoining Properties State and Tribal Registered Storage Tank Sites 4 Property and Adjoining Properties SPILLS Sites 4 1 Sites that were identified by EDR but located outside the minimum search distance are not included in the table. 3.5.1 FEDERDAL CERCLIS AND NPL SITES CERCLA was enacted to identify and address releases or threatened releases of hazardous substances that may endanger public health or the environment. The Comprehensive Environmental Response, Cleanup, and Liability Information System (CERCLIS) lists all CERCLA sites, including those on the National Priority List (NPL). The NPL is the list of the highest priority CERCLA sites and those requiring long-term remedial response actions. RESULTS: One federal NPL facility was identified within a 1.0-mile radius of the Subject Property. The Idaho Pole Co. (IPC) is located at approximately 0.46 miles north of the Subject Property. Between the late 1800s and early 1940s, the precursor to Burlington Northern Santa Fe Railway Company (BNSF) operated a five-stall roundhouse south of Cedar Street and east of L Street. The IPC wood treating facility began operation in 1945 using creosote to preserve wood. In 1952 the company switched to pentachlorophenol in carrier oil (similar to fuel oil such as diesel) for the wood treating solution. Site processes included pole treatment in butt vats with the later addition 14 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment of pressurized heated retort equipment in the area south of Cedar Street. Treated poles were stacked for drying and shipment in the area. Pole treatment processes included pole peeling with a bark-fill area for wood waste north of Cedar Street. In 1975 a pressurized heated retort was added for treating full-length poles. The pole-length vats were removed in the early 1980s. IPC continued wood treating with a pressurized heated retort and butt-dipping vat until September 1997, when the company ceased wood-treating operations. EPA and DEQ have completed the fifth five-year review of the Idaho Pole Company (IPC) Superfund site. The five-year review is a regular checkup on a Superfund site to ensure that cleanup decisions continue to protect people and the environment. The review has determined that the remedy currently protects human health and the environment because institutional controls are in place such as a deed restriction on IPC property and a controlled groundwater area that restricts potable use of the groundwater. Because of the downgradient direction of this facility, and its distance from the Subject Property, and its current designation by DEQ and EPA, the Idaho Pole Co is not considered a REC for the Subject Property. 3.5.2 FEDERAL CERCLIS NFRAP SITES The Federal CERCLA information system (CERCLIS) includes non-NPL sites, where actions may be taken to address releases or threatened releases requiring prompt, short-term responses. It also includes sites withdrawn from the NPL because the EPA has determined that it poses no real or potential threat to human health and the environment. These latter sites are identified as No Further Remedial Action Planned (NFRAP) facilities. RESULTS: Two CERCLIS NFRAP facilities were identified within a 0.5-mile radius of the Subject Property. The CMC Asbestos Site is located approximately 0.1 mile southeast of the Subject Property. The CMC Asbestos Bozeman facility is not a REC for the Subject Property. The Mercer Post Plant is located approximately 0.4 miles northwest of the Subject Property and is not a REC for the Subject Property. 3.5.3 MONTANA CECRA SITES, INCLUDING EQUIVALENT NPL & VCRA Montana Comprehensive Environmental Cleanup and Responsibility Act (CECRA) facilities are the state equivalent of CERCLIS sites and are referred to as State Superfund sites. These facilities include facilities being managed under the Voluntary Cleanup and Redevelopment Act 15 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment (VRCA). The VCRA was developed to permit and encourage voluntary cleanup of facilities where releases or threatened releases of hazardous or deleterious substances exist. RESULTS: DEQ’s Hazardous substance release mapping database was reviewed, and three state-equivalent NPL (CECRA) sites were identified within a 1.0-mile radius of the Subject Property. The Idaho Pole Co. is located at approximately 0.46 miles north of the Subject Property and it is discussed in Section 3.5.1 above. In addition, the Mercer Pole Plant site (0.4 miles northwest) and the Developmental Technology site (0.96 miles north-northwest) are located within a 1.0-mile radius of the Subject Property. Neither of these sites are considered a REC for the Subject Property due to their distance and downgradient direction from the Subject Property. 3.5.4 MONTANA AND TRIBAL LUST FACILITIES Leaking Underground Storage Tanks (LUSTs) are facilities where contamination is or has been present from former and/or current USTs. The EDR Recovered Government Archive LUST database provides a list of LUST incidents derived from historical databases and includes many records that no longer appear in current government lists. The DEQ, EPA, and EDR databases of LUST facilities were reviewed for properties within a 0.5-mile radius of the Subject Property. RESULTS: Eighteen LUST facility releases and sixty-seven recovered government archive (RGA) LUST facilities were documented by EDR within 0.5-mile of the Subject Property. All of these facilities are listed in the EDR radius report in Appendix B of this ESA, however, four of the LUST sites that are located adjacent to or hydraulically-upgradient to the Subject Property are also RGA LUST sites and these are listed below. Each of these facilities has been addressed to the satisfaction of the DEQ and is considered to be “resolved;” none are considered to be RECs for the Subject Property. FACILITY ID SITE NAME ADDRESS PROXIMITY DATE CONFIRMED DATE RESOLVED 21505 Town Pump Inc Bozeman 1 803 E Main St 0.04 miles 3/14/1991 11/14/2016 30617 Vacant Lot Bozeman (Former Chevron Station/Delaney & Co #4218) N Broadway Ave & E Main St 0.051 miles 5/21/1999 7/17/2000 17252 Former Badgley Distributing Inc 716 E Main St 0.092 miles 6/5/2007 4/22/2010 16 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment FACILITY ID SITE NAME ADDRESS PROXIMITY DATE CONFIRMED DATE RESOLVED 21813 Manseau Auto Clinic 715 E Mendenhall St 0.018 miles 4/21/1993 12/14/1995 3.5.5 MONTANA AND TRIBAL REGISTERED UST FACILITIES Registered storage tank facilities include facilities with underground storage tanks (USTs) and regulated above-ground storage tanks (ASTs). Unless these facilities are also listed on DEQ’s Leaking UST facility list or in DEQ’s unpermitted releases database, they have no known contamination issues associated with them. They are identified here due to the potential for contamination. The DEQ and Tribal databases were searched by EDR for registered storage tank facilities on the Subject Property or adjoining properties. RESULTS: Three storage tank facilities were found on properties adjoining the Subject Property or hydraulically upgradient of the Subject Property. Three of the UST facilities are listed by EDR as “closed”. One facility (Town Pump Inc Bozeman 1) is listed as “open” but does not have an open petroleum release listed in association with the UST. None of the UST facilities are considered to be RECs for the Subject Property. FACILITY ID SITE NAME ADDRESS PROXIMITY CLOSED? 21505 Town Pump Inc Bozeman 1 803 E Main St 0.04 miles OPEN 30617 Vacant Lot Bozeman (Former Chevron Station) N Broadway Ave & E Main St 0.051 miles CLOSED 17252 Pacific Hide and Fur (Former Badgley Distributing Inc) 626 E Main St 0.060 miles CLOSED 21813 Manseau Auto Clinic 715 E Mendenhall St 0.018 miles CLOSED 3.5.6 SPILLS SITES Records of emergency release reports are listed as SPILLS Sites by EDR. A review of the SPILLS list revealed that there are four SPILLS sites either on or adjacent to the Subject Property. RESULTS: The Subject Property is listed on the SPILLS list. A spill related to sediment in water was observed on 7/13/2019 and anonymously reported on 11/13/2019. EDR reports the status of the Subject Property SPILLS report is “Closed Referred.” The listing of the Subject Property on 17 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment the SPILLS list is not a REC because no record of contamination was recorded or regulated by DEQ. Three properties that adjoin the Subject Property are also on the SPILLS list. They include the Town Pump Bozeman 1 site; the Bouma Trucking Site; and the property located at 715 East Mendenhall Street (Manseau Auto Clinic) Each of these sites is listed on other databases noted above and are either closed or resolved by DEQ. None of these SPILLS Sties are considered to be RECs for the Subject Property. 3.5.7 OTHER FACILITIES One site was within 0.5-miles of the Subject Property was identified by EDR to be on the Voluntary Cleanup and Redevelopment Program (VCP) list and on the list of sites that has been delisted from the CECRA Priority List (DEL SHWS). The CMC Asbestos Bozeman site is located at the 600 block of East Main Street approximately 0.07 miles southeast of the Subject Property. This site is not a REC for the Subject Property. The Bouma Trucking Site is located 0.07 miles west of the Subject Property at 34 North Wallace Avenue. The Bouma Trucking Site is on the DEL SHWS list and the WQA list. The Montana Water Quality Act (WQA) was developed to address long-term soil, surface water, and groundwater remediation and monitoring. Both listings for the Bouma Trucking Site indicate that it is delisted from its respective program. The Bouma Trucking Site is not a REC for the Subject Property. 18 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment 4.0 SITE RECONNAISSANCE The objective of the site reconnaissance is to obtain information indicating the likelihood of identified RECs in connection with the Subject Property. 4.1 SITE OBSERVATIONS The Subject Property and adjoining properties were visually observed on September 15, 2021, by WGM staff Michelle Pond and Melissa Matassa-Stone, PE. The purpose of site reconnaissance was to obtain information indicating the potential presence of RECs in connection with the Subject Property. Larry Pearson, with Pearson Design Group, provided access to the property and acted as the Key Site Manager for this investigation. 4.1.1 SITE OVERVIEW AND CURRENT USE The Subject Property is located in Bozeman, Montana, in the eastern downtown area on the corner of off East Mendenhall Street and North Broadway Avenue. Appendix A includes a location map, site map, topographical map, and site visit map. The Subject Property is made up of a complex of structures that include four grain silos and a large grain elevator with ancillary structures. The main elevator structure is located at the western edge of the parcel. A small, unimproved parking area services the complex and is located and accessed off East Mendenhall Street and sits just north of the east building. Based on the historical records review, the building has been used as an agricultural grain elevator since it was constructed in 1928 and has had several additions/revisions since that time. The northern and western additions have been remodeled are in good condition. The elevator and warehouse portions of the building are in generally poor condition, and no RECs were observed during site reconnaissance. A few items of note include: • Minor water staining was observed on the office portion of the main building. • Numerous electric motors, used to move grain in the elevator, are present throughout the buildings. • Small quantities of general cleaning supplies and chemicals, typical for an office building, were found in the office building. 19 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment • At the northwest side of the main office building, an unknown 1-inch outer diameter PVC pipe was observed protruding from the ground (Appendix C; Photo #45). No RECs were identified during site reconnaissance activities; however, the unknown PVC pipe is considered a de minimis condition due to the unknown origin/purpose of this item. A de minimis condition is not considered a REC. 4.1.2 DESCRIPTION OF SPECIFIC SITE FEATURES The area surrounding the Subject Property is generally used for commercial purposes, or are vacant, as illustrated on Exhibit A-2 in Appendix A. SOURCE OF DRINKING WATER/WELLS The Subject Property is connected to the City of Bozeman water service. SEWAGE DISPOSAL/SEPTIC SYSTEM It is not known if the Subject Property is connected to the City of Bozeman Sanitary and/or Storm sewer systems. PITS, PONDS, OR LAGOONS No pits, ponds, or lagoons were observed on the property. 4.2 ADJOINING PROPERTIES OBSERVATIONS Reconnaissance of adjoining properties was performed by viewing land use from legal boundaries and reviewing aerial photos and Montana Cadastral records. Adjoining properties were visually examined from public access rights-of-way to make a cursory assessment of the current land use and its potential for RECs that may have an impact on the Subject Property. Adjoining properties appear to be primarily commercial and/or residential in nature. Based on observations of adjoining properties and associated research, there are no apparent RECs with the potential to impact the Subject Property. 20 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment 4.3 INTERVIEWS A key site manager is defined in ASTM E 1527-13 as a person “having good knowledge of the uses and physical characteristics of the property.” Larry Pearson, with Pearson Design Group, provided access to the property and acted as the Key Site Manager for this investigation. Appendix E includes a Questionnaire completed by Larry Pearson for the Subject Property. Based on the nature of the property and the information collected regarding historical uses, no RECs were identified the Subject Property. 4.4 ADDITIONAL INVESTIGATION 4.4.1 OBJECTIVES AND PURPOSE OF ADDITIONAL INVESTIGATION In initial correspondence prior to conducting the Phase I ESA, the Client requested that WGM conduct a broader scope of assessment to determine if the known historical industrial uses and historical railroad use of the Subject Property may have released hazardous substances or petroleum products to environmental media at the property. To assess the potential for a historical release, WGM developed a preliminary conceptual site model (CSM) of the Subject Property based on the following assumptions: • A release related to historical industrial and railroad use on the Subject Property would be present in surface soil. • Past releases on adjoining properties and hydraulically upgradient properties would be present in subsurface soil and groundwater on the Subject Property, and all of these past releases have been designated as “Resolved” by DEQ. • Chemicals of potential concern (COPCs) related to historical industrial and railroad use on the Subject Property are petroleum hydrocarbon compounds related to industrial use; herbicides related to agricultural use, and metals related to both industrial and railroad use. Target analytes for these COPCs include: o Extractable petroleum hydrocarbon (EPH) screen (MT DEQ MA EPH); in the event the initial EPH screen exceeds 200 mg/kg (ppm) total extractable hydrocarbons (TPH), then EPH fractions analysis and polycyclic aromatic hydrocarbons (PAHs; SW-846 8270C) analysis would also be conducted o Chlorinated herbicides (SW-8151A) o RCRA metals (SW-6010.20 & SW 7471). 21 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment 4.4.2 SURFACE SOIL SAMPLING PLAN AND SAMPLING METHODS WGM developed a sampling plan to validate the CSM which included collecting four surface soil samples on the Subject Property (Exhibit A-4, Appendix A). On September 21, 2021, Michelle Pond with WGM, collected surface soil samples SS-1, SS-2, SS-3, and SS-4 at depths of approximately 0 to 6 inches bgs from undisturbed locations surrounding the Subject Property. Field notes for the sampling are included in Appendix F. Each discreet grab sample was collected by wearing disposable nitrile gloves and collecting a sample by of soil using a stainless-steel sampling trowel. Each sample of soil was placed in a stainless-steel bowl and all coarse fragments (including organic material) greater than 0.5 inches were removed from the bowl. The material in the bowl was mixed with the stainless-steel spoon to homogenize the sample. The soil was then transferred directly into a four-ounce glass sample jar with a Teflon cap and stored in a cooler at four degrees Celsius or lower. The time and date of sample collection was documented on the glass sample jar. Residual sample material (if any) was retained in a plastic bag for archiving purposes. A flag or stake was pushed into the ground at the sample location, which allowed for obtaining the coordinates of the sample location with a handheld device. Soil samples were sent to Energy Laboratories in Helena in a cooler under proper chain-of-custody on September 21, 2021. The lab received the samples on September 22, 2021 and analyzed each for the COPCs identified above in Section 4.4.1. Laboratory analytical results are included in Appendix G. 4.4.3 SURFACE SOIL SAMPLE RESULTS Surface soil samples with identification numbers SS-1, SS-2, SS-3 and SS-4 were collected from the areas shown in Appendix A; Exhibit A-4. Each sample was collected from surface soil at depths ranging from 0 to 6 in bgs. No evidence of impacted soil (petroleum staining or odor) was observed in any of the surface soil samples. Soil from all four locations was submitted for laboratory analysis of EPH Screen, Chlorinated Herbicides, and RCRA Metals. Since no EPH screen result exceeded 200 ppm, no additional analysis for EPH fractions or PAHs was conducted. Analytical results are summarized below and tabulated in Appendix H. • None of the four surface soil samples analyzed for EPH Screen detected total extractable hydrocarbons (TEH) above a concentration that requires further analysis. Because of this, no analysis of EPH fractions or PAHs analysis was necessary. 22 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment • Two of the four surface soil samples analyzed for chlorinated herbicides detected concentrations above laboratory detection levels. These detections included: o SS-3 detected pentachlorophenol (PCP) at 0.0055 mg/kg (ppm) o SS-4 detected pentachlorophenol (PCP) at 0.075 mg/kg, dicamba at 0.025 mg/kg, dinoseb at 0.034 mg/kg, and picloram at 0.18 mg/kg None of the chlorinated herbicide concentrations listed above exceeded any EPA residential or industrial EPA Regional Screening Levels (RSLs). • RCRA metals were detected in soil, although most concentrations were below applicable DEQ Risk-Based Corrective Action (RBCA) screening levels or RSLs. Two surface soil samples (SS-3 and SS-4) detected RCRA Metals at or above regulatory screening levels and include: o SS-3 detected barium at 429 mg/kg, at the DEQ Risk-Based Screening Level (RBSL) for residential direct contact (429 mg/kg) o SS-3 and SS-4 both also detected mercury at 2.1 mg/kg and 1.2 mg/kg, respectively. Both these concentrations are slightly above EPA RSL for residential direct contact (1.0 mg/kg) 23 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment 5.0 DISCUSSION AND FINDINGS This Phase I ESA investigation included records review, site reconnaissance, personnel interviews, review of historical maps, and permit reviews intended to assess the environmental condition of commercial real estate taking into account commonly known and reasonably ascertainable information. The Phase I ESA did not find any RECs associated with the Subject Property; however, the ESA also included collection of surface soil samples on the Subject Property to assess potential impacts from historical use on and adjacent to the property. The surface soil samples collected to assess potential impacts from historical use on the Subject Property detected RCRA Metals (barium and mercury) and chlorinated herbicides (dicamba, dinoseb, PCP, picloram). Barium and mercury were detected at concentrations slightly above residential direct contact screening levels and chlorinated herbicides (dicamba, dinoseb, PCP, picloram) were all detected at concentrations below applicable regulatory screening levels (Appendix H). Since the location of both surface soil samples containing metals are adjacent the abandoned railroad spur line along the southern portion of the Subject Property, it is likely these metals are related to the historical use of this railroad spur. Based on site conditions and the historical use of the Subject Property outlined the CSM (Section 4.4.1) the occurrence of RCRA metals (barium and mercury) in surface soil is likely to be in shallow surface soil (12 in bgs or less) and in conjunction with the historic rail spur. 5.1 DATA GAPS A data gap is the lack of or inability to obtain information required by ASTM Standard E 1527-13 despite good faith efforts to gather such information. Data gaps may result from incompleteness in any of the activities required by ASTM Standard E 1527-13, including, but not limited to, site reconnaissance. No data gaps were identified in this investigation. 5.2 RECS RECs are defined under the ASTM standard as: “the presence or likely presence of any hazardous substances or petroleum products on a site under conditions that indicate an existing release, a past release, or a material threat of release of any hazardous substances or petroleum products into structures on the property or into the ground, groundwater, or surface water of the property. The term is not intended to include de minimis conditions that generally do not present a threat to human health or the environment 24 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment and that generally would not be the subject of an enforcement action if brought to the attention of appropriate governmental agencies.” No RECs were identified for the Subject Property in this investigation; however, due to several decades of industrial/commercial/railroad use ether on or adjacent to the Subject Property, additional assessment was completed for this ESA. The analytical results from the additional assessment are discussed below in Section 5.4. 5.3 DE MINIMIS CONDITIONS De minimis conditions are defined under the ASTM standard as conditions that generally do not present a threat to human health or the environment and that generally would not be the subject of an enforcement action if brought to the attention of appropriate governmental agencies. The site visit described in Section 4.1.1 identifies an unknown PVC pipe extending from the surface of the ground in the grassy area just west of the parking lot area (Appendix C; Photo #45). This unknown PVC pipe is considered a de minimis condition due to the unknown origin and or purpose of this item. Since it is likely related to a septic or sewer system appurtenance, WGM considers this to be a de minimis condition and not a REC. Future development or redevelopment of the Subject Property should include documentation and removal of this unknown PVC pipe. 5.4 ANALYTICAL RESULTS ABOVE REGULATORY SCREENING LEVELS RCRA metals were detected in soil above regulatory screening levels in SS-3 and SS-4 (Appendix A and Appendix H). Both these sample locations are adjacent to the abandoned rail spur line south of the onsite buildings. The metals (barium and mercury) were detected above residential direct contact screening levels at the following concentrations: • SS-3 detected barium at 429 mg/kg • SS-3 detected mercury at 2.1 mg/kg • SS-4 detected mercury at 1.2 mg/kg 25 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment 6.0 CONCLUSIONS On behalf of the Client, WGM conducted an ESA of 714 East Mendenhall Street Property located in Bozeman, Montana. The ESA was conducted in general accordance with ASTM Standard E 1527-13 and conforms to the EPA’s Standards and Practices for AAI – Final Rule published November 2013. Any exceptions to or deletions from this practice are presented in the appropriate sections of this report. Although the Phase I ESA did not identify any RECs (as defined by ASTM Standard E 1527-13) associated with the Subject Property, the additional sampling identified RCRA metals (barium and mercury) in surface soil adjacent to the abandoned rail spur located on the Subject Property. These metals are present at concentrations slightly above EPA residential direct contact screening levels. SS- 3 and SS-4 also detected chlorinated herbicides but at concentrations below EPA regulatory screening levels. 6.1 OPINION AND RECOMMENDATIONS WGM’s ESA was performed in accordance with generally accepted practices of the profession undertaken in similar studies at the same time and in the same geographical area, and WGM observed that degree of care and skill generally exercised by the profession under similar circumstances and conditions. RCRA metals (barium and mercury) are present in surface soil adjacent to the abandoned rail spur located on the Subject Property. These metals are present at concentrations above preliminary EPA residential screening levels. Based on the findings of this ESA, WGM suggests if future development or redevelopment of the Subject Property includes residential use, then surface soil associated with the abandoned rail spur should be either removed and property disposed according to regulatory requirements, or further analyzed to evaluate risk. If future development will be commercial or industrial use only, then no additional action is recommended, as the concentrations detected were below initial screening levels for industrial/commercial use. 26 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment 7.0 ENVIRONMENTAL PROFESSIONAL STATEMENT I declare that, to the best of my professional knowledge and belief, I meet the definition of Environmental Professional as defined in 312.10 of 40 CFR 312 and I have the specific qualifications based on education, training, and experience to assess a property of the nature, history, and setting of the Subject Property. I have developed and performed all appropriate inquiry in conformance with the standards and practices set forth in 40 CFR Part 312. 9/30/2021 Tyler Etzel Senior Geologist WGM Group, Inc. 27 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment 8.0 REFERENCES American Society for Testing and Materials (ASTM) International. ASTM Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process (ASTM E 1527-13). <www.astm.org>. Architecture Trio, 2017. Historic Inventory Report for the BG Mill Property (former Montana Elevator Co Grain Elevator). Prepared by Architecture Trio, Inc. March 1, 2017. DEQ. Mapping DEQ’s Data. <http://svc.mt.gov/deq/dst/#/home>. Environmental Data Resources, Inc. (EDR). Accessed September 2, 2021. < https://edrnet.com/>. Environmental Solutions, 2019. Asbestos Inspection Report for BG Mill, BG Mill, East Mendenhall St./Broadway Ave., Bozeman, MT. Prepared for Pearson Design Group by Environmental Solutions. February 8, 2019. EPA. US Environmental Protection Agency. < https://www.epa.gov/>. Google Earth Pro. Accessed September 15, 2021. Kendy, E. and R. E. Tresch. Geographic, Geologic, and Hydrologic Summaries of Intermontane Basins of the Northern Rocky Mountains, Montana, U. S. Geological Survey Water-Resources Investigations Report 96-4025. 1996. SWDAR, 2001. Source Water Delineation & Assessment Report, City Of Bozeman, PWSID MT0000161. Prepared by Western Groundwater Services. February 22, 2001. SWDAR, 2005. Source Water Delineation & Assessment Report, Montana Kids Public Water System, PWSID MT0003940. Prepared by Montana Department of Environmental Quality. June 2005. US Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS). Custom Soil Resource Report. At <http://websoilsurvey.sc.egov.usda.gov/>. Accessed June 25, 2021. 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment APPENDIX A EXHIBITS E a s t G a l l a t i n R i v e rJackrabbitMai n Hwy 1 0 Mid d l e C r e e k Gallatin RiverBozeman C reek Bozeman Belgrade Four Corners Gallatin Gateway p Sedan Logan Menard Anceney Maudlow Trident Bozeman BelgradeChurchill Clarkston Manhattan Amsterdam Sappington Three Forks West Yellowstone Gallatin Gateway Big Sky Meadow Village State of Montana, USA Gallatin County, MT Subject Property Subject Property 0 2 4 61Miles EXHIBIT A-1 Phase I Location Map 714 E Mendenhall St Property Bozeman, MT 1111 E. Broadway | Missoula, MT 59802www.wgmgroup.com Disclaimer: This map is neither a legally recorded map nor a survey and is not intended to be used assuch. WGM Group does not guarantee the accuracy, current status, or completeness of the materialcontained herein and is not responsible for any misuse or misrepresentation of this information or itsderivatives. This map is a graphic representation and is to be used for general planning purposes only. Gallatin County2S 6E2018 Aerial01_LocationMap.mxd LOC:TR:BASE:FILE: PROJ MGR:DRAWN BY:PROJ:DATE: TEEC21-09-0909/15/2021 I-9 0 R GPROPERTIESLLC BOZEMAN 1RE2 LLC VILLAGEDOWNTOWNPUD SUB 777BUILDINGLLC PAPILLON LLC MONTANARAIL LINK 705 EASTMENDENHALL LLC CHEPULIS LLC STRONGCONDOMASTER E MENDENHALL ST NBROADWAYAVEUS 191 S WALLACE AVEN WALLACE AVECYPRESS AVEBUTTONWOOD AVEVILLAGE DOWNTOW N B L V D Subject Property Owner Parcels 0 100 200 30050Feet q EXHIBIT A-2 Phase I Site Map714 E Mendenhall St Property Bozeman, MT 1111 E. Broadway | Missoula, MT 59802www.wgm group.com Disclaimer: This map is neither a legally recorded map nor a survey and is notintended to be used as such. WGM Group does not guarantee the accuracy,current status, or completeness of the material contained herein and is notresponsible for any misuse or misrepresentation of this information or itsderivatives. This map is a graphic representation and is to be used for generalplanning purposes only. Gallatin County2S 6E2018 Aerial02_SiteMap.mxd LOC:TR:BASE:FILE: PROJ MGR:DRAWN BY:PROJ:DATE: TEEC21-09-0909/15/2021 0 0.25 0.5 0.75 10.125 Miles 1111 E. Broadway | Missoula, MT 59802www.wgm group.com Disclaimer: This map is neither a legally recorded map nor a survey and is notintended to be used as such. WGM Group does not guarantee the accuracy,current status, or completeness of the material contained herein and is notresponsible for any misuse or misrepresentation of this information or itsderivatives. This map is a graphic representation and is to be used for generalplanning purposes only. Gallatin County2S 6EUSGS Topo03_TopoMap.mxd LOC:TR:BASE:FILE: PROJ MGR:DRAWN BY:PROJ:DATE: TEEC21-09-0909/15/2021 q EXHIBIT A-3 Phase I Topo Map714 E Mendenhall St Property Bozeman, MT Subject Property !( !( !( !( SS-1 SS-2 SS-3 SS-4 Subject Property !(Surface Soil Sample Locations (SS-#)0 30 60 9015Feet q EXHIBIT A-4 ESA SurfaceSoil Sampling Map714 E Mendenhall St Property Bozeman, MT Vacant Offices 1111 E. Broadway | Missoula, MT 59802www.wgm group.com Disclaimer: This map is neither a legally recorded map nor a survey and is notintended to be used as such. WGM Group does not guarantee the accuracy,current status, or completeness of the material contained herein and is notresponsible for any misuse or misrepresentation of this information or itsderivatives. This map is a graphic representation and is to be used for generalplanning purposes only. Gallatin County2S 6E2018 Aerial04_SoilSamplingMap.mxd LOC:TR:BASE:FILE: PROJ MGR:DRAWN BY:PROJ:DATE: TEEC21-09-0909/26/2021 Grain Silos Storage Offices Pits/Scales North Broadway AveMendenhall St 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment APPENDIX B RECORDS REVIEW DOCUMENTATION *APPLICANT'S NOTE: APPENDIX B OF THE ENVIRONMENTAL ASSESSMENT IS A 900+ PAGE SECTION, COMPRISED LARGELY OF THE "RADIUS REPORT." IF REVIEW OF APPENDIX B IS DEEMED NECESSARY, IT WILL BE MADE AVAILABLE UPON REQUEST. 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment APPENDIX C SITE VISIT PHOTOS 1 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment SITE VISIT PHOTOS 714 EAST MENDENHALL ST PROPERTY 9.15.2021 BOZEMAN, MT VIEW FROM PARKING LOT LOOKING WEST 2 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment VIEW LOOKING AT NORTHEAST CORNER OF NORTHERN OFFICES 3 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment VIEW OF FLOOR STAINING IN NORTHERN OFFICES 4 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment VIEW OF OVERHEAD PIPES IN MAIN ELEVATOR ROOM 5 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment VIEW LOOKING DOWN INTO GRAIN VAULT PIT 6 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment VIEW OF ELECTRIC MOTORS IN MAIN ELEVATOR 7 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment VIEW OF ELECTRIC MOTOR AND GRAIN SHAFT 8 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment VIEW OF GRAIN HANDLING EQUIPMENT IN MAIN ELEVATOR ROOM 9 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment ACTIVE RAILROAD SPUR LOCATED ON ADJACENT SOUTH PROPERTY 10 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment ABANDONED RAILROAD SPUR ALONG SOUTHERN BORDER OF PROPERTY 11 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment WESTERN END OF ABANDONED RAILROAD SPUR LOOKING WEST 12 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment VIEW LOOKING EAST AT EXTERIOR OF GRAIN ELEVATOR 13 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment UNKNOWN PVC PIPE LOCATED WEST OF NORTHERN PARKING LOT 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment APPENDIX D RESUMES Tyler has more than 25 years of experience as a consulting scientist on complex, remediation-focused environmental projects. He has extensive experience in assessment, characterization and remedial cleanup of industrial facility chemical releases. His projects have ranged from multi-contaminant remediation sites to environmental due diligence projects including Phase I and II ESAs. He has successfully completed projects under many regulatory frameworks, including EPA Brownfields, CERCLA, LUST, CECRA, TSCA, and RCRA, projects that span a wide range of contamination profiles from organic hydrocarbons and PCBs to heavy metals, and projects that require interactions with clients, stakeholders, and regulatory agencies, and legal teams. He also has experience preparing MPDES permits, SWPPPs, and SPCC plans, and expert witness support. EDUCATION B.S., Environmental Geology, University of Montana, 1995 TYLER ETZEL, GIT, CAPM Scott Street Limited Liability Partnership Property (SSLLP), Missoula, MT — Lead Scientist Prepared a Data Summary and Environmental Liability Report to assist the City of Missoula with due diligence for acquisition and redevelopment of the Scott Street Limited Liability Partnership Property (SSLLP) Site. The SSLLP Site is located within the boundaries of the Missoula White Pine Sash (MWPS) Facility, a former lumber mill and wood treating facility that is a Montana DEQ State Superfund Site listed on DEQ’s CECRA Priority List. The report provided a summary of environmental data; a description of regulatory involvement since being listed in 1994; remedial actions performed to date; geotechnical data; a summary of potential data gaps associated with characterization of impacted media; and an analysis of environmental liability associated with potential acquisition and redevelopment of the property. Stimson Lumber Cooling Pond Remedial Action, Bonner, MT — Project Manager/Lead Scientist Teamed with Envirocon to remove PCB-impacted sediment and soil associated with a historic lumber Millsite located adjacent to the Blackfoot River in Bonner. Served as Project Manager and Lead Project Scientist for delineating and remediating PCB- laden sediment and soil. The work was conducted to comply with requirements of an Administrative Order on Consent (AOC) with MDEQ and EPA TSCA requirements. During the 10-year project, over 250 borings were advanced and over 110,000 cubic yards of PCB- impacted material was excavated and disposed at an onsite repository and other designated facilities. SENIOR GEOLOGIST WGM GROUP, INC., Senior Geologist/Project Manager, 3 years OTHER FIRMS, 17 years NEWFIELDS, Senior Geologist/Project Manager, 5 years PROFESSIONAL EXPERIENCE PROJECT EXPERIENCE PROFESSIONAL AFFILIATIONS American Institute of Professional Geologists (AIPG- GIT, Washington) National Groundwater Association (NGWA) Certified Associate Project Management Professional (CAPM) Missoula Manufactured Gas Plant Site (Free Cycles), Missoula, MT — Project Scientist/ Manager Conducted assessment work at this site beginning in 1999 with a supplementary Phase II Investigation of soil and groundwater, which included drilling three additional soil borings and collecting groundwater samples. Additional investigation assessment of COCs and submittal of a follow-up assessment report. More recently, working for the City of Missoula Brownfields Program, additional assessment included preparation of a remedial alternative analysis with objectives including: assessment of existing environmental reports, description of known conditions, identification of data gaps and remedial options, and development of a work plan to address Brownfields requirements. The remedial alternative analysis provided six alternatives using DEQ’s standardized procedure. A targeted, Phase II ESA was conducted to evaluate surface soils information and provide recommendations for follow-up actions to limit exposure. Gershman Investment Corp. Phase II ESA, Missoula, MT — Project Manager and Lead Scientist Completed a Phase II ESA for Gershman Investment Corp at a property located adjacent to the Missoula Manufactured Gas Plant Site in Missoula, MT. The Phase II ESA complied with ASTM E1903-19 and US Department of Housing and Urban Development (HUD) requirements. Objectives included assessing contamination; evaluating exposure pathways and potential receptors; conducting a risk evaluation; and, determining if concentrations could result in potential vapor encroachment. A Tier 2 analysis showed contaminants did not present a risk above the DEQ allowable risk levels. Additional analysis based on HUD critical distance requirements showed that vapor encroachment was unlikely. WGM recommended conservative mitigation measures to assure no exposure pathways were present to onsite receptors. MRL Triangle Montana Rail Link 1930 South Avenue West Facility, Missoula Montana — Lead Project Scientist Currently assisting the City of Missoula, via US EPA Brownfields funding, in developing and implementing a Voluntary Cleanup Plan (VCP) Environmental Assessment (EA) for the MRL Triangle Montana Rail Link 1930 South Avenue West Facility. The MRL Triangle Site is a State Superfund (CECRA) Site with contamination related to historical railroad maintenance activity and historic lumber mill activity that contaminated soil with lead and PAHs. The work is being conducted in accordance with a DEQ-approved VCP in order to meet DEQ and EPA standards for residential reuse, with the ultimate goal of delisting the Site from the State Superfund program. Missoula White Pine & Sash (MWPS) Facility, Missoula, MT — Project Manager/Scientist Development of a SAP for contaminant delineation, soil and waste management, and a Report of Findings at a former wood treatment State Superfund site. Contaminants of concern include pentachlorophenol and dioxins/furans. Assisted the City with the remedial actions required to be completed to allow for redevelopment on the site. Additional duties included completion of a RCRA-compliant soil handling plan describing actions for how excavated soil was managed, characterized, and disposed of for a City water main extension project. The plan also described equipment decontamination procedures during construction. Developed a sampling and analysis plan, contaminant delineation procedures, soil characterization procedures, and cradle-to-grave management using RCRA hazardous waste protocols. Prepared RCRA hazardous waste Contained-In Determination documents for removed soil. CONTINUINGEDUCATION PSMJ Resources – Project Management Bootcamp 40-Hour HazMat Certified Underground Storage Tank (UST) Management Advanced Groundwater Training with Pesticides Waterloo Hydrogeologic Groundwater Training Waterloo Hydrogeologic Remediation Training Spill Prevention Control and Countermeasure (SPCC) EPA Workshop Confined Space Entry and Rescue H2S Safety Training TYLER ETZEL, GIT, CAPM SENIOR GEOLOGIST LICENSES/CERTIFICATIONS Environmental Professional Per ASTM 1527-13 Milltown Reservoir Sediments CERCLA, Milltown, MT — Project Manager Assessed heavy metal contamination in sediments behind the Milltown dam. The work was conducted to assist delineation of metals in sediments and was performed as part of the remediation of 6.6 million cubic yards of heavy metal laden sediments. Managed the groundwater monitoring phase, which included groundwater data statistical analysis describing the spatial and seasonal plume geometries of metals through GMS modeling. Missoula Professional Baseball Park Brownfield Site, Missoula, MT — Project Scientist Completed Phase I/II ESA assessment of a portion of this state-listed (CECRA) site (Missoula Champion Mill). Helped complete a historical analysis of past industrial activities and waste streams/releases, and performed the subsurface investigation to assess site contamination and risks on the baseball park site. The full characterization of the site allowed removal of a portion of land from the state- listed site for development of the ballpark. Ice Box Canyon, Phase II Subsurface Investigation, Bigfork, MT — Project Scientist Completed a Phase II Subsurface Investigation for MDT at the former Shorty’s Gas Station Site in Bigfork, Montana. The work included a geophysical survey for potential UST and UST appurtenances related to the former gas station and an assessment of surface soil and groundwater impacts along MDT’s ROW. Results of the geophysical survey identified buried linear anomalies within MDT ROW. Soil and groundwater samples collected from the Site suggested that soil and groundwater along the MDT ROW was not impacted by COCs associated with former use as a gas station and no additional assessment of cleanup work was recommended for the site. S&W Sawmill CECRA Site, Darby, MT — Project Manager and Lead Project Scientist Lead Project Scientist and Project Manager for a Subsurface Soil Investigation at this State Superfund site. Soil samples were collected from a portion of the former S&W Sawmill site to identify the presence of PCP and dioxin/furan contaminants and assist in the determination of whether a portion of the site could be excluded from CECRA designation. Stimson Lumber Co. Fire Pond Lagoon LUST Remediation, Bonner, MT — Project Scientist Work at the site included completing remedial actions to define the extent of soil and groundwater impacts from historic hydraulic equipment and seepage of PCB-impacted oil into the Blackfoot River. A Remedial Alternatives Analysis was performed to evaluate source removal, cut-off walls, bioslurping, and product recovery to eliminate seepage into the river. The remedial actions culminated in removal and disposal of 1,180 cubic yards of contaminated soil. Milltown Dam Transformer Site, Milltown, MT — Project Scientist Completed remedial actions on an abandoned transformer disposal site near the former Milltown Dam for Montana Power Company. Conducted a geophysical (magnetic) survey of the site to identify buried metallic objects. The survey identified six anomalous regions and subsequent excavations found transformer and transformer parts in each of the areas, with one area containing thirty-eight transformers. Little evidence of petroleum or PCB contaminated soil were found in the excavations and the site was cleared for cleanup associated with the Milltown Reservoir Sediments NPL/CECRA project. TYLER ETZEL, GIT, CAPM SENIOR GEOLOGIST COMMUNITY INVOLVEMENT Missoula Aquatic Club Board of Directors – President & VP Missoula Water Quality District Advisory Council City of Missoula Brownfields Program, Missoula, MT — Qualified Environmental Professional Conducts Phase I and Phase II ESAs and completes all necessary reports to ensure the City of Missoula Brownfields Program remains EPA-compliant and promotes redevelopment of properties. Snowy Mountain Development Corporation/Central Montana Brownfield Coalition, Lewistown, MT — Qualified Environmental Professional Selected as a Qualified Environmental Professional (QEP) for this 501(c)(3) non-profit organization to assist with Brownfields Phase I/II ESA and cleanup plans to support environmental due diligence and responsible redevelopment within an eleven county area including Gallatin, Park, Fergus, Judith Basin, Golden Valley, Musselshell, Petroleum, Wheatland, Broadwater, Lewis and Clark and Meagher Counties. City of Kalispell Brownfields Assessment, Kalispell, MT — Qualified Environmental Professional Performed QEP services and extensive Environmental Due Diligence assessments for the Kalispell Core and Rail Development project in the center of Downtown Kalispell. Big Sky Economic Development (BSED) Brownflelds Projects, Billings, MT — Project Manager Project Manager for hazardous substance and petroleum assessment projects in the East Billings Urban Renewal District (EBURD). Projects included Brownfields Phase I and II site assessments and completing all reports (SAPs, QAPPs, HASPs) to ensure the BSED Brownfields Program remained EPA-compliant while promoting redevelopment of properties. Headwaters Resource Conservation and Development (RC&D), Butte, MT — Qualified Environmental Professional Project Manager for this EPA Brownfields assessment coalition grant. The work includes conducting Phase I and Phase II ESAs, preparation of an inventory of brownfield sites, and prioritizing brownfields sites. Assessment activities focus on southwestern Montana counties including Anaconda-Deer Lodge, Beaverhead, Butte-Silver Bow, Granite, Jefferson, Madison, and Powell. Coalition partners are the Butte Local Development Corporation and Anaconda Local Development Corporation. Confederated Salish and Kootenai Tribes Brownfield Project, Polson, MT — Project Scientist Tasks included development of a Cleanup Plan for the Former Joseph Allotment to remediate petroleum hydrocarbon impacts to groundwater that migrated onto this site from an adjacent Brownfields site. Great Northern Development Brownfields Assessment, Wolf Point, MT — Project Scientist Performed a technical review of Phase I and Phase II documents from a former airport site in Poplar, Montana. Focused on a Proposed Development Area of the former airport property to determine whether potential recognized environmental conditions were fully characterized. TYLER ETZEL, GIT, CAPM SENIOR GEOLOGIST Bear Paw Development Corporation Brownfields Assessment, Wolf Point, MT — Project Scientist Prepared a Background Study Sampling and Analysis Plan on a Voluntary Cleanup and Redevelopment (VCRA) Program site to investigate impacts related to historical pesticide application at a former airport in Malta, Montana. Fort Peck Tribes Brownflelds Projects, Poplar, MT — Project Manager Completed Phase I ESAs on 18 large ranch properties on the Fort Peck Indian Reservation. Fort Peck Tribes commissioned due diligence on these properties to acquire individual fee-land and restore it into Tribal Trust land. Venture Petroleum Leaking Underground Storage Tank Investigation, Libby, MT — Project Manager and Lead Project Scientist Evaluated impacts to soil and groundwater from a diesel fuel spill. Completed a feasibility study, which recommended removal and thermal desorption of impacted soils, installation of an in situ biovent treatment system, and extended monitoring of the impacted groundwater resources. Performed oversight of the removal and thermal desorption of 3,100 tons of soil. Removed and treated groundwater on site with activated carbon. Kootenai Business Park Assessment & Remediation Design, Libby, MT — Project Manager/Lead Scientist Served as Lead Project Scientist and Project Manager to characterize environmental conditions on this former industrial wood products site. The assessments documented PCP contamination related to the Libby Groundwater and Asbestos Federal Superfund sites. The data was used to determine potential risks to construction workers and assist in design of remediation plans for areas of the business park most suitable for development. I-90 Auto Truck Plaza Leaking Underground Storage Tank Investigation, Deer Lodge, MT — Project Manager and Lead Project Scientist Duties included design and implementation of groundwater excavation pumping and soil vapor extraction pilot tests, bioremediation testing and evaluation, assisting in extraction well and remediation system design, analysis and interpretation of data, modeling for capture zone analysis, and budget development and cost tracking. Provided oversight of the removal of three USTs within the tank basin, excavation and disposal of contaminated soils, pumping and disposal of over 13,000 gallons of petroleum-contaminated groundwater, and installation of horizontal soil vapor extraction (SVE) piping. Greenough Cattle Company Phase II Investigation, Missoula, MT — Project Manager Duties included assessment and remediation of soil and groundwater impacted from gasoline and pentachlorophenol waste at this 10,000-acre ranch and LUST site. The Phase II Remedial Investigation revealed the presence of a large gasoline plume in soil and groundwater, one abandoned UST, and a dissolved-phase plume of pentachlorophenol in shallow groundwater. Performed oversight of the UST removal and 1,100 cubic yards of associated contaminated soil, and pumping and treating over 30,000 gallons of contaminated groundwater. Remedial actions also included characterization and removal of PCP-impacted soil. Stromberg Enterprises Remedial System Design/Installation, Havre, MT — Project Scientist Designed and installed an automated in situ groundwater bioremediation system. The TYLER ETZEL, GIT, CAPM SENIOR GEOLOGIST project involved slug testing the shallow aquifer, design/installation of dissolved oxygen injection wells, design/installation of LNAPL and vapor extraction wells, and monitoring for enhanced natural attenuation parameters. Summarized mass removal for the remediation systems, and performed a limited risk-assessment of the hydrocarbon plume affecting water quality down gradient of the site. 4,145 cubic yards of petroleum-impacted soil was removed and an air-sparging vapor extraction system was installed. Wagons West Motel & Campground Phase II & Ill Environmental Site Assessments, Augusta, MT — Project Scientist Managed the remedial investigations of this LUST site, including development of project work plans/budgets, oversight of staff, and analysis of technical data. Work included removal and disposal of USTs and associated contaminated soil. Contaminated groundwater within the excavation was removed and hauled to a licensed disposal facility. The site was closed by MDEQ after two years of groundwater monitoring showed groundwater impacts to be below state screening levels. Tribal LUST Remediation Sites — Lead Project Scientist Site Specific Corrective Actions for Custers, MT (Northern Cheyenne Indian Reservation) Zephiers, Batesland, and Denby, SD (Pine Ridge Indian Reservation) Fort Yates, ND (Standing Rock Indian Reservation). Teamed with Timberline Resources and sanctioned a Mentor/Protégé relationship under the Small Business Administration’s Mentor/Protégé Program. Served as Lead Project Scientist for the EPA-required corrective actions performed at these five LUST sites. Duties included scope of work, sampling and analysis plans, health and safety plans, budgets, TERO compliance, bid solicitations, sub- contractor coordination, LUST removal, and contaminated soil excavation. East Poplar Oil Field Brine Feasibility Study and Groundwater Investigation, Poplar, MT — Project Manager and Project Scientist Completed a groundwater investigation and corrective actions feasibility study on oil and gas derived brine plume that leaked into a shallow drinking water aquifer northeast of Poplar. The work was completed under an EPA Administrative Order on Consent to three oil companies that may have been contributors to the impacted water supply. All investigations and analysis were completed in concert with the Fort Peck Tribes. An additional EAO required the respondents to initiate water quality monitoring at COP public water supply wells. Developed a SAP with rigorous data quality objectives (DQOs) and data quality indicators (DQls). The EAO required that the water system sampling and reporting be performed on an expedited schedule, which required a high level of coordination between consultant personnel and all stakeholders. Molt Petroleum Contamination Site Remedial Design Report, Molt, MT — Project Scientist Completed a Supplemental Investigation and Remedial Design Report to determine the most effective means of remediating petroleum contamination of soil and groundwater. The investigation assessed site conditions and confirmed whether previous investigations adequately characterized the soil and groundwater contamination. The Remedial Alternatives Analysis (RAA) and subsequent remedial design section evaluated multiple remedial options and recommended treatment methods to clean up petroleum contamination in soil and groundwater to pre-release conditions. TYLER ETZEL, GIT, CAPM SENIOR GEOLOGIST Expert Witness Vapor Intrusion Evaluation, Roundup, MT — Project Scientist Assisted with data collection and evaluation to provide an Expert Report and a Rebuttal Report for a confidential client to refute toxic tort claims of vapor intrusion in a private residence. The data and reports contended that the source of the vapor intrusion was not from the client and that vapor intrusion was not impacting the private residence. As a result of the findings, compensatory damages claims were reduced for the client. Expert Report Rebuttal, Condon, MT — Project Scientist Provided a Rebuttal Report to refute claims provided In an Expert Report regarding the origin, timing, extent & magnitude, necessity, and cost of remedial actions for a petroleum release. As a result of the report, compensatory damages claims were significantly reduced for the client. Sadowsky Truck Spill Response on Interstate 94, Glendive, MT — Project Manager Performed excavation and remedial cleanup of petroleum-contaminated soils, which was required by MDEQ Enforcement, for this emergency response semi-truck spill of 4,000 gallons of mixed gasoline and diesel. The work involved a traffic control plan, traffic control subcontractor, preparation of a temporary haul road in the ditch of the interstate, excavation of contaminated soil in the barrow-ditch, disposal of impacted soil at a licensed facility, and compaction/restoration of the disturbed area. MDT required interstate highway specifications for backfill, compaction, and restoration. Approximately 2,000 cubic yards of soil required excavation. Michaels West Spill Response, Kalispell, MT — Project Manager and Lead Project Scientist Managed the remediation process for this 10,000-gallon gasoline release, which infiltrated storm water and sanitary sewer pipes. Corrective actions included total fluids recovery at several points on the release site and in the right-of-way, and vapor extraction of water and storm water utility trenches. Recovered water was treated at both on and off site locations to remove all gasoline compounds to below detection limits. The treated water was permitted for discharge to a small creek under a Montana DEQ general discharge permit for petroleum contaminated groundwater. Subsequent remedial actions included design, installation, and operation of two air-sparging soil vapor extraction systems - one within MDT right-of-way and the other within the on-site UST basin. Stratnor Oil Spill Response, Sidney, MT — Project Manager and Lead Project Scientist Managed the remediation process for this crude oil spill at a frac tank oil storage facility in the Bakken Oil Field. Three 21,000-gallon mobile frac tanks were overfilled during loading and leaked crude, which migrated off the secondary containment liner and impacted adjacent soils. Two response actions were completed that included excavations and confirmatory soil sampling to delineate the impacted soil cleanup. Following the cleanup actions and associated reporting, the spill was issued a closure letter by DEQ Enforcement. Mountain States lntertie Transmission Project EIS, Montana/Idaho — Project Geologist Work for this linear EIS project included total transmission line routing options over 1,100 miles long, and an even longer supporting road network. Included scoping, technical reports, geological hazards assessment and evaluation, draft and final EIS sections, and responding to comments. Evaluated the potential for direct, indirect, and cumulative impacts to the project from geological hazards. TYLER ETZEL, GIT, CAPM SENIOR GEOLOGIST XTO Energy Minerals Exploration, Williams County, North Dakota — Project Scientist Assisted in the development of multiple EAs in support of oil exploration activities on US Army Corps of Engineers property near Williston, ND. Developed 17 EAs (16 well pads and one road improvement segment), 16 of which were approved by the BIA with FONSls. SPCC Plans for MDT Maintenance Facilities, Missoula, Kalispell, Shelby, Great Falls, Havre, Wolf Point, Glendive, Miles City, Billings, Roy, Lewistown, Butte — Project Manager Ongoing work includes Preparation and updates of Spill Prevention Control and Countermeasures (SPCC) plans for maintenance sections throughout Montana. The work includes reviews of facility records and correspondence with MDT maintenance personnel to coordinate site inspections. Field reconnaissance of each Maintenance Section Site was performed to identify: general facility and land usage information; determination of substantial harm criteria; storm water/process water discharges; oil & fuel storage information; delivery tank truck compartment capacities; spill prevention design measures; critical situations; tank evaluations; potential tank disposal or removal; the SPCC coordinator and the alternate SPCC coordinator. Site observations were noted, mapped, and photographed. Recommendations for physical or operational changes were relayed to MDT personnel to comply with SPCC regulation. An SPCC report is being completed for each Maintenance Section Site. Phase II Site Investigation, 2nd Ave North and 9th Street, Great Falls — Consulting Scientist A Phase II Subsurface Investigation was performed to delineate potential impacts to soil and groundwater along MDT’s planned construction corridor. Fieldwork preparation included correspondence with local business owners or tenants of the planned work; traffic control groundwork; subcontractor coordination; and supervision of detailed utility locates. The subsurface assessment included completing forty-eight (48) Geoprobe® direct push borings with collection of forty-six (6) soil samples and four (4) groundwater samples. The report compiled field and analytical data from the investigation to characterize concentrations on hazard or risk potential, and define approximate linear and vertical limits of contaminants. Potential risks to city waterlines were noted along with recommendations for further investigation along six (6) areas of MDT’s planned construction corridor. UST Removal Tradewinds Realty, Polson — Consulting Scientist UST Removal Project at the former Tradewinds Realty property in Polson, Montana. The work included removing five (5) underground storage tanks (USTs) and completion of a site assessment to identify the quantity and magnitude of potentially impacted soil. Fifty- four cubic yards of petroleum-impacted soil was excavated, stockpiled, and hauled to the BFI sanitary landfill in Missoula. Results of the confirmation soil sampling showed the majority of impacts below laboratory detection limits. Land & Water/PBS&J recommended no further investigations on the former Tradewinds Property. TYLER ETZEL, GIT, CAPM SENIOR GEOLOGIST Melissa is a Principal Engineer and Project Manager with more than 18 years of experience in the civil and environmental engineering fields. She heads WGM Group’s Environmental Division and is a LEED Accredited Professional specializing in MEPA/ NEPA document preparation, environmental permitting, open channel hydraulics, small water system and on-site wastewater design, and storm drainage systems. Melissa is known for her communication skills as part of a project team, both written and oral, and is effective at conveying technical information to audiences with varying expertise. At WGM Group, Melissa develops and implements natural resource studies and designs, prepares MEPA and NEPA documents, conducts Phase I and II environmental site assessments, and provides water-related permitting services. LICENSES/ CERTIFICATIONS EDUCATION Professional Engineer Montana 18385 LEED A.P., U.S. GreenBuilding Council Certified Site Evaluator, Missoula City-CountyEnvironmental Health Dept. M.S., Project Engineering and ManagementMontana Tech2008 B.S., Civil Engineering Georgia Institute ofTechnology2002 MELISSA MATASSA-STONE, PE, LEED AP MDT Environmental Engineering Term Contract, Missoula District — Project Manager Serves as Project Manager providing monthly reporting to MDT and coordination of resources for SWPPP permit transfers and final inspections, MDT maintenance staff training to perform SWPPP Administration, and MS4 permitting requirements in MDT’s Missoula District, frequently within limited response time frames. Missoula Brownfields Assessment Grant, Missoula, MT — Project Manager Serves as project manager for environmental cleanup planning, community outreach, and site prioritization for the City of Missoula Brownfield Assessment Grant. Responsible for ACRES reporting, quarterly and QA/QC of deliverables, and meeting project schedules and budgets. Russell Street Improvements, Missoula, MT — Project Engineer Working with MDT to provide improvements on two miles of Russell Street in Missoula. Designing and coordinating irrigation ditch improvements for three different ditch companies, including culvert extensions, replacements, and realignments, plus permitting services. Leading the storm drainage design efforts and assisting with hydraulic analysis. Old Sawmill District, Missoula, MT — Project Engineer Serves on the design team for overall development of this 31-acre Brownfield site in downtown Missoula, with focus on storm drainage and floodplain interactions. Responsibilities include infrastructure design and cost estimating. Performed grading and road relocation in support of methane abatement measures during site cleanup. Obtained County Floodplain Permit for site grading in advance of successful FEMA LOMR application to remove all areas slated for building construction from the regulatory floodplain. EXECUTIVE OFFICER/PRINCIPAL ENGINEER WGM GROUP, INC., Principal Engineer, 15 years TENNESSEE VALLEY AUTHORITY, Environmental Engineer, 2 years ISLANDWOOD (AmeriCorps), Restoration Ecology Intern, 1 year PROFESSIONAL EXPERIENCE PROJECT EXPERIENCE MDT Environmental Engineering Term Contract, Missoula District — Project Manager Serves as Project Manager providing monthly reporting to MDT and coordination of resources for SWPPP permit transfers and final inspections, MDT maintenance staff training to perform SWPPP Administration, and MS4 permitting requirements in MDT’s Missoula District, frequently within limited response time frames. Missoula Brownfields Assessment Grant, Missoula, MT — Project Manager Serves as project manager for environmental cleanup planning, community outreach, and site prioritization for the City of Missoula Brownfield Assessment Grant. Responsible for ACRES reporting, quarterly and QA/QC of deliverables, and meeting project schedules and budgets. Russell Street Improvements, Missoula, MT — Project Engineer Working with MDT to provide improvements on two miles of Russell Street in Missoula. Designing and coordinating irrigation ditch improvements for three different ditch companies, including culvert extensions, replacements, and realignments, plus permitting services. Leading the storm drainage design efforts and assisting with hydraulic analysis. Old Sawmill District, Missoula, MT — Project Engineer Serves on the design team for overall development of this 31-acre Brownfield site in downtown Missoula, with focus on storm drainage and floodplain interactions. Responsibilities include infrastructure design and cost estimating. Performed grading and road relocation in support of methane abatement measures during site cleanup. Obtained County Floodplain Permit for site grading in advance of successful FEMA LOMR application to remove all areas slated for building construction from the regulatory floodplain. 2014 Report Card for Montana’s Infrastructure — Committee Chair Led efforts of a 30-person volunteer committee to develop the first Report Card for Montana’s Infrastructure, issued in November 2014. The eight infrastructure categories reviewed include Dams, Drinking Water, Irrigation Canals & Waterways, Schools, Solid Waste, Transit, Transportation, and Wastewater. Volunteers were largely engineers from both the public and private sectors, located statewide across Montana. Worked closely with the National chapter of the American Society for Civil Engineers, obtaining two grants from the National chapter to fund development and outreach costs. Serves as key contact for outreach efforts, including interviews with print, radio and television media; state legislative action, including testimony to the Legislature; and presentations at conferences/workshops and to citizen groups including School District Boards. Libby Riverfront Park, Libby, MT — Project Manager Provided master planning and site design for a 17-acre City park on the Kootenai River located on an Environmental Protection Agency (EPA) Superfund site, following clean-up activities. This project was a unique opportunity for the City of Libby to coordinate with the EPA, DEQ, and contractors to facilitate site improvements, including grading, storm drainage design, road relocation, and construction of a sewer main, so the site was ready to be transformed into a recreational amenity. Responsibilities included coordination with the EPA for project funding and restoration activities, cost estimating and quantity verification, technical presentations to the City Council and EPA, construction support, and service as a trusted advisor on technical matters to the City of Libby as they worked to overcome a history of distrust and confrontation with the EPA. The success of this PROFESSIONALAFFILIATIONS CONTINUING EDUCATION American Society of Civil Engineers, Montana Section Managing NEPA Projects & Teams, Shipley Group, 2019 MT iLead Breakthrough Leadership Program, 2017 Association of Montana Floodplain Managers Annual Conference, 2013-2018 Pump Characteristics and Applications, Volk & Associates, 2014 PSMJ PM Boot Camp, 2013Trenching & Excavation Safety Training, 2013 ASTM Training, Phase I & II Environmental Site Assessments for Commercial Real Estate, 2010 MELISSA MATASSA-STONE, PE, LEED AP EXECUTIVE OFFICER/PRINCIPAL ENGINEER project is seen as a feather in the EPA’s cap, and is the basis for an EPA Case Study “Out of the Dust: Recreational Reuse After Vermiculite Mining – The Libby Asbestos Superfund Site in Libby, Montana.” Milwaukee Railroad Path, Missoula, MT — Project Manager Designed 1.25 miles of asphalt bike/pedestrian path in the heart of Missoula, including seven irrigation ditch structures for two ditch companies, enhanced road crossings, drainage, and utility relocation. Provided contract administration for the $600,000 project. CTEP, City of Missoula, Montana Fish Wildlife and Parks, and the Missoula Redevelopment Agency provided funding for the project. Wyoming Street, Missoula, MT — Project Manager Designed four blocks of Wyoming Street, a local collector, across a vacant brownfields site, including complete streets guidelines, LED street lighting, wet utility stub-outs with methane mitigation accommodations, and large irrigation ditch re-routing. Coordinated construction efforts with two other projects with a shared funding source, each with a different engineer and contractor, being constructed simultaneously on the site. Project awards include 2013 Project of the Year with < $10M in Construction (American Society of Civil Engineers, Region 8) and 2013 Best Reconstruction of Urban/City Road (Montana Contractor’s Association). US Highway 93 Whitefish West, Whitefish, MT — Project Engineer Worked with MDT on the storm drainage and permitting parts of this project to reconstruct approximately five miles of US Highway 93 beginning in downtown Whitefish and extending west to Twin Bridges Road. Performed hydraulic analysis for culvert crossings, including floodplain implications for Spencer Lake. Led permanent erosion and sediment control analysis, water quality permitting, and development of FEIS re-evaluation. Stevensville Main Street Improvements, Stevensville, MT — Project Manager Assisted Stevensville and Ravalli County to upgrade Main Street in downtown Stevensville. Included sidewalk improvements/curb extensions, landscaping, benches, bike racks, trash receptacles, storm drainage upgrades, and provisions for future street lighting. Coordinated with concurrent Montana Department of Transportation projects for sidewalk replacement, water main upgrades, and pavement resurfacing. Prepared PS&E packages, assisted with bidding, performed construction management, and completed all necessary permitting. NEPA/MEPA PERMITTING PROJECTS • Fairgrounds Road Path, Hamilton, MT — Project Engineer • Stemple Pass, Lincoln, MT - Project Engineer • Whitefish West Final EIS Re-evaluations, Whitefish, MT — Project Engineer • Whitefish 2nd Street Improvement Project, Whitefish, MT — Project Engineer • 5th/6th/Arthur/Maurice Avenues Project, Missoula, MT — Project Engineer • MT 200 & HWY 10, Bonner, MT — Project Engineer • US 2 & Spring Creek Drive/Sunset Drive, Evergreen, MT — Project Engineer • Arlee Safe Sidewalks (TA), Arlee, MT — Project Engineer • Westside Road Improvements, Hamilton, MT —Project Engineer • Willow Creek Road Improvement Project, Covallis, MT — Project Engineer • 4th Avenue East Sidewalks, Polson, MT — Project Engineer • Florence Sidewalks (CTEP), Florence, MT — Project Engineer PRESENTATIONS Montana Contractors Association Conference Presenter, 2018 Association of Montana Floodplain Managers Conference, Presenter, 2016 Montana Joint Engineers Conference, Presenter, 2014 CONTINUINGEDUCATION ASCE Webinar - Understanding HEC-RAS Errors, Warnings and Notes, 2009 Intro to Brownfields in EPA Region 8, 2008 MELISSA MATASSA-STONE, PE, LEED AP EXECUTIVE OFFICER/PRINCIPAL ENGINEER • North Higgins Improvements Project, Missoula, MT - Project Engineer FLOODPLAIN AND HEC-RAS ANALYSIS PROJECTS • Russell Street, Missoula, MT - Project Engineer • Old Sawmill District, Missoula, MT - Project Engineer • US 2 & Spring Creek Drive/Sunset Drive, Evergreen, MT - Project Engineer • Starvation Creek, Clinton, MT - Project Engineer • 8-Mile Creek, Florence, MT - Project Engineer • Grant Creek Floodplain Analysis, Missoula, MT - Project Engineer • Kootenai Creek Bridge, Ravalli County - Project Engineer • Sweathouse Creek Bridge, Ravalli County - Project Engineer MELISSA MATASSA-STONE, PE, LEED AP EXECUTIVE OFFICER/PRINCIPAL ENGINEER After graduating with a degree in Environmental Engineering Science, Michelle spent two years serving her communities through AmeriCorps. Through these programs, she worked with both state and county agencies to perform environmental monitoring and to help engage communities with their environment, water resources and public health. She has experience providing technical, financial and managerial assistance, related to groundwater and surface water monitoring, water, wastewater, and solid waste systems. LICENSES/ CERTIFICATIONS EDUCATION Engineer-in-Training: California: 161828 R. ProtectWET Educator Certified B.S., Environmental Engineering Science, Minor in Conservation Resource Studies, UC Berkeley2016 Water Resource Engineering Master’s Program - Semester Abroad at Lund University, Sweden MICHELLE POND, EI Nutrient Groundwater Assessment, Big Sky, MT — Intern Evaluated nutrient loads from sources in the Upper Gallatin River Watershed near Big Sky, Montana. Performed literature review on nutrient loading quantification based on septic type and condition. Prepared summary memorandum summarizing findings, nutrient load estimates and cost range of reduction measures. Due-Diligence for Planned Unit Development- Big Sky, MT — Intern Evaluated disposal options and land suitability. Assisted with technical memo summarizing conceptual alternatives, opinion of probable costs, and required permits/ approvals. Canyon Sewer PER, Big Sky, MT — Intern Assisted with the preparation of Preliminary Engineering Report (PER) for collecting numerous existing septic systems for central treatment and disposal along the canyon corridor. PROFESSIONAL PRESENTATIONS & TRAININGS CONDUCTED • Financial Reporting Tips for Effective Management of Small Utilities – operators, clerks and financial officers • Understanding Source Water Protection Plans in Montana - operators • Asset Management for Small Water and Wastewater Systems - operators and clerks • Stream Teams Water Quality Monitoring Training – citizen scientist volunteers • Lab and Field Procedures for Water Quality and Flow Monitoring – Montana State University students • Aquatic Macroinvertebrates and Water Quality – various school groups • Well Aware Course – private well owners in Gallatin County ENVIRONMENTAL ENGINEER INTERN WGM GROUP, INC., Environmental Assistant, <1 year OTHER FIRMS, 2 years MIDWEST ASSISTANCE PROGRAM, Technical Assistance Provider, 1 year PROFESSIONAL EXPERIENCE PROJECT EXPERIENCE • The Water Cycle – all 4th grade classes in Gallatin County • Bioengineering for Sustainable Stream Bank Stabilization – community members and school groups • Safe Water Storage in Point of Use Water Systems – UC Berkeley students TECHNICAL SKILLS PROFESSIONAL AFFILIATIONS CONTINUINGEDUCATION ArcGIS PRO MATLAB ESRI Story Maps Microsoft Office Suite Big Sky Watershed Corp Member, 2018 Oakland Watershed Stewards Program Member, 2016-2017 Sludge Handling and Disposal Techniques, RCAP Setting the right rates, AWWA Facilitation, Tara Kuipers Consulting, LLC Treasure State Endowment Program Grant Workshop, MT Department of Commerce MICHELLE POND, EI ENVIRONMENTAL ENGINEER INTERN 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment APPENDIX E QUESTIONNAIRE 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment APPENDIX F FIELD NOTES In certain circumstances, samples submitted to Energy Laboratories, Inc. may be subcontracted to other certified laboratories in order to complete the analysis requested. This serves as notice of this possibility. All subcontracted data will be clearly notated on your analytical report. Chain of Custody & Analytical Request Record Page _____ of _____www.energylab.com Account Information (Billing information) Report Information (if different than Account Information) CommentsCompany/Name Company/Name ContactContactPhonePhoneMailing Address Mailing Address City, State, Zip City, State, Zip EmailEmailReceive Invoice Hard Copy Email Receive Report Hard Copy Email Receive Report Hard Copy Email Purchase Order Quote Special Report/Formats:  LEVEL IV  NELAC  EDD/EDT (contact laboratory)  Other______________ Project Information Matrix Codes A - Air W- Water S - Soils/ Solids V - VegetationB - Bioassay O -Other DW -Drinking WaterAnalysis RequestedAll turnaround times are standard unless marked as RUSH. Energy Laboratories MUST be contacted prior to RUSH sample submittal for charges and scheduling – See Instructions PageProject Name, PWSID, Permit, etc. See Attached Bottle Order Sample Origin State EPA/State Compliance  Yes  No Sampler Name Sampler Phone Sample Identification (Name, Location, Interval, etc.)Collection Number of ContainersMatrix (See Codes Above)RUSH TATELI LAB ID Laboratory Use OnlyDate Time 1 2 3 4 5 6 7 8 9 10 Custody Record MUST be signed Relinquished by (print) Date/Time Signature Received by (print) Date/Time Signature Relinquished by (print) Date/TimeSignatureReceived by Laboratory (print)Date/TimeSignatureLABORATORY USE ONLY Sample Disposal Client Lab Shipped By Cooler ID(s) Custody Seals Y N C B Intact Y N Receipt Temp °C Temp Blank Y N On Ice Y N Payment Type CC Cash Check__________ Amount $ Receipt Number (cash/check only) WGM GROUP, INCTYLER ETZEL406.240.77951111 E BROADWAY STMISSOULA, MT 59802TETZEL@WGMGROUP.COMXX210909.1714 E MENDENHALL ESAXN/AMTMICHELLE POND805.215.4018SAME11RUSH ANALYSIS -QUICKEST TAT POSSIBLE PLEASE210909-SS-19/21/21210909-SS-29/21/21210909-SS-39/21/21210909-SS-49/21/213333SSSSXXXXEPH SCREEN (FRACTIONS & PAHS)CHLOR. HERBICIDES- SW 8151ARCRA METALS -SW 6010.2 & SW 7471XXXXXXXXXXXXMICHELLE POND 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment APPENDIX G ANALYTICAL LABORATORY REPORT ANALYTICAL SUMMARY REPORT This is a PRELIMINARY REPORT that contains incomplete data or data that has not been fully validated. Caution should be exercised in the use of any data presented as final reported results may not reflect the values presented. The analyses presented in this report were performed at Energy Laboratories, Inc., 3161 E. Lyndale, Helena, MT 59601 unless otherwise noted. Any exceptions or problems with the analyses are noted in the Laboratory Analytical Report, the QA/QC Summary Report, or the Case Narrative. Any issues encountered during sample receipt are documented in the Work Order Receipt Checklist. The results as reported relate only to the item(s) submitted for testing. This report shall be used or copied only in its entirety. Energy Laboratories, Inc. is not responsible for the consequences arising from the use of a partial report. If you have any questions regarding these test results, please contact your Project Manager . Lab ID Client Sample ID Collect Date Receive Date Matrix Test Report Approved By: H21090630-001 210909-SS-1 09/21/21 9:47 09/22/21 Soil Metals by ICP/ICPMS, TotalMercury in Solid By CVAAEPH-Ultrasonic Extraction SW3550CHydrocarbons, Extractable Petroleum-Scrn8151-Herbicides, ChlorinatedMoisturePercent MoistureTotal Metals Digestion by SW3050BMercury Digestion by SW7471BSonication Extraction SW3550CSoil Preparation USDA1 H21090630-002 210909-SS-2 09/21/21 11:02 09/22/21 Soil Metals by ICP/ICPMS, TotalMercury in Solid By CVAAEPH-Ultrasonic Extraction SW3550CHydrocarbons, Extractable Petroleum-Scrn8151-Herbicides, ChlorinatedMoisturePercent MoistureTotal Metals Digestion by SW3050BMercury Digestion by SW7471BSonication Extraction SW3550C H21090630-003 210909-SS-3 09/21/21 11:32 09/22/21 Soil Same As Above H21090630-004 210909-SS-4 09/21/21 11:49 09/22/21 Soil Same As Above WGM Group Inc Project Name:210909 Work Order:H21090630 1111 E Broadway Missoula, MT 59802-4909 September 24, 2021 H2316Quote ID: Energy Laboratories Inc Helena MT received the following 4 samples for WGM Group Inc on 9/22/2021 for analysis. Page 1 of 7 LABORATORY ANALYTICAL REPORT Client:WGM Group Inc Project:210909 Lab ID:H21090630-001 Client Sample ID:210909-SS-1 Collection Date:09/21/21 09:47 Matrix:Soil Report Date:09/24/21 DateReceived:09/22/21 Prepared by Helena, MT Branch Analyses Result Units Analysis Date / ByRLMethodMCL/QCLQualifiers PHYSICAL CHARACTERISTICS 09/23/21 16:45 / kmm0.2wt%22.0Moisture SW3550C 3050 EXTRACTABLE METALS 09/24/21 12:11 / dck1mg/kg-dry3Arsenic SW6020 09/24/21 12:11 / dck1mg/kg-dry201Barium SW6020 09/24/21 12:11 / dck1mg/kg-dryNDCadmium SW6020 09/24/21 12:11 / dck2mg/kg-dry28Chromium SW6020 09/24/21 12:11 / dck1mg/kg-dry18Lead SW6020 09/24/21 12:11 / dck1mg/kg-dryNDSelenium SW6020 09/24/21 12:11 / dck1mg/kg-dryNDSilver SW6020 METALS, TOTAL 09/23/21 16:46 / cfg0.50mg/kg-dryNDMercury SW7471B EXTRACTABLE PETROLEUM HYDROCARBONS-SCREEN ANALYSIS J 09/23/21 18:07 / jdh53mg/kg-dry52Total Extractable Hydrocarbons SW8015M200 09/23/21 18:07 / jdh40-140%REC107 Surr: o-Terphenyl SW8015M - Note: Total Extractable Hydrocarbons are defined as the total hydrocarbon responses regardless of elution time. Report Definitions: PRELIMINARYRL - Analyte Reporting Limit MCL - Maximum Contaminant Level QCL - Quality Control Limit ND - Not detected at the Reporting Limit (RL) J - Estimated value - analyte was present but less than the Reporting Limit (RL) Page 2 of 7 LABORATORY ANALYTICAL REPORT Client:WGM Group Inc Project:210909 Lab ID:H21090630-002 Client Sample ID:210909-SS-2 Collection Date:09/21/21 11:02 Matrix:Soil Report Date:09/24/21 DateReceived:09/22/21 Prepared by Helena, MT Branch Analyses Result Units Analysis Date / ByRLMethodMCL/QCLQualifiers PHYSICAL CHARACTERISTICS 09/23/21 16:45 / kmm0.2wt%16.1Moisture SW3550C 3050 EXTRACTABLE METALS 09/24/21 12:13 / dck1mg/kg-dry2Arsenic SW6020 09/24/21 12:13 / dck1mg/kg-dry170Barium SW6020 09/24/21 12:13 / dck1mg/kg-dryNDCadmium SW6020 09/24/21 12:13 / dck1mg/kg-dry18Chromium SW6020 09/24/21 12:13 / dck1mg/kg-dry44Lead SW6020 09/24/21 12:13 / dck1mg/kg-dryNDSelenium SW6020 09/24/21 12:13 / dck1mg/kg-dryNDSilver SW6020 METALS, TOTAL 09/23/21 16:48 / cfg0.50mg/kg-dryNDMercury SW7471B EXTRACTABLE PETROLEUM HYDROCARBONS-SCREEN ANALYSIS 09/24/21 08:05 / jdh12mg/kg-dry55Total Extractable Hydrocarbons SW8015M200 09/24/21 08:05 / jdh40-140%REC107 Surr: o-Terphenyl SW8015M - Note: Total Extractable Hydrocarbons are defined as the total hydrocarbon responses regardless of elution time. Report Definitions: PRELIMINARYRL - Analyte Reporting Limit MCL - Maximum Contaminant Level QCL - Quality Control Limit ND - Not detected at the Reporting Limit (RL) Page 3 of 7 LABORATORY ANALYTICAL REPORT Client:WGM Group Inc Project:210909 Lab ID:H21090630-003 Client Sample ID:210909-SS-3 Collection Date:09/21/21 11:32 Matrix:Soil Report Date:09/24/21 DateReceived:09/22/21 Prepared by Helena, MT Branch Analyses Result Units Analysis Date / ByRLMethodMCL/QCLQualifiers PHYSICAL CHARACTERISTICS 09/23/21 16:46 / kmm0.2wt%29.5Moisture SW3550C 3050 EXTRACTABLE METALS 09/24/21 12:15 / dck1mg/kg-dry5Arsenic SW6020 09/24/21 12:15 / dck1mg/kg-dry429Barium SW6020 09/24/21 12:15 / dck1mg/kg-dry1Cadmium SW6020 09/24/21 12:15 / dck2mg/kg-dry32Chromium SW6020 09/24/21 12:15 / dck1mg/kg-dry96Lead SW6020 09/24/21 12:15 / dck1mg/kg-dryNDSelenium SW6020 09/24/21 12:15 / dck1mg/kg-dryNDSilver SW6020 METALS, TOTAL 09/23/21 18:22 / cfg0.50mg/kg-dry2.1Mercury SW7471B EXTRACTABLE PETROLEUM HYDROCARBONS-SCREEN ANALYSIS 09/24/21 08:55 / jdh14mg/kg-dry137Total Extractable Hydrocarbons SW8015M200 09/24/21 08:55 / jdh40-140%REC103 Surr: o-Terphenyl SW8015M - Note: Total Extractable Hydrocarbons are defined as the total hydrocarbon responses regardless of elution time. Report Definitions: PRELIMINARYRL - Analyte Reporting Limit MCL - Maximum Contaminant Level QCL - Quality Control Limit ND - Not detected at the Reporting Limit (RL) Page 4 of 7 LABORATORY ANALYTICAL REPORT Client:WGM Group Inc Project:210909 Lab ID:H21090630-004 Client Sample ID:210909-SS-4 Collection Date:09/21/21 11:49 Matrix:Soil Report Date:09/24/21 DateReceived:09/22/21 Prepared by Helena, MT Branch Analyses Result Units Analysis Date / ByRLMethodMCL/QCLQualifiers PHYSICAL CHARACTERISTICS 09/23/21 16:46 / kmm0.2wt%18.8Moisture SW3550C 3050 EXTRACTABLE METALS 09/24/21 12:17 / dck1mg/kg-dry5Arsenic SW6020 09/24/21 12:17 / dck1mg/kg-dry366Barium SW6020 09/24/21 12:17 / dck1mg/kg-dryNDCadmium SW6020 09/24/21 12:17 / dck2mg/kg-dry26Chromium SW6020 09/24/21 12:17 / dck1mg/kg-dry72Lead SW6020 09/24/21 12:17 / dck1mg/kg-dryNDSelenium SW6020 09/24/21 12:17 / dck1mg/kg-dryNDSilver SW6020 METALS, TOTAL 09/23/21 19:28 / cfg0.50mg/kg-dry1.2Mercury SW7471B EXTRACTABLE PETROLEUM HYDROCARBONS-SCREEN ANALYSIS 09/24/21 09:43 / jdh12mg/kg-dry163Total Extractable Hydrocarbons SW8015M200 09/24/21 09:43 / jdh40-140%REC108 Surr: o-Terphenyl SW8015M - Note: Total Extractable Hydrocarbons are defined as the total hydrocarbon responses regardless of elution time. Report Definitions: PRELIMINARYRL - Analyte Reporting Limit MCL - Maximum Contaminant Level QCL - Quality Control Limit ND - Not detected at the Reporting Limit (RL) Page 5 of 7 Shipping container/cooler in good condition? Custody seals intact on all shipping container(s)/cooler(s)? Custody seals intact on all sample bottles? Chain of custody present? Chain of custody signed when relinquished and received? Chain of custody agrees with sample labels? Samples in proper container/bottle? Sample containers intact? Sufficient sample volume for indicated test? All samples received within holding time?(Exclude analyses that are considered field parameterssuch as pH, DO, Res Cl, Sulfite, Ferrous Iron, etc.) Container/Temp Blank temperature: Containers requiring zero headspace have no headspace or bubble that is <6mm (1/4"). Water - pH acceptable upon receipt? Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No No No No No No No No No No No No £R £ £ £ £ £ £ £ £ £ £ R R R R R R R R R R R £ Not Present Not Present Not Present £ £ £ No VOA vials submitted Not Applicable £ £ °C Date Received: Received by: Login completed by: Carrier name: Reviewed by: Reviewed Date: Contact and Corrective Action Comments: Temp Blank received in all shipping container(s)/cooler(s)?Yes NoR £Not Applicable £ Lab measurement of analytes considered field parameters that require analysis within 15 minutes of sampling such as pH, Dissolved Oxygen and Residual Chlorine, are qualified as being analyzed outside of recommended holding time. Solid/soil samples are reported on a wet weight basis (as received) unless specifically indicated. If moisture corrected, data units are typically noted as –dry. For agricultural and mining soil parameters/characteristics, all samples are dried and ground prior to sample analysis. Radiochemical precision results represent a 2-sigma Total Measurement Uncertainty. Standard Reporting Procedures: Work Order Receipt Checklist Page 6 of 7 Page 7 of 7 714 E MENDENHALL ST PROPERTY - BOZEMAN Expanded Phase I Environmental Site Assessment APPENDIX H TABLES TABLE 1 EPH in Surface Soil 714 E Mendenhall St ESA Bozeman, Montana EPH Screen (TEH)C9-C18 Aliphatics C19-C36 Aliphatics C11-C22 Aromatics TPH 200*270,000 immobile 2,000 np200*110 24,000 490 np SS-1 9/21/2021 0 - 6 52 J ---------------- SS-2 9/21/2021 0 - 6 55 ---------------- SS-3 9/21/2021 0 - 6 137 ---------------- SS-4 9/21/2021 0 - 6 163 ---------------- Notes: All results in milligrams per kilogram (mg/kg)J qualifier indicates the result is estimated because the analyte was present but less than the laborartory reporting limit*This concentration is used to determine if additional analysis (EPH fractionation) of the soil sample is needed---- indicates the parameter was not analyzed becase the EPH Screen level did not exceed 200 ppm Bolded value indicates the value was detected above the laboratory reporting limit MDEQ Tier 1 RBSL Leaching (< 20 ft to GW) MDEQ Tier 1 RBSL Direct Contact Residential Sample ID Date Collected Sample Depth (inches bgs) Extractable Petroleum Hydrocarbons (EPH)