RELEVANT ASPECTS

Key PM Environmental Personnel

Douglas E. McVey, C.P.G.

Michael T. Kulka, P.E., C.P.

Peter S. Bosanic, P.E., C.P.

CATEGORY S BASELINE ENVIRONMENTAL ASSESSMENT AND COMPLIANCE ANALYSIS OF THE RETAIL DRY CLEANING FACILITY LOCATED IN CLINTON TOWNSHIP, MACOMB COUNTY, MICHIGAN:

Client: Confidential

Site Location: Westland , Michigan

Start Date: 2004

Completion Date: Seven Months

Total Project Budget:$25,000

A total of 19 soil borings were completed and 6 existing monitoring wells were sampled on the subject property by PME in October and November 2004, with selected soil and groundwater samples submitted for laboratory analysis of VOCs, SVOCs, PCBs, ammonia, glycols, nitrate/nitrite, alcohol, and selected metals.

The intended use of the subject site was for printing operations. The chemicals of ammonia, xylenes, and 1,2,4 TMB that were identified on the property at levels exceeding the MDEQ Part 201 GSI cleanup criteria are used in the printing operations. A Category S BEA was appropriate was completed that used a combination of 1) the characterization of the three primary greenbelt areas used as soil isolation zones and 2) engineering controls in the asphalt/concrete paved areas and inside the industrial building as a basis to distinguish potential new hazardous substance releases from existing contamination. Any new release of hazardous substances, used by Childers in the greenbelt isolation zones would be identified in the unsaturated soils and be the liability of Childers and then the BEA would not provide an exemption to strict liability with respect to the required response activities. Childers acknowledged that if there was a failure of an engineering control or similar feature identified in the BEA, and if a release occured as a result of the failure, the BEA woul not provide an exemption to liability for response activity necessary to address contamination resulting from the failure. The burden of distinguishing the release attributable to the failure of the engineering control from existing contamination would be borne by the Childers according to Section 29 of Part 201.

Engineering controls were used in the building and in the remaining outside asphalt/concrete paved portions of the property as a basis to distinguish potential new hazardous substance releases from existing contamination. Office, mail staging, and mail processing activities are conducted in the western portion of the building and do not involve the use of hazardous substances in significant quantities that exceed those commonly used for typical residential or office purposes.

Printing operations and storage of significant hazardous substances will be conducted in the eastern portion of the site building, including truck product delivery and waste removal activities which are provided inside access through over head doors on the east side of the building. The concrete floor in this eastern portion of the building (approximately 19,500 square feet) where any significant hazardous substance usage occurs was sealed with General Polymers 3741 NOVO-FLO solvent/acid resistant coating (Appendix I), which is resistant to the proposed use hazardous substances. The chemical resistant NOVO-FLO coating prevents any further contamination from entering the subsurface soil or groundwater. The floor drains and the floor trenches in this eastern control area were filled in and sealed or the trenches inspected for drains were plugged and then the drain/trenches sealed to prevent the potential for contamination from entering the subsurface soil or groundwater. The concrete floor in the other areas of the building and the outside asphalt/concrete paved areas of the property will comprise the remaining engineering control area portions of the site.

The Category S BEA and Due Care plan were affirmed by the MDEQ .