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HomeMy WebLinkAbout680 ALD058221326 097 12-18-2023 CORR KLT FMR MOBILE RIVER TERMINAL PHASE 2 ESA WORK PLAN P�P-MA S v �� Mi .A Hi nd yam° December 18,2023 Ms.Ashley Mastin, Chief Governmental Hazardous Waste Branch Land Division Alabama Department of Environmental Management 1400 Coliseum Blvd. Montgomery,AL 36110-2400 RE: Phase II Environmental Site Assessment Work Plan Former Mobile River Terminal AHWMMA Permit Number: ALD 058221326 Mobile,Alabama Dear Ms. Mastin, The Alabama State Port Authority (ASPA) received ADEM Review and Comments dated October 3, 2023 for the Former Mobile River Terminal Phase II Environmental Site Assessment Work Plan submitted June 23,2023. In the interest of time, ASPA has been corresponding with Ms. Kaneshia Townsend,ADEM,to ensure that the comments are satisfactorily addressed with this submittal. ASPA hereby submits revised pages for the Phase II Environmental Site Assessment Work Plan and responses to ADEM comments. I certify under penalty of law that this document and all attachments were prepared under my direction or supervision according to a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system,or those persons directly responsible for gathering the information,the information submitted is, to the best of my knowledge and belief,true,accurate,and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. Should you have any questions, please do not hesitate to contact Gretchen Barrera at 251-441-7086 or via email at Gretchen.Barrera@ALports.com. Sincerely, /g- Douglas C.Otto,Jr., P.E. �l Vice President, Engineering cc: Gretchen Barrera,ASPA Robert Bailey, La Bella Associates P.O.Box 1588•Mobile,AL 36633 Office:251.441.7200•Fax:251.441.7216 ALports.com Alabama State Port Authority Responses to: ADEM RevfewandComments on the Former Mobile River Terminal Phase IIEnWonmentalSIteAssessment Work Plan Alabama State Port Authority Mobile,Alabama Alabama Department of Environmental Protection (ADEM) comments are numbered (and italicized) according to their October 4, 2023 comment letter and subsequent November 21 through December 14, 2023 emails. Alabama State Port Authority/La Bella Associates, D.P.C. responses are bulleted under each ADEM comment. 1. PaWe5.Section3.0. This section states that analytical results for diesel range organics were above detection limits at Sites 2, 3, and 5. Based on the information provided in Appendix C, there may have been fuel spills that occurred at or near the subject site. Please discuss if any constituents were detected at levels that are harmful to human health or the environment or if the concentrations are above any applicable Environmental Protection Agency (EPA) Regional Screening Levels(RSLs) • Diesel range organics(DRO)were detected; however,they were not detected at a concentration above 100 ppm. Asummary of the analytical data obtained during the Phase I/II is provided as bullet points on Page 5,Section 3.0. The only constituents that were detected at concentrations above ADEM PSVs were the PAH benzo[a]pyrene(in a soil sample collected at Site 5),selenium (in a groundwater sample at Site 5), and arsenic (in a soil sample at Sites 1 and 5, and in the marine sediment samples at Sites 6, 7,and B). Comment below (in Italics) from ADEM's December 1, 2023 email pertaining to ASPA's response to Comment#1 above. 1a.Please note that the MRT is evaluated under the Governmental Hazardous waste (RCRA) program (instead of the UST program). Therefore, ASPA may consider removing that sentence. ASPA may considering addressing whether the constituents listed on Table 1 address the DRO concerns. • Acknowledged. Since TPH diesel range organics were detected above the detection limits in soil at Sites 2, 3, and 5, volatile organic compounds (VOCs) have been added to the soil and groundwater samples to be collected from Sites 2,3, and 5. The VOCs, in conjunction with the listed PAHs to be analyzed, will provide an ample evaluation of the potential petroleum organics/concentrations in Site media. Table 1 and all associated text in the workplan have been updated to reflect this change. 2. Pame 3 Sectfon 30. This section states that elevated concentrations were noted in sediment samples during a 2007 sampling event. ASPA states that this area was dredged between 2007 and early 2009. Please provide documentation of this dredging event. Also,ADEM notes that three sediment samples were collected in 2014. The analytical results indicated arsenic exceedances in these samples. Please explain why these sediment locations are not included in the site investigation. If the 2014 sediment sample exceedances have been addressed by dredginglexcavation, please provide documentation. Please clarify if any of these areas were excavated at depths that adequately address sediment screening level exceedances. • Unfortunately, no documentation of the 2007-2009 dredging event was able to be located. However,according to the borings logs from the Phase 1/II performed by Volkert,Inc.(July 2014) (see Attachment A), the depth at which the sediment was collected in the vessel slip was approximately 40 feet below the surface of the water at two locations, and approximately 46 feet below the surface of the water at sampling location MS7. It should be noted that ASPA's future plans for the vessel slip is to backfill (cap)this area with soil to grade, and cover with a minimum of 1 foot of concrete slab, with eventually being included in an environmental covenant. ASPA has already applied for,and received,a permit from the Army Corp of Engineers for this work(File Number SAM-2017-00189-JEB,Modification Number 1). ASPA believes these future plans should address the exceedances in sediment in the vessel slip area.Therefore, no additional assessment of the vessel slip is warranted/included in this workplan. Similar text to ASPA's response to this ADEM comment has been added to the end of Section 3.0. Comment below (in italics) from ADEM's December 1, 2023 email pertaining to ASPA's response to Comment#2 above. 2a.ADEM recommends that ASPA conduct a waste determination for any dredged (or waste material) that may be accumulated when the site is prepared to be backfill or leveled in preparation for the future plans. Please revise the response accordingly. • Comment acknowledged. This comment will be addressed when applicable. 3. Pa¢e 7.Secdon 41. For consistency with Section 4.3, please revise Section 4.1 to state that a total of three samples will be collected from each boring instead of up to three samples. • Understood. It should be noted that it is our intent to collect three samples, but due to the possibility of a shallow water table, two samples may only be able to be collected. A field call will be made during onsite sampling activities. 4. Page a Section 4.2. Please revise this section and all other relevant text to state that mercury in groundwater will be analyzed using Method 7470A (most recent method) instead of Method 74708. • Understood. The report text has been updated where applicable. 5. Pa¢e&SeeUon 4.2. The rationale used to develop contaminants of concern (COGS)only includes contaminants that exhibited issues with obtaining appropriate method detection limits (MDLs). Please expand this discussion to include all criteria(e.g.,screening level exceedance and any other relevant items) used to develop COCs. • The following text has been included in the COC determination rationale: a constituent will be considered a COC"if the detected concentration of that constituent exceeds the EPA RSL in soil and/or groundwater.". Comment below (in Italics) from ADEM's December 1, 2023 email pertaining to ASPA's response to Comment#5 above. 5a.Please revise text to include the both the EPA RSL and MCL in regards to groundwater(RSL used in absence of MCL). Also, please revise to state EPA Residential RSL in soil. • Clarification text has been added to the workplan where applicable. 6. PaMe 10.Sectfon 4.32. ADEM notes that four soil samples in each cardinal direction(surrounding a central sample)will be collected during the original sample collection. Please provide more details regarding the direction(e.g., continuation of a central sample surrounded by four samples)of step- outs in the case of a RSL exceedance. • This sampling assumption provided in this comment is correct. The following text has been added to Section 4.3.2.,"Additional step-outs may be warranted pending the review of the initial soil sampling effort. In the event EPA RSL exceedances are detected in a step-out boring sample, additional step out borings will be advanced in the applicable Cardinal direction to definitively delineate (horizontally and vertically) the EPA RSL exceedance to unlimited use/unrestricted exposure.". 7. BW S. Sectlon 5.0. Please clarify the source of the site media sample criteria. Samples (semi- volatile organic compounds) should be kept at <6 •C(protected from light) in sealed vials (e.g., screw-cap vials or crimp-capped vials) equipped with unpierced PTFE-lined septa. Also, please ensure that the information provided in the table is consistent with SW-846. • The site media sample criteria were obtained from the nationally accredited laboratory chosen for this project, and they, as well as the field technician performing the sampling, will comply with sample integrity as detailed in this comment. Comment below (In Italics) from ADEM's December 1, 2023 email pertaining to ASPA's response to Comment#8 above. 7a.In accordance with the AEIRG, samples should be analyzed using S W-846. Please revise accordingly. • Clarification text has been added to the workplan where applicable. 8. 8W 13.Sectbon 5.0. Please define "2"in the notes section. • Based on all comments to date, the sample criteria and analytical method table has been revised. 9. Table L Table 1 does not include screening levels for cadmium and chromium. Please update Table 1 to include the appropriate Environmental Protection Agency(EPA)regional screening level (RSL) for each constituent. ASPA should use the value listed for cadmium (diet) for soil and cadmium(water)for groundwater. Please clarify which chromium species ASPA plans to include in the site media analyses. At a minimum, chromium VI should be included in the analyses. • Table 1 has been updated to include the EPA RSL value listed for cadmium (diet)for soil and cadmium (water) for groundwater. Hexavalent chromium has been included in the analytical suite for soil and groundwater; however, it should be noted that for soil sampling, hexavalent chromium will only be analyzed in samples where the detected total chromium concentration exceeds the hexavalent chromium EPA RSL for Residential soil. (The total chromium MDL is less than the hexavalent chromium EPA RSL for residential soil.) 10. Table 1. ADEM notes that the proposed site media analytical list includes constituents that have noted exceedances based on data from the 2014 sampling event. Please ensure that there were no MDL issues during this analytical event. If so, all relevant constituents should be included in laboratory analysis during the forthcoming site investigation. • It is our understanding from a conference call on June 2, 2023 between ADEM, ASPA, and LaBelle representatives that only PAHs and RCRA metals would be needed during this investigation because those were the ADEM PSV exceedances noted in the previously conducted Phase 1/II sampling event. Comment below (In Italics) from ADEM's November 21, 2023 email pertaining to ASPA's response to Comment#10 above. 10a. 1 noted that the Site 1(MRT)is a former switchyard. In your response to the attached document, please discuss why PCBs were not included in Table 1 (Constituent Analytical Summary). • Based on historical knowledge and past sampling, PCBs were not recommended as a constituent of potential concern. The 2014 ESA and Limited Phase II Report included soil and groundwater analytical results for PCBs. All PCB results were non-detect. Sample collection location 'Site 1'was located at the"switch yard"where pad-mounted transformers,owned by Alabama Power Company,were located. Accordingtothe2014 ESA,Alabama Power Company removed surrounding soil and replaced it with clean fill. Since PCB laboratory analytical results were non-detect at the laboratory detection limit in soil samples collected as part of the Phase 1/11 ESA (i.e., in which the laboratory detection limit was below the current U.S. EPA Residential Soil RSLs[November 2023]), no soil samples are proposed to be analyzed for PCBs. However, out of an abundance of caution,and since the laboratory detection limit in groundwater samples collected as part of the Phase I/II ESA (i.e., in which the laboratory detection limit was above the current U.S. EPA RSLs [November 2023]), groundwater samples are proposed to be analyzed for PCBs. The Workplan and Table 1 have been revised to include the collection of groundwater samples at Site 1 for PCB analysis. 11. Table 1. ADEM notes that the list for polynuclear aromatic hydrocarbons (PAHs) is abbreviated. Please revise this list for consistency with EPA's RSL Summary Table list of PAHs. Also,ASPA plans to analyze site media for the Resource Conservation and Recovery Act (RCRA) 8 metals. Please ensure that all metals associated with coal and any other historical site uses are included in the table. • There are 17 PAHs currently listed in Table 1,the same list of PAHs analyzed during the Phase I/II ESA conducted by Volkert, Inc. In the EPA RSL Summary Table there are 22 PAHs listed. We've contacted our nationally accredited laboratory about these remaining PAHs,and they have responded that they do not analyze for those. With that,ASPA/LaBella is not recommending any changes to the current Table 1 for PAHs. 12. AnnendbrB. The text states there is a storm water collection pond on site. Please explain why ASPA does not propose to collect samples at this location. • Four soil borings with one surface (0 - 1' bgs) and two subsurface samples (1' - 4' bgs; and above the soil/groundwater interface) in the former storm water collection pond have been added to this assessment. This pond has not been used for storm water collection for several years and the area is dry,thus no aqueous samples are proposed atthis time. These samples will be analyzed for PAHs and RCRA 8 metals. Figure 3 has been revised to include the storm water collection pond, and Figure 3F has been added to the revised work plan for illustration purposes of the former storm water collection pond soil boring sampling locations. 13. Appendix B. ADEM notes that the buildings on the subject property have been demolished. Asbestos-containing material was noted in Section 4.2 of the Phase I and Limited Phase II Environmental Site Assessment (ESA) dated July 2014. Please discuss the disposal of the asbestos-containing material and whether sampling is necessary to determine if asbestos may be present in surface soil. • Correct, building demolition occurred prior to the ASPA's purchase of the property.Section 4.2 of the Phase 1 and Limited Phase 11 Environmental Site Assessment (ESA) dated July 2014 is referencing findings from an earlier ESA performed in 2009.The 2009 ESA found that the pipe wrapping in the office building had been abated and the transite wallboard in the crane was left in place. Since the report indicates that the asbestos was found on the interior of the office building and the asbestos abatement would require proper disposal, there is no reason to believe that asbestos would occur in the soil.Additionally, due to the value of the equipment, it is an industry practice to relocate a crane rather than demolish it. 14. Appendix B. ADEM notes that fill material has been placed in some areas at the subject site.ASPA should avoid sampling the fill material. Please ensure that the vertical and horizontal dimensions of this material are taken into consideration if samples are collected in these areas. • Understood. Fill material is not anticipated to be sampled as part of this investigation. 15. Appendix C. The health and safety plan appears to be an internal document and not submitted for ADEM approval. Please remove the health and safety plan from the work plan. • This plan has been removed from the workplan and will only be distributed internally prior to field activities. VOLUNTARY CHANGES TO NOTE: • Soil sample identifications have been slightly modified to better simplify the nomenclature. For example, sample depth identifiers have been converted from a numerical range to a single alphabetical determination. For instance, varying sample depths from the same boring are proposed to be collected. Instead of identifying the depth ranges in the sample ID numberically, the sample intervals ground surface to 1' bgs(will be identified in the sample ID as"A"), 1' - 4' bgs (will be identified in the sample ID as "B"), and just above the soil/groundwater interface (will be identified in the sample ID as"C") have been modified in this revised version of the workplan. See Table 4.3 in the revised Workplan for details. LaBeRa Powered by partnership. PHASE II ENVIRONMENTAL SITE ASSESSMENT WORK PLAN FORMER MOBILE RIVER TERMINAL 82 VIRGINIA STREEr MOBILE,MOBILE COUNTY,ALABAMA 36603 LABELLA PROJECT No.:2232421 PREPARED FOR: ALABAMA STATE PORT AUTHORITY P.O. Box 1588 Mobile, Mobile County,Alabama 36633 JUNE 23,2023 REVISED DECEMBER 18 2023 PREPARED BY: LABELLA ASSOCIATES, D.P.C. 528 MINERALTRACE BIRMINGHAM,ALABAMA 35244 PHONE(205)985-4874 Robert R. Bailey, P.G. Phillip D. Davis, P.E. Senior Project Geologist Senior Engineer TABLE OF CONTENTS 1.0 INTRODUCTION .................................................................................................................. 1 2.0 GENERAL FACILITY DESCRIPTION........................................................................................2 2.1 SURROUNDING AREA........................................................................................................2 2.2 SITE DESCRIPTION...........................................................................................................2 2.3 FORMER SITE USES OPERATIONS......................................................................................2 3.0 PREVIOUS SITE INVESTIGATIONS.........................................................................................4 4.0 PHASE II ESA INVESTIGATION WORK PLAN...........................................................................7 4.1 FIELD INVESTIGATION STRATEGY..........................................................................................7 4.2 SAMPLING AND ANALYSIS RATIONALE...................................................................................8 4.3 SOIL SAMPLING STRATEGY................................................................................................ 10 4.3.1 Soil Characteristic Analysis................................................................................. 11 4.3.2 Soil Sample Delineation...................................................................................... 12 4.4 MONITORING WELL INSTALLATION ....................................................................................... 13 4.5 GROUNDWATER SAMPLING................................................................................................ 13 4.5.1 Groundwater Sample Analysis............................................................................. 14 5.0 SAMPLE HANDLING AND QUALITY ASSURANCE.................................................................... 15 6.0 MANAGEMENT OF INVESTIGATIVE DERIVED WASTE(IDW)...................................................... 18 7.0 DECONTAMINATION............................................................................................................ 19 7.1 SAMPLING EQUIPMENT DECONTAMINATION............................................................................ 19 7.2 PERSONNEL DECONTAMINATION ......................................................................................... 19 7.3 DECONTAMINATION PAD.................................................................................................... 19 8.0 IMPLEMENTATION SCHEDULE.............................................................................................21 9.0 DATA MANAGEMENTAND REPORTING.................................................................................22 9.1 DATA EVALUATION ...........................................................................................................22 10.0 REFERENCES.....................................................................................................................24 528 Mineral Trace I Hoover,AL 35244 1 P(205)985-4874 1 f(205)987-6080 www.tabellapc.com TABLES Table 1 Laboratory Detection Limits(Revised December 2023) FIGURES Figure 1 Site Location Topographic Map Figure 2 Site Layout Map Figure 3 Proposed Soil Boring Locations:Site Wide (Revised December 2023) Figure 3A Proposed Step-Out Boring Locations: Site#1 Figure 3B Proposed Step-Out Boring Locations: Site#2 Figure 3C Proposed Step-Out Boring Locations: Site#3 Figure 3D Proposed Step-Out Boring Locations: Site#4 Figure 3E Proposed Step-Out Boring Locations: Site#5 Figure 3F Former Stormwater Collection Pond Sampling Mao Figure 4 Monitoring Well Location Map Figure 5 Typical Type II Monitoring Well Cross Section APPENDICES On Compact Disk Appendix A RCRA Facility Assessment Report - ADEM February 2020 Appendix B Phase I and Limited Phase II ESA -Volkert, Inc.July 2014 _!lard �revi AppendiIle lam-Safety-Pla*n 52B Mineral Trace I Hoover,AL 35244 I P(205)985-4874 1 f(205)987-6080 www.tabettapc.com Phase II Environmental Site Assessment Work Plan Alabama State Port Authority Former Mobile River Terminal Site Project No.2232421 Mobile,Alabama Page 1 of 24 1.0 INTRODUCTION On behalf of Alabama State Port Authority (ASPA), La Bella Associates, D.P.C. (La Bella) has prepared this Phase II Environmental Site Assessment Work Plan (herein referred to as the "Work Plan") to conduct an investigation of the former Mobile River Terminal (MRT) located at 82 Virginia Street in Mobile, Mobile County, Alabama (the Site). The primary focus areas of this Work Plan were identified in the Resource Conservation and Recovery Act (RCRA) Facility Assessment (RFA) report (Alabama Department of Environmental Management [ADEM]/Environmental Protection Agency [EPA] February 2020) (Appendix A). The findings of the RFA indicated the presence of five "sites' (identified as Sites 1 through 5 in the Phase 1 and Limited Phase II Environmental Assessment Report [Phase 1/11 ESA; Volkert, Inc.July 2014] (Appendix B))as Area of Concern (AOC) 12 that require additional investigation. According to the RFA, no solid waste management units(SWMUs)were identified. ASPA currently owns the former MRT site, which encompasses approximately 36-acres. The Site is currently vacant and was purchased by ASPA whom purchased the Site from Blue Creek Coal Sales, Inc.in 2014 with the intention of restoring it to a satisfactory condition for sale as an industrial property. On October 10,2019, representatives of the ADEM's Industrial Hazardous Waste Branch conducted an RFA of the Site and a review of historical assessment documents. Based on observations made during the assessment,ADEM determined that additional sampling was warranted in order for the Department to determine the Site's regulatory status. A copy of the RFA report is included as Appendix A(provided on CD). LaBelle was retained by ASPA to generate a Work Plan to address the results of the RFA. In this Work Plan, LaBelle details the collection of soil and groundwater samples in the vicinity of the five "sites" identified in the RFA. The results of the fieldwork associated with this Work Plan will be provided in a subsequent Phase 11 ESA report submitted under separate cover. In an effort to delineate the extent of soil and groundwater contamination at the Site, LaBelle has prepared this Work Plan in accordance with the most recent edition of the Alabama Environmental Investigation and Remediation Guidance(AEIRG)Manual. 528 Mineral Trace I Hoover,AL 35244 1 p(205)985-4874 1 f f205)987-5080 www.labelLapc,com Phase II Environmental Site Assessment Work Plan Alabama State Port Authority Former Mobile River Terminal Site Project No.2232421 Mobile,Alabama Page 2 of 24 2.0 GENERAL FACILITY DESCRIPTION The Site consists of two parcels which are currently owned by ASPA, identified by parcel numbers 2910380007003.000 and 2910380006134.000 according to the Mobile County, Alabama Tax Assessor website. Information concerning the location is provided as follows: LATITUDE&LONGITUDE: 30.671657°;-88.0393333° (approximate center of Site) STREETADDRESS: 82 Virginia Street CITY,STATE,ZIP CODE Mobile, Alabama 36603 COUNTY: Mobile The Site is located west of the Mobile River and north of Virginia Street. The Site is displayed on the Mobile, Alabama United States Geological Survey(USGS)Topographic Map in Figure 1. 2.1 SURROUNDING AREA A Site walk was conducted on May 26,2023 by representatives of ASPA and La Bella. The Site is noted as being located in a heavily industrialized area of southeast Mobile, Alabama. Railroad tracks are adjacent to the western border of the property, followed by a mixture of commercial and industrial facilities, then Interstate 10. The Mobile Container Terminal (MCT), which is also owned by ASPA, is located south of the Site and is mostly covered by a concrete lot with steel shipping containers. BAE Systems owns the property north of the Site. A residential area is located approximately one-third of a mile west of the Site.A ship basin and the Mobile River is located along the eastern border of the Site. A Site Layout Map is provided as Figure 2. 2.2 STE DEscRIPnoN The Site is situated on approximately 36 acres, which consists of two parcels located at 82 Virginia Street in Mobile,Alabama (north of Virginia Street and west of the Mobile River).According to the RFA, the Site has been inactive since 2012,and all Site facilities and buildings have since been demolished and removed from the Site.The Site is partially occupied by several surcharges of stockpiled, certified clean,sand that is planned to be used for the expansion of the adjacent MCT site(located south of the Site). Railway tracks are adjacent to the western border of the property. Some underground and aboveground utility features such as power poles and disconnected lines, and a portion of the sewer and water lines remain on the property.A Site Layout Map is provided as Figure 2. 2.3 FORMER SITE USES/OPERATIONS The Site was initially developed and began operation in the early 1950's by Marine Bulk Handling,which reportedly stored, imported, and exported bulk materials. Mobile River Terminal, Inc. purchased the Site in the 1980's, and continued operations. Walter Energy, an affiliate of Blue Creek Sales, Inc, purchased the Site in 2010 in order to expand shipping capacity. Most of the Site's infrastructure was 528 Mineral Trace I Hoover,AL 35244 1 p(205)985-4874 1 f f205)987-5080 wwwAabelLapc,com Phase II Environmental Site Assessment Work Plan Alabama State Port Authority Former Mobile River Terminal Site Project No.2232421 Mobile,Alabama Pape 3 of 24 demolished between 2010 and 2012, with plans to convert the area into a coal hand I ingfaci I ity. The ASPA acquired the Site in 2014 where it was planned to be used as a lay down yard to accommodate the expansion of the MCT.The Site has remained inactive since 2012; however,the future plan for the Site remains to be a lay down yard to accommodate the expansion of the MCT. 528 Mineral Trace I Hoover,AL 35244 1 p(205)985-4874 1 f f205)987-5080 www.labelLapc,com Phase II Environmental Site Assessment Work Plan Alabama State Port Authority Former Mobile River Terminal Site Project No.2232421 Mobile,Alabama Page 4 of 24 3.0 PREVIOUS SITE INVESTIGATIONS The majority of the information provided in this section was obtained from the Phase VII ESA report performed by Volkert, Inc. The text below was taken (in most cases) verbatim from the Phase VII ESA report as La Bella has no previous association with the Site. A Phase I Environmental Site Assessment (Phase I ESA) dated October 20, 2009, was conducted by ENVIRON International Corporation of Arlington,Virginia.The Phase I ESA was completed on the Site to identify Recognized Environmental Conditions(RECs) in accordance with the current"ASTM Standard" at that time. The Phase I ESA did not include the sampling of environmental media. The Phase I ESA concluded with no RECs in connection with the property. The Phase I ESA did note three neighboring properties reported as having known or suspected soil and groundwater contamination; however, ENVIRON did not consider this a REC. Marine sediment data was collected by PPM Consultants, Inc. in July 2007, prior to dredging the ship basin in the vicinity of the Site. Analytical results from the sediment samples indicated some elevated constituent concentrations. ENVIRON did not consider this a REC since the area was dredged between 2007 and early 2009, and the sediment was placed in a permitted upland disposal area. A Phase 1/11 ESA was completed on the Site by Volkert, Inc. in June and July of 2014. During the performance of this Phase 1/11 ESA,soil and groundwater sampling was conducted. Core borings were conducted at five "sites" on July 1, 2014 which were identified as areas of possible concern based on historical Site operations.According to the Phase 1/11 ESA,the sampling"sites"are described as follows: Site Number 1 Site Number 1 is located between the previous bathhouse and garage building. According to Walter Energy personnel, the site is a former "switch yard" or substation. Walter Energy personnel indicated earth was removed from the site by Alabama Power Company and replaced with clean sandy material. Remnants of concrete pads were found at the site on June 26, 2014, as well as what appears to be fresh fill material adjacent to the west end of the pad area. Site Number 2 Site Number 2 is located near the previous garage area. Historical information indicates an aboveground gasoline storage tank was located at the site. No AST was at the site on June 26, 2014. 528 Mineral Trace I Hoover,AL 35244 1 P(205)985-4874 1 f f205)987-5080 www.labelLapc,com Phase II Environmental Site Assessment Work Plan Alabama State Port Authority Former Mobile River Terminal Site Project No.2232421 Mobile,Alabama Pape 5 of 24 Site Number 3 Site Number 3 is located near the previous oil storage area. Historical information indicates aboveground oil and diesel fuel storage tanks were located at the site. No AST was at the site on June 26, 2014. Site Number 4 Site number is located in the northern portion of the Site and was previously used for coal storage. Site Number 5 Site Number 5 is located in the southern area of the Site and was previously used for coal storage. As part of the Phase 1/11 ESA field activities, composite soil samples were collected and analyzed for volatile organic compounds (VOCs), semivolatile organic compounds (SVOCs), polycyclic aromatic hydrocarbons(PAHs),gasoline range organics(GRO),diesel range organics(DRO), RCRA 8 metals, and polychlorinated biphenyls (PCBs). Groundwater samples were analyzed for VOCS, SVOCs, RCRA 8 metals, PCBs, and formaldehyde. Additionally,three marine sediment core borings were advanced on July 9, 2014, within the ship basin. Sample sites were selected to provide representation of the ship basin area and complement data presented in the PPM Consultants' Mobile River Terminal Sediment Sampling Analysis report dated July 2007. Composite sediment samples were analyzed for VOCs, SVOCs, GRO, DRO, RCRA 8 metals,and PCBs. Analytical results from the Phase I/II ESA field activities revealed the following material findings in connection with the Site duringthe time of the investigation: • No metals concentrations found in the soil sample analysis were above the ADEM Preliminary Screening Values (PSVs)except at Site 1,Arsenic was 9.16 parts per million (ppm)and Site 5, Arsenic was 2.03 ppm. The ADEM PSV forArsenic is 1.6 ppm. • No concentrations of VOCs, SVOCs and PCBs found in the soil sample analysis were above the ADEM PSVs except at Site 5 Benzo fa]pyrene concentration was 0.286 ppm and the respective ADEM PSV is 0.21 ppm. • All Gasoline Range Organics concentrations found in the soil sample analysis were below detection limits for all sites. • Diesel Range Organics found in the soil sample analysis were above detection limits at Site 2, 8.05 ppm,Site 3, 9.73 ppm, and Site 5, 45.3 ppm. • Groundwater sample analysis indicated no constituent concentrations (metals, VOC, SVOC, PCB, and Formaldehyde) were above their respective ADEM PSVs except at Site 5, selenium was 0.09 ppm compared to the PSV of 0.05 ppm. • Analytical results for the marine sediment samples indicate metals at all sites were below the ADEM PSV except Arsenic at Site 6, 11.83 ppm,Site 7, 5.47 ppm,and Site 8, 12.66 ppm. The ADEM PSV for Arsenic is 1.6 ppm. All sites were below detection limits for all VOCs, SVOCs, 528 Mineral Trace I Hoover,AL 35244 1 p(205)985-4874 1 f f205)987-5080 www.labelLapc,com Phase II Environmental Site Assessment Work Plan Alabama State Port Authority Former Mobile River Terminal Site Project No.2232421 Mobile,Alabama Page 6 of 24 PCBs, Gasoline Range Organics, and Diesel Range Organics. • No significant environmental issues such as contamination from current or past land use were identified. Based on information reviewed and data collected it does not appear that further environmental investigation is warranted for this property at this time. A RFA was completed at the Site by ADEM on October 10, 2019.The RFA was conducted to determine whether further investigation was warranted and to determine the regulatory status of the Site.The RFA included a site inspection as well as a review of all historical documents pertaining to previous investigations at the Site. The ADEM RFA identified AOC 12, which includes the five sites/focus areas (described above in this section)to be further investigated. Based on the review of the 2020 RFA report, indicating that additional assessment of the Site is warranted, LaBelle has prepared this Work Plan to further assess soil and groundwater, which is presented in the following section. It should be noted that ASPA's future plans for the vessel slip(i.e.,the location of the July 2014'Phase I/II ESA sediment sampling performed by Volkert. Inc.l)is to backfill(cap)this area with fill soil to grade, and cover with a minimum of 1 foot of concrete slab,with eventually being included in an environmental covenant ASPA has already applied for and received a permit from the Army Corp of Engineers for this work (File Number SAM-2017-00189-JEB. Modification Number 1). ASPA believes these future Nansshould addressthe exceedances in sediment in the vessel slip area eliminatingthe riskto human health or the environment. Therefore no additional assessment of the vessel slip is warranted/included in this workplan. 528 Mineral Trace I Hoover,AL 35244 1 p(205)985-4874 1 f f205)987-5080 www.labelLapc,com Phase II Environmental Site Assessment Work Plan Alabama State Port Authority Former Mobile River Terminal Site Project No.2232421 Mobile,Alabama Page 7 of 24 4.0 PHASE II ESA INVESTIGATION WORK PLAN The following activities are proposed in order to investigate possible impacts to soil and groundwater resulting from historical operations on-Site based on the findings of the 2020 RFA completed by ADEM. Sample collection activities conducted as part of this assessment will be in general accordance with the most recent edition of the AEI RG. For the purposes of this investigation, the RFA identified five site/focus areas requiring additional investigation. The locations of the focus areas and previously installed soil boring areas (advanced during the Phase Vil ESA)are shown in Figure 3. 4.1 FIELD INVESTIGATION STRATEGY In an effort to further assess possible impacts to soil and groundwater from previous on-Site activities, the following field activities are proposed: Soil • Advance five (5)soil borings utilizing OPT methodology at the locations shown on Figure 3(the proposed soil boring locations are collocated with the five ACC 12 sites identified in the RFA and the Phase 1/11 ESA). • One step-out boring will be advanced on the four points of the compass surrounding the central boring(see above bullet),approximately 20 feet from the central boring. • Collection of up-te-three soil samples from each boring (one surficial sample [0 - 1' below ground surface (bgs), one subsurface sample [1' - 4' bgs], and one sample just above the soil/groundwater interface). •_Based on the review of the RFA and the Phase VII ESA,soil samples will be analyzed for PAHs and RCRA 8 metals in samples collected from Sites 1 through 5. Additionally, based on TPH DRO results indicated in the Phase 1/11 ESA. VOCs will be analyzed in samples collected from Sites 2. 3. and 5. See Table 1 for a complete list of constituents to be analyzed. o Since PCB laboratory analytical results were non-detect at the laboratory detection limit in soil samples collected as part of the Phase 1/II ESA(i.e., in which the laboratory detection limit was below the current U.S. EPA Residential Soil RSLs (November 202311 no soil samples are proposed to be analvzed for PCBs. • Additional step-out soil borings/samples(for delineation purposes)may be warranted based on a review of the original and initial step-out soil sampling analytical results (i.e., EPA Residential Soil Regional Screening Levels [RSLs]). See Section 4.3.2 for more details. • Four soil borings in the base of the storm water collection pond have been added to this assessment per ADEM request. This pond has not been used for storm water collection for several Years and the area is dry,thus no aqueous samples are proposed. Collection of three soil samples from each boring (one surficial sample 0 - 1' below ground surface flu as), one subsurface Sample[1' -4' has] and one sample lust above the soil/groundwater interface)will be performed. These samples will be analyzed for PAHs and RCRA 8 metals. 528 Mineral Trace I Hoover,AL 35244 1 p(205)985-4874 1 f f205)987-6080 www.labeltapc,com Phase II Environmental Site Assessment Work Plan Alabama State Port Authority Former Mobile River Terminal Site Project No.2232421 Mobile,Alabama Page 8 of 24 Groundwater • Installation of five (5) Type II groundwater monitoring wells (the proposed wells are to be collocated with the five AOC 12 sites identified in the 2020 RFA). • One groundwater sample will be collected from each monitoring well. • Based on the review of the 2020 RFA and the Phase I/II ESA, groundwater samples will be analyzed for PAHs and RCRA 8 metals at Sites 1 - 5. VOCs at Sites 2. 3. and 5. and PCBs at Site 1. See Table 1 for a complete list of constituents to be analyzed. o Since PCB laboratory analytical results were non-detect at the laboratory detection limit in groundwater Samples collected as Dart of the Phase 1/11 ESA (i.e., in which the laboratory detection limit was above the current U.S. EPA RSLS [November 20231) and since Site 1 was historically identified as being a former "switchyard" out of an abundance of caution, a groundwater sample is proposed to be analyzed for PCBs in the well to be installed at Site 1. • Additional monitoring wells(for delineation purposes) may be considered based on a review of the groundwater analytical results (i.e., EPA Reg ORa' S-•OO-iRg ' -••-'-MCLs [Tapwater IRSL used in absence of an MCLI for groundwater). 4.2 SAMPLING AND ANALYSIS RKnoNALE For the purposes of this investigation,soil and groundwater samples will be collected from each of the five focus areas (Site 1 through Site 5)as identified in the 2020 RFA/Phase I/II ESA and analyzed for RAMS and onon o metalthe below list of analyses/analyte groups per Site. Table 1 in the Tables Section provides a complete list of analyses for this assessment. Pace Analytical Center for Testing and Innovation (Pace)will be contracted to perform analyses on the Samples collected as part of this Work Plan. The following EPA methods are the most current (and nationally recognized) methods available and will be used for analysis of soil and groundwater samples collected as part of this Phase II assessment: Sites 1 - 5(Soil and Groundwater Samples): • PAHs: EPA Method 8270E-Selective Ion Monitoring(SIM) • RCRA 8 Metals: EPA Method 6020E o Mercury: EPA Methods7471B/-T 747OA(Soil/Groundwater) o Hexavalent Chromium: EPA Method 3060A(soil only)/7199 (details provided in this section) Because Sites 2.3, and 5 were identified as having elevated detections of TPH DRO.VOCs were added to the analytical suite for these samples. Sites 2.3.and 5 (Soil and Groundwater Samples): • VOCs: EPA Method 8260D and 8011 (1.2-dibromoethane and 1.2-0ibromo-3chloroproloane) 528 Mineral Trace I Hoover,AL 35244 1 P(205)985-4874 1 f f205)987-5080 www.labell.apc,com Phase II Environmental Site Assessment Work Plan Alabama State Port Authority Former Mobile River Terminal Site Project No.2232421 Mobile,Alabama Page 9 of 24 Because Site 1 was identified in the Phase 1/II ESA as being a former "switch yard". PCBs have been included as a potential CDC for this area. It should be noted that soil samples collected in this area returned soil sample analytical results of PCBs below the ADEM PSVs,which are below the current EPA RSLs for Residential Soil:therefore,only a groundwater sample will be collected and analyzed for PCBs. Site 1(Groundwater Samole Only): • PCBs: EPA Method 8082A Four representative soil borings with one surface(0 - 1' bgs)and two subsurface samples(1' - 4' bgs' and above the soil/groundwater interface) in the former storm water collection pond have been added to this assessment. This pond has not been used for storm water collection for several years and the area is dry,thus no aqueous samoles are proposed at this time The soil samples will be collected by DF- and advanced within the footprint of the former storm water collection pond. See Figure 3F for the proposed soil boring sampling locations Former Storm Water Collection Pond (Soil Samples Only • PAHs: EPA Method 8270E- SIM • RCRA 8 Metals: EPA Method 6020B o Mercury: EPA Methods7471B/747OA(Soil/Groundwater) o Hexavalent Chromium: EPA Method 306OA/7199 (details provided in this section While using the EPA analytical methods listed above for this project, the rationale for developing constituents of concern(CDC)will include: if the detected concentration of that constituent exceeds the EPA Residential RSL in soil and/or EPA MCL in groundwater(Taowater RSL used in absence of an MCL); if a constituent is non-detect at the laboratory minimum detection limit(MDL), and the MDL is greater than the EPA Residential RSLforsoil and/or EPA Maximum Contaminant Level(MCL) (or Tapwater RSL if no MCL is available)for groundwater,and there is no historical on-Site operations indicating that that constituent was ever used,then ASPA, after careful consideration, may recommend to the Department that the constituent be removed from the constituent of concern (CDC) list. Please note that the analysis for total chromium measures for both tri-valent and hexavalent,and there is no EPA RSL for total chromium in soil. As such,hexavalent chromium will only be analyzed in samples where the detected total chromium concentration exceeds the hexavalent chromium EPA RSL for Residential soil. (The total chromium MDL is less than the hexavalent chromium EPA RSL for residential soil.) Per Pace, hexavalent chromium in soil will be extracted by EPA Method 3060A.then analyzed in accordance with EPA Method 7199. 528 Mineral Trace I Hoover,AL 35244 1 p(205)985-4874 1 f f205)987-5080 www.labelLapc,com Phase II Environmental Site Assessment Work Plan Alabama State Port Authority Former Mobile River Terminal Site Project kill Mobile,Alabama Page 10 of 24 Table 1 in the Tables Section lists the constituents to be reported in each of the target analyte groups (i.e., PAHs_arA-RCRA 8 metals VOCs, and/or PCBs), along with their respective EPA RSLs and their respective MDLs/reporting detection limits (RDLs) (MDLs/RDLs provided by Pace) that will be used during the laboratory analytical result screening process. 4.3 SOIL SAMPLING STRATEGY The soil sampling effort will be conducted in order to define the horizontal and vertical extent of a potential source area of contamination in soils within each focus area (Site 1 through Site 5 and the former Storm Water Collection Pond) at the Site. For Sites 1 through 5.(initially, one central boring will be collocated with the original boring location from the previous Phase /Phase II ESA. One step- out boring will then be advanced on each of the four points of the compass surrounding the central boring at approximately 20 feet from the central boring. This will result in a total of 5 borings advanced at each focus area. For the former storm water collection pond, a total of four soil borings will be advanced, one in each cuadrant of footprint of the former pond. The proposed boring configurations are illustrated on Figures 3A(Site 1),313(Site 2),3C(Site 3),3D(Site 4),and-3E(Site 5) and 3F(former Storm Water Collection Pond). A total of three soil samples will be collected from each boring,with each sample being labeled specific to the axis of the compass, boring number, and depth interval. The soil samples will be collected in each boringfrom the following depth intervals:ground surface to 1' bgs(will be identified in the sample ID as "A"), 1' - 4' bgs (will be identified in the sample ID as "B"), and just above the soil/groundwater interface (will be identified in the Sample ID as "C"). The samples collected from the borings will be labelled as illustrated in the following Table 4.3. TABLE 4.3—SAMPLE LABELING SPECIFICATIONS Focus AREA COMPABSAXLS BORING NUMBER DEPTH INTERVAL(BGS) Site 1 (S1) North (N) Soil Boring-1(SB1) 1.0-- 4.0 (4-4B) Former Storm Water Collection Pond Not applicable Soil Boring-1(SBD 1.0 - 4.0(B) (SWPI Notes' BGS-below ground surface In the first example provided above, the sample labeled as SINSBIB-1-4 would be collected from the first step-out boring from the center of Site 1, on the North compass axis, and collected at the depth interval 1' - 4' bgs. All depths will be captured on each boring log for each sampling location. 528 Mineral Trace I Hoover,AL 35244 1 p(205)985-4874 1 f f205)987-5080 www.labell.apc,com Phase II Environmental Site Assessment Work Plan Alabama State Port Authority Former Mobile River Terminal Site Project No.2232421 Mobile,Alabama Page 11 of 24 This sampI!ngstrategy will result in the collection of 15 soil samples from each focus area. The a:,e sSample analysis will be SA -'-performed in accordance with the Sampling and Analysis Rationale provide in Section 4.2. In the second example provided in Table 4.3.the sample labeled as SWPSBIB would be collected from one of the borings(to be documented in the field)from one of the four quadrants of the former storm water collection pond and collected at the depth interval 1' - 4' bgs. All depths will be captured on each boring logfor each sampling location. This sampling strategy will result in the collection of 12 soil samples from this focus area. Sample analysis will be performed in accordance with the Samoling and Analysis Rationale provide in Section 4.2. Direct Push Technology(DPT) drilling(or similar method capable of completing the subsurface tasks outlined in this Work Plan)will be employed to collect surface and subsurface soil samples. DPT drilling typically uses 4' or 5' acetate sleeves within probe rods(primary core barrel)to obtain subsurface soil samples. The soil samples will be collected continuously in acetate sleeves for the purpose of logging subsurface materials. Five borings (collocated with the central borings at Sites 1 - 5) are planned to be used for the installation of groundwater monitoring wells, for the purposes of the collection of groundwater samples. Soils will be continuously logged in the field by a qualified geologist or scientist experienced in subsurface investigations in accordance with the Unified Soil Classification System (USCS). Prior to conducting any subsurface investigation,the Alabama 811 underground utility location system will be contacted to clear utilities along easements and rights of way. In addition,a ground penetrating radar(GPR) may be employed to clear each of the proposed boring locations prior to drilling. Proposed boring locations will be adjusted in the field as necessary based on the findings of the 811 survey and/or GPR survey(if conducted). 4.3.1 Soil Characterisbc Analysis One undisturbed soil sample will be collected using a Shelby Tube from soil borings immediately adjacent to two monitoring wells to be installed. The samples will be held pending a review of the groundwater analytical results and will only be analyzed in the event additional investigations and/or an Alabama Risk Based Corrective Action (ARBCA) evaluation is necessary. If necessary, the Shelby Tube samples will be analyzed for porosity,specific gravity,moisture content,dry density,and fractional organic carbon. The undisturbed samples will be collected from a depth of approximately 2'to 4' bgs. 528 Mineral Trace I Hoover,AL 35244 1 p(205)985-4874 1 f f205)987-5080 www.labellapc,com Phase II Environmental Site Assessment Work Plan Alabama State Port Authority Former Mobile River Terminal Site Project No.2232421 Mobile,Alabama Page 12 of 24 LaBelle will make a decision whether to analyze the Shelby Tubes prior to exceeding the applicable holding times. 4.3.2 Soil Sample Delineation The soil samples collected from the initial and first step-out soil borings will be analyzed for the Site- specific target analyte groups(i.e., PAHs and RCRA 8 metals). Additional step-out soil borings/samples will be advanced if warranted. See below for a more detailed summary of the Focus Area's soil boring sampling methodology. In the first step-out soil boring, if one or more constituent(s) is/are detected at a concentration above the EPA Residential RSL for soil in a sample,then the vertically equivalent and next underlying sample interval will be analyzed in a subsequent step-out soil boring(likely in approximately 20 foot intervals). The constituent(s)to be reported in the subsequent step-out boring soil samples will be those detected in the nearest step-out samples with concentrations above the EPA Residential RSL. As an example, if in the first step-out soil boring, one metal is detected at a concentration above the EPA Residential RSL for soil in the 0 - 1' interval and two PAHs are detected at concentrations above the EPA Residential RSL for soil in the 1' -4' interval,then in the subsequent step out boring, one metal will be analyzed in the 0- 1' (vertically equivalent)and 1' - 4'(next underlying)intervals, and two PAHs will be analyzed in the 1' - 4' (vertically equivalent) and just above the soil/groundwater interface (next underlying) intervals. Additional step-outs may be warranted pending review of the initial soil sampling effort. In the event EPA RSL exceedances are detected in a step-out boring sample additional step out borings will be advanced in the applicable Cardinal direction(s) to definitively delineate (horizontally and vertically) the EPA RSL exceedance(s) to unlimited use/unrestricted exposure. The same analytical result screening methodology as detailed in the above example will be performed on the laboratory results from subsequent step-out samples analyzed to determine which, if any, constituents, and intervals should be analyzed in additional step-out soil borings (if warranted). All sample analyses will be performed to allow adequate time(i.e.,taking into consideration the analytical method hold times)to analyze subsequent step-out soil samples if warranted. It is the intent of this investigation to adequately delineate soil and groundwater at the Site both vertically and horizontally to unlimited use/unrestricted exposure(UU/UE). However, it should be noted that the ASPA property to the south (MCT) is concrete covered and already has an environmental 528 Minera[Trace I Hoover,AL 35244 1 p(205)985-4874 1 f f205)987-5080 www.labeltapc,com Phase II Environmental Site Assessment Work Plan Alabama State Port Authority Former Mobile River Terminal Site Project No.2232421 Mobile,Alabama Page 13 of 24 covenant restricting soil and groundwater use; therefore, step-out borings will not extend onto that property,or into the waterway to the east. Parcels to the west and north are owned by others;therefore, ASPA will request access if sampling delineation is required beyond the ASPA property boundary. 4.4 MONITORING WELL INSTALLATION LaBella proposes the installation of five Type II groundwater monitoring wells at the approximate locations shown on Figure 4. The location of each of the monitoring wells was selected to define the horizontal extent of contamination in groundwater, if present, in the local area of each focus area;and, to determine the direction of groundwater flow at the Site. The monitoring wells will be constructed as Type II permanent monitoring wells in general accordance with the most recent edition of the AEIRG Manual. Each of the monitoring wells will be constructed using a 2-inch diameter Schedule 40 PVC, 0.01-inch slotted screen (centered on the top of the shallow water table) and riser casing to ground surface.The wells will be completed by filling the well annulus with a sand filter pack to a minimum of two feet above the screened interval, followed by a 2-ft thick bentonite seal above the filter pack. The remainder of the annulus will be grouted to the surface. Depending on the location of a monitoring well, a well may be completed with either a flush-mounted, bolt-down well vault anchored in a concrete surface pad,or a steel/aluminum stick-up protective cover set in a concrete surface pad. All stick-up wells will be protected with steel bollards installed at each corner of the concrete pad. A typical Type II monitoring well construction is provided on Figure 5. 4.8 GROUNDWATER SAMPLING Once the monitoring wells are installed,the newly installed wells will be developed to remove sediments and return groundwater flow to pre-drilling conditions. Groundwater samples will be collected from all permanent groundwater monitoring wells using low-flow sampling techniques to minimize the introduction of sediment into the groundwater samples and to minimize the amount of purge water generated during sample collection. Low-flow sampling will be conducted by lowering disposable polyethylene tubing to a depth that intersects the top of the screened interval in each well. A peristaltic pump, set to a flow rate that minimizes drawdown of groundwater inside the well casing,will be utilized in an effort to collect samples most representative of formation water passing through the screened interval of the well. Additionally, the pump tubing will be positioned in the well so as to reduce the agitation of the water column, which can increase the level of turbidity in groundwater samples. Groundwater will be pumped from each well at a rate approximately equal to the well recharge rate,and the water level will be monitored every three to five minutes until an equilibrium flow rate from the aquifer into the well column is achieved. 528 Mineral Trace I Hoover,AL 35244 1 p(205)985-4874 1 f f205)987-5080 www.labelLapc,com Phase II Environmental Site Assessment Work Plan Alabama State Port Authority Former Mobile River Terminal Site Project No.2232421 Mobile,Alabama Page 14 of 24 Field indicator parameters [turbidity, temperature, pH, dissolved oxygen (DO), oxidation-reduction (redox) potential, and specific conductivity] will be measured and recorded until stabilization of these parameters is achieved in three consecutive readings, indicating that formation water is passing through the pump. Samples will be collected after field indicator parameters have been stabilized. 4.5.1 Groundwater Sample Analysis Groundwater samples will be analyzed for: Sites 1 through 5 - PAHs in accordance with EPA Method 8270ESIM and RCRA 8 metals in accordance with EPA Methods 6020B,^^'" 'vrm 7irvv70R 7470A(mercury), and 7199(hexavalent chromium).Sites 2.3.and 5 - VOCs in accordance with EPA Method 8260D and 8011(1.2-dibromoethane and 1.2-dibromo-3chloroorooane),and Site 1-PCBs in accordance with EPA Method 8082A. 528 Mineral Trace I Hoover,AL 35244 1 p(205)985-4874 1 f f205)987-5080 www.labellapc,com Phase II Environmental Site Assessment Work Plan Alabama State Pon Authority Former Mobile River Terminal Site Project No.2232421 Mobile,Alabama Page 15 of 24 5.0 SAMPLE HANDLING AND OUALITYASSURANCE As part of this assessment, each sample will be tracked from the time of collection by completing sample custody documentation. The sample custody documentation will include the field documentation and the chain of custody report. All samples will be containerized in laboratory provided containers and preserved in a manner appropriate to the analytical method requested in accordance with the AEIRG. Sample containers will be stored in a clean, secure area prior to use. Containerized samples will be labeled as they are collected and placed in a cooler with ice to maintain a sample temperature of 4°Celcius until delivered to the analytical laboratory. Sample criteria are summarized in the following table. ANALYTICAL METHOD CONTAINER PRESERVATIVE HOLDING TIMES SOIL Polvyycrc Aromatic Hydrocarbons 4 oz glass 4' C 14 Days Method 8270E-SIM 180 Days 30 days for RCRA 8 Metals hexavalent chromium Methods 6020BT, 7471Br ',and 4 oz glass 4-O from samolingto 3060A/7199znd-6019Bz extraction(then 7 days from extraction to anal is volatile Ontario Compounds 1-40ml clear Was Me0H 4° C 14 Dates Methods 8260D GROUNDWATER Method 82701 2 -40 ml amber glass 4° C 7 Days RCRA8 Matale 250 ml plastic&200 ml s 24 Methods 6020B, 74798 0Ar r747 T plastic(hexavalent Nitric Acid_,4° C 180 80 Days, hours for 24 chromium a and 7199z6O1OR? chromium) a Volatile Organic Compounds 3-40ml amber glass HCI Acid,4° C 14 Days Methods 8260D and 8011 Polychlorinated BiphenNs 2- 1 Liter amber glass 4la CC 7 Da s Method 8082A Nofea' SIM-selective ion monitoring i EPA Method 747113/74iB6-7470A for Mercury 2 EPA Method 7199 for hexavalent Chrom um when extraded Ev Method 3060A(S,il oink) oz-ounce ° C-degrees Celsius RCRA-Resource conservation and Recovery Act HCI-Hvdmchloric acid mI-milliliter MCOH—..(h elMgtbanol Sample labels will be filled out using the labeling strategy in Table 4.3 and affixed to appropriate containers immediately prior to or following sample collection, as appropriate. The label will be filled out in indelible ink and will include the following information on the portion affixed to the sample 528 MineraLTrace I Hoover,AL 35244 1 p(205)985-4874 1 f f205)987-5080 www.labelLapc,com Phase II Environmental Site Assessment Work Plan Alabama State Port Authority Fortner Mobile River Terminal Site Project No.2232421 Mobile,Alabama Page 16 of 24 container:sample ID number;analyses requested; project name;and the person's name collecting the sample. Applicable quality control samples (field duplicates, equipment blanks, etc.) will be collected and analyzed in accordance with Appendix D of the AEIRG. The following quality control sampling frequencies will be implemented duringthe Phase II ESA. • Field Duplicates: One per 20 samples per media. • Equipment Blanks: One per media per sampling event. • Matrix Spike/Matrix Spike Duplicates:One per 20 samples per media. The field data recorded at the time of sample collection provides an unambiguous identification of each sample.The field data will be recorded in a bound daily record book with numbered pages. Field notes will include the following: • date and time of sampling; • name(s)of field personnel conducting sampling; • name(s)of any observers at the sampling site; • purpose of sampling; • description of sample point; • number and size(s)of sample(s)taken; • field sample identification number(s); • deviation from sampling plan, if any; • field observations; • references(such as maps)of samplingsite;and • sample handling and shipping information. Sample handling and shipping procedures will assure that samples are properly preserved, protected, and secured until delivered to Pace. After sample containers are labeled,they will be sealed in plastic air cushion bags and wrapped in clear plastic bags to protect sample bottles and labels from potential moisture damage. Ice packs will be sealed in plastic bags and placed on top of Samples in order to maintain an optimum temperature of 4-C until the samples are delivered to the laboratory. Any remaining void space in the ice chest will be filled with appropriate bubble-wrap packing material. Samples will be sent to Pace via overnight delivery service and will be accompanied by an appropriate freight (shipment) bill of lading form with the completed freight bill number recorded on the Chain of Custody accompanying each cooler. The Chain of Custody will be sealed in a plastic bag and taped to the underside of the inside of the cooler. The coolers will be sealed with tape and a custody seal that will be initialed and dated to prevent any tampering during shipping and handling. Sample custody documentation procedures will be maintained throughoutthe following activities: 528 Mineral Trace I Hoover,AL 35244 1 p(205)985-4874 1 f f205)987-5080 www.labellapc,com Phase II Environmental Site Assessment Work Plan Alabama State Port Authority Former Mobile River Terminal Site Project No.2232421 Mobile,Alabama Page 17 of 24 • initial sample collection; • transportation from sample collection site to analytical laboratory; • receipt and preparation of laboratory sample extracts and digestives; • storage at laboratory until an evaluation of analytical results determines that re-analysis is not required;and • final sample disposition. At the time of Sample collection, Samples will be labeled, and a record of the sampling activity will be recorded in the daily field log. Sample labeling procedures were discussed previously. Information required to identify sample custody and to request sample analyses are then entered on the Chain of Custody. The information recorded on the Chain of Custody will include: • project name and number; • sampler's name and signature; • sample identification numbers; • sample date,time,and location; • requested analyses; • sample containertype and quantity; • requested analytical turnaround time;and • person to receive results and a contact telephone number to call in case problems arise. Pace will be notified prior to shipment of samples that would arrive at the laboratory on a weekend or holiday to assure that the samples are properly received. In accordance with the AEIRG,samples will be analyzed by the laboratory according to the most current EPA SW-846 guidance. 528 Mineral Trace I Hoover,AL 35244 1 p(205)985-4874 1 f f205I 987-5080 www.labelLapc,com Phase II Environmental Site Assessment Work Plan Alabama State Port Authority Former Mobile River Terminal Site Project No.2232421 Mobile,Alabama Page 18 of 24 6.0 MANAGEMENT OF INVEMATIVE DERIVED WASTE(IDWI LaBelle will containerize soil cuttings from drilling and sampling activities,groundwater that is removed from monitoring wells during development and purging activities, and accumulated water and solids generated from decontamination of equipment. The investigative derived wastes (IDW) will be stored onSite in either roll-off containers or 55-gallon drums pending characterization for disposal. Upon receipt of laboratory analysis, the IDW will be properly disposed following local, state, and federal guidelines. 528 Mineral Trace I Hoover,AL 35244 1 p(205)985-4874 1 f f205)987-5080 www.labeltapc,com Phase II Environmental Site Assessment Work Plan Alabama State Port Authority Former Mobile River Terminal Site Project No.2232421 Mobile,Alabama Page 19 of 24 7.0 DECONTAMINATION All contaminated equipment and tools will be decontaminated or disposed of in accordance with the most recent edition of the AEIRG. Decontamination and routine maintenance of all drilling and sampling equipment will be completed prior to arriving at the subject site. 7.1 SAMPLING EQUIPMENT DECONAMINATION Sampling equipment will be either disposable or decontaminated prior to use and between sampling locations. New disposable nitrile gloves will be used between each soil sample and groundwater sample. Disposable polyethylene tubing will be used to collect all groundwater samples during the groundwater sample collection activities. The water level indicator will be decontaminated between uses at each well. Decontamination of non-disposable equipment will be conducted by washing with distilled water and laboratory grade detergent wash, followed by rinsing with distilled water. All non- disposable equipment used during this Assessment will be decontaminated according to the following procedures: • Drilling equipment will be decontaminated prior to use and between each monitoring well location. • The equipment will be manually brushed using soap and tap water to remove all particulate matter. The residue will be consolidated with drill cuttings and other Solid materials generated duringthe groundwater assessment activities. • The equipment will then be washed with a high-pressure steam-cleaner using potable water. All hand-held equipment will be steam cleaned using potable water and a laboratory grade detergent. • Equipment will be rinsed thoroughly using analyze free water. Accumulated water and solids will be collected, containerized,and stored on-Site pending characterization for disposal. 7.2 PERSONNEL DECONTAMINATION Personnel decontamination will be performed on an as-needed basis only. All contractors and employees will wear Level D personal protective equipment(PPE)when there is potential for exposure to hazardous materials in the work area. Any contaminated PPE generated during site activities will be disposed of following applicable State disposal guidelines. Non-disposable PPE will be manually brushed to remove residue. The residue will be placed with drill cuttings and other solid materials generated during investigative activities. 7.3 DECONTAMINATION PAD A decontamination pad will be constructed onSite in an area known or believed to be free of surface contamination, on a level, paved surfaced that is well drained.The pad will retain all decontamination 528 MineraLTrace I Hoover,AL 35244 1 p(205)985-4874 1 f f205I 987-5080 www.labelLapc,com Phase II Environmental Site Assessment Work Plan Alabama State Port Authority Former Mobile River Terminal Site Project No.2232421 Mobile,Alabama Page 20 or 24 fluids and site contaminants, which will be achieved by surrounding the pad with a berm or wall that is 8 to 12 inches high.The walls will be constructed of lumber. A small shallow sump will be dug in one corner of the pad.The sump will be deep enough to contain the intake line of a pump.The pad will be lined with a disposable, impervious material with no seams within the pad. Prior to laying down the liner, the area will be swept or pressure-washed.The pad will be drained frequently to keep standing water from splashing onto clean equipment. Following the end of the project,the contents of the pad will be removed and properly disposed,then the sump will be backfilled with the appropriate material. 528 Mineral Trace I Hoover,AL 35244 1 p(205)985-4874 1 f f2051 987-5 080 www.labellapc,com Phase II Environmental Site Assessment Work Plan Alabama State Port Authority Former Mobile River Terminal Site Project No.2232421 Mobile,Alabama Page 21 of 24 8.0 IMPLEMENTATION SCHEDULE Scheduling and implementation of the investigative activities described in the Plan, including monitoring well installation and sampling, is estimated to require approximately 45 days from the date of plan approval; however, will be dependent on subcontractor scheduling. Completion of field activities, data collection, and preparation of a report of the findings associated with this Work Plan is estimated to require approximately 60 to 90 days from receiving all laboratory analytical data reports. 528 Mineral Trace I Hoover,AL 35244 1 p(205)985-4874 1 f f205)987-5080 www.labelLapc,com Phase II Environmental Site Assessment Work Plan Alabama State Port Authority Former Mobile River Terminal Site Project No.2232421 Mobile,Alabama Page 22 of 24 9.0 DATA MANAGEMENT AND REPORTING Following completion of the field assessment activities, LaBelle will prepare a Phase II ESA report.The report will include a detailed description of all investigation activities conducted at the site. The report will include details of assessment activities and recommendations for corrective action measures, if indicated. Additionally,the comprehensive report will include copies of soil boring logs, monitoring well diagrams, field parameters, analytical data and laboratory reports with copies of completed chain-of- custody forms. Additionally, certified copies of the waste disposal manifests, if regulated wastes are generated during completion of assessment activities,will also be included. It is anticipated that this assessment will result in a significant volume of data. This data will include information about the Site lithology, sampling locations, sample media, field data, and the results of laboratory analysis. Data management procedures will be established to effectively process this data such that relevant data descriptions are readily accessible and accurately maintained. The procedures outlined in this Work Plan will assist in managingthe data generated. The data will be presented in a clear and logical format including narrative descriptions and discussions, tabular presentation of data, and graphical and pictorial displays including boring/monitoring well locations,soil boring logs,and potentiometric maps. One hardcopy and one electronic copy of the final report will be provided to ADEM. 9.1 DATA EVALUATION SO& Detected concentrations of PAHs and RGRA 8 metaisconstituents of potential concern (see Table 1 in the Tables Section) in soils will be compared to the EPA RSLs for Residential and Industrial Soils. It is LaBella's understandingthatthe Site's planned future use will be for commercial or industrial purposes; therefore,the comparison to EPA Residential RSLs would be for comparison purposes only and would be used to identify the COCs at the Site for the purpose of corrective action,such as an environmental covenant with land-use controls, should it be necessary. Groundwater Detected concentrations of oAus and RCRA o .....e..r, o ...,......constituents of potential concern (see Table 1 in the Tables Section) in groundwater samples will be compared to the US EPA MCLs,and in the absence of a published MCL, compared to US EPA RSLs for Tap Water. 528 Mineral Trace I Hoover,AL 35244 1 p(205)985-4874 1 f f205)987-5080 www.labeltapc,com Phase II Environmental Site Assessment Work Plan Alabama State Port Authority Former Mobile River Terminal Site Project No.2232421 Mobile,Alabama Page 23 or 24 nnHSAITHAKIIIAl VS to Ste Safe Meet ngs and 528 Mineral Trace I Hoover,AL 35244 1 p(205)985-4874 1 f f205)987-5080 www.labelLapc,com Phase II Environmental Site Assessment Work Plan Alabama State Port Authority Former Mobile River Terminal Site Project No.2232421 Mobile,Alabama Page 24 of 24 1-0.0 REFERENCES Alabama Department of Environmental Management, Alabama Environmental Investigation and Remediation Guidance, Revision 4.0. February 2017. Alabama Department of Environmental Management, Resource Conservation and Recovery Act Facility Assessment. October 10, 2019. Alabama Department of Environmental Management, Resource Conservation and Recovery Act Facility Assessment Addendum. February 26, 2020. ENVIRON International Corporation, Phase I Environmental Site Assessment. October 20, 2009. Environmental Resources Management, Environmental Due Diligence Assessment. May 2007. Gustaysson, N., Bolviken, B., Smith D.B., and Severson, R.C., Geochemical Landscapes of the Conterminous United States. November 2001. Volkert, Inc., Phase I and Limited Phase II Environmental Assessment Report.July 2014. 528 Mineral Trace I Hoover,AL 35244 1 p(205)985-4874 1 f f205I 987-5080 www.labeltapc,com TABLES Table 1 Soil and Groundwater Constituent Analytical Summary Phase 11 Environmental Site Assessment Former Mobile River Terminal,Mobile,Alabama Revised December 2023 GROUNDWATER METHOD PARAMETER Pale EPA METHOD PARAMETER Pare EPA Former MRT Resident RSL for Intlustrial RSL for 9i[e(s(to be MDL RDL MDL RDL Tap Water MCL RSL' Analyzed MG KG MG KG (m /I l (m /I ( u L u L (ug/L( (ug/L) (ug/L( VO VOU 8260D ACETONE 0,0365 0,05 7000 110000 8260D ACETONE 113 50 18W 1800 8260D Acrolein NA NA 0014 0,05 8260D Acrolein 2,54 50 00042 00042 8260D ACRYLONITRILE 0.00361 0.0125 0.25 1.1 8260D ACRYLONITRIIE 0.671 10 0.052 0.052 8260D BENZENE 0.000467 0.001 1.2 5.1 8260D BENZENE 0,0941 1 0.46 5 5 8260D BROMOBENZENE 0.0009 0.0125 29 180 8260D BROMOBENZENE 0.118 1 6.2 6.2 8260D BROMODICHLOROMETHANE 0.000725 0.0025 15 63 8260D BROMODICHLOROMETHANE 0.136 1 8.3 8.3 8260D BROMOFORM 0.00137 0.025 19 86 8260D BROMOFORM 0.129 1 3.3 80 80 8260D BROMOMETHANE 0.00197 0.0125 0.68 3 8260D BROMOMETHANE 0.605 5 0.75 O.JS 8260D N-BUTYLBENZENE 0.00525 0.0125 390 58W 8260D N-BUTYLBENZENE 0.157 1 100 IN 8260D SEC-BUTYLBENZENE 0.00288 0.0125 780 120M 8260D SEC-BUTYLBENZENE 0.125 1 200 200 8260D TERT-BUTYLBENZENE 0.00195 0.005 780 120M 8260D TERT-BUTYLBENZENE 0.127 1 69 69 8260D CARBON TETRACHLORIDE 0.000898 0.005 0.65 2.9 8260D CARBON TETRACH LORIOE 0.128 1 0.46 5 5 8260D CHLOROBENZENE 0.00021 0.0025 28 130 8260D CHLOROBENZENE 0.116 1 7.8 100 100 8260D CHLORODIBROMOMETHANE 0.000612 0.0025 0.29 1.3 8260D CHLORODIBROMOMETHANE 0.14 1 0.13 SO 80 8260D CHLOROETHANE 0.0017 0.005 540 23W 8260D CHLOROETHANE 0.192 5 830 830 8260D CHLOROFORM 0.00103 0.0025 0.32 1.4 8260D CHLOROFORM 0.111 S 0.22 SO 80 8260D CHLOROMETHANE 0.00435 0.0125 11 46 8260D CHLOROMETHANE 0.96 2.5 19 19 8260D 2-CHLOROTOLUENE 0.000865 0.0025 160 23W 8260D 2-CHLOROTOLUENE 0.106 1 24 24 8260D 4-CHLOROTOLUENE 0.00045 0.005 160 23W 8260D 4-CHLOROTOLUENE 0.114 1 25 25 8260D DIBROMOMETHANE 0.00075 0.005 2.4 9.9 8260D DIBROMOMETHANE 0.122 1 0.83 0.83 8260D 1,2-DICHLOROBENZENE 0.000425 0.005 ISO 930 8260D 1,2-DICHLOROBENZENE 0.107 1 30 600 600 8260D 1,3-DICHLOR0BENZENE 0.0006 0.005 NE NE 8260D 1,3-DICHLOROBENZENE 0.11 1 NE 8260D 1,4-DICHLOROBENZENE 0.0007 0.005 2.6 11 8260D 1,4-DICHLOROBENZENE 0.12 1 0.48 75 75 8260D DICHLORODIFLUOROMETHANE 0.00161 0.0025 8.7 37 8260D DICHLORODIFLUOROMETHANE 0.374 5 20 20 8260D 1,1-DICHLOROETHANE 0.000491 0.0025 3.6 16 8260D 1,1-DICHLOROETHANE 0.1 1 2.8 2.8 8260D 1,2-DICHLOROETHANE 0.000649 0.0025 0.46 2 8260D 1,2-OICHLOROETHANE 0.0819 1 0.17 5 5 8260D 1,1-DICHLOROETHENE 0.000606 0.0025 23 100 8260D 1,1-DICHLOROETHENE 0.188 1 28 J J 8260D CIS-1,2-DICHLOROETHENE 0.000734 0.0025 6.3 37 8260D CIS-1,2-DICHLOROETHENE 0.126 1 2.5 JO 70 8260D TRANS-I,2-DICHLOROETHENE 0.00104 0.005 ] 30 8260D TRANS-I,2-DICHLOROETHENE 0.149 1 6.8 IN 100 8260D 1,2-DICHLOROPROPANE 0.00142 0.005 1.6 6.6 8260D 1,2-DICHLOROPROPANE 0.149 1 0.82 5 5 8260D 1,1-DICHLOROPROPENE 0.000809 0.0025 HE NE 8260D 1,1-DICHLOROPROPENE 0.142 1 NE 8260D 1,3-DICHLOROPROPANE 0.000501 0.005 160 23W 8260D 1,3-DICHLOROPROPANE 0.11 1 37 37 8260D CIS-1,3-DICHLOROPROPENE 0.0007S7 0.0025 HE NE 8260D CI5-1,3-DICHLOROPROPENE 0.111 1 NE Sites 2,3,&5 8260D TRANS-I,3-DICHLOROPROPENE 0.00114 0.005 NE NE 8260D TRANS-I,3-DICHLOROPROPENE 0.118 1 NE 8260D 2,2-DICHLOROPROPANE 0.00138 0.0025 HE NE 8260D 2,2-DICHLOROPROPANE 0.161 1 HE 8260D DI ISOPROPYL ETHER 0.00041 0.001 220 940 8260D DI-ISOPROPYL ETHER 0.105 1 150 150 8260D ETHYLBENZENE 0.000737 0.0025 5.8 25 8260D ETHYLBENZENE 0.137 1 1.5 700 700 8260D HEKACHLORO-I,3-BUTADIENE 0.006 0.025 1.2 5.3 8260D HEKACHLORO-I,3-BUTADIE 0.337 1 0.14 0.14 8260D ISOPROPYLBENZENE 0.000425 0.0025 190 990 8260D ISOPROPYLBENZENE 0.105 1 45 45 8260D P-ISOPROPYLTOLUENE 0.00255 0.005 HE NE 8260D P-ISOPROPYLTOLUENE 0.12 1 HE 8260D 2-BUTANONE(MEK) DOBBS 0.1 2700 19000 8260D 2-BUTANONE(MEK) 1.19 30 560 560 8260D METHYLENE CHLORIDE 0.00664 0.025 35 320 8260D METHYLENE CHLORIDE 0.43 5 11 5 5 8260D 4-METHYL-2-PENTANONE(MIER) 0.00228 0.025 33M 14000 8260D 4-METHYL-2-PENTANONE(MIBK) 0.478 30 630 630 8260D METHYL TERT-BUTYL ETHER 0.00035 0.001 47 230 1111111V82601) METHYL TERT-BOWL ETHER 0.101 1 14 14 8260D N-PROPYLBENZENE DUNES 0.005 380 24M 8260D N-PROPYLBENZENE 0.0993 1 66 66 8260D STYRENE 0.000229 0.0125 BUD 35W 8260D STYRENE 0.118 1 120 100 100 8260D 1,1,1,2-TETRACHLOROETHANE 0.000948 0.0025 2 9A 8260D 1,1,1,2-TETRACHLOROETHANE 0.147 1 0.57 O.SJ z 8260D 1,1,2,2-TETRACHLOROETHANE 0.000695 0.0025 0.6 2.7 8260D,LL 1,1,2,2-TETRACHLOROETHANE 0.015 1 0.076 0.076 8260D 1,1,2-TRICHLOROTRIFLUOROETHANE 0.000754 0.0025 670 28W 8260D 1,1,2-TRICHLOROTRIFLUOROETHANE 0.18 1 3000 3000 8260D TETRACHLOROETHENE 0.000896 0.0025 8.1 39 8260D TETRACHLOROETHENE 0.3 1 0.1 5 5 8260D TOLUENE O.O013 0.005 490 4]00 8260D TOLUENE 0.278 1 130 3000 3000 8260D 1,2,3-TRICHLOROBENZENE 0.00]33 0.0125 6.3 93 8260D 1,2,3-TRICHLOROBENZENE 0.23 1 OJ OJ BZfiOD 1,2,4-TRICHLOROBENZENE 0.0044 0.0125 5.8 26 8260D 1,2,4-TRICHLOROBENZENE 0.481 1 0.4 JO ]D 8260D 1,1,1-TRICHLOROETHANE 0.000923 0.0@5 830 3600 8260D 1,1,1-TRICHLOROETHANE 0.149 1 800 200 200 8260D 1,1,2-TRICHLORO ETHANE O.DOD597 0.0025 0.15 0.63 8260D 1,1,2-TRICHLOROETHANE 0.158 1 0.041 5 5 8260D TRICHLOROETHENE 0.000584 0.001 0.41 1.9 8260D TRICHLOROETHENE 0.19 1 0.28 5 5 8260D TRICH LOROFLUOROM ETHANE 0.000827 0.0025 2300 35000 8260D TRICH LOROFLU ORO METHANE 0.16 5 520 520 8260D 1,2,3-TRICHLOROPROPANE 0.00162 0.0125 BOOK 0.11 8260D 1,2,3-TRICHLOROPRO 0.23] 25 0.00075 0.00075 8260D 1,2,4-TRIMETHVLBENZENE 0.00158 0.005 30 180 82600 1,2,4-TRIM ETHVLBENZENE D.322 1 5.6 5.6 8260D 1,2,3-TRIMETHVLBENZENE 0.00158 0.005 34 200 82600 1,2,3-TRIM ETHVLBENZENE DAN 1 5.5 5.5 8260D 1,3,5-TRIMETHVLBENZENE 0.002 0.005 27 150 82600 1,3,5-TRIMETHVLBENZENE DAN 1 6 6 8260D VINYL CHLORIDE 0.00116 0.0025 0.059 13 8260D VINYL CHLORIDE 0.234 1 D.019 2 2 8260D XYLENES,TOTAL 0.00088 3.0065 58 250 8260D XYLENES,TOTAL 0.174 3 19 10000 10000 8260D 1,2-DIBROMOETHANE(ETHYLENE DIBROMIDE) O.DOD648 0.0025 0.036 0.16 8011 1,2-DIBROMOETHANE(ETHYLENE DIBROMIDE) 0.00536 0.02 0.0075 0.05 0.05 8260D 1,2 DIBROMO-3-CHLOROPROPANE 0.W039 0.025 0.0053 0.064 8011 1,2 DIBROMO-3-CHLOROPROPANE 0.00748 0.02 0.W033 0.2 0.2 PARS Ms 8270E-SIM ACENAPHTHENE 0.00209 0.006 360 4500 8270E-SIM ACENAPHTHENE 0.019 0.05 53 53 8270E-SIM ANTHRACENE 0.0023 0.006 1800 23000 8270E-SIM ANTHRACENE 0.019 0.05 180 180 8270E-SIM BENZO(A)ANTHRACENE 0.001]3 0.006 1.1 21 827OE-SIM BENZO�A)ANTHRACENE 0.0203 0.05 0.03 0.03 8270E-SIM BENZO(A)PVRENE 0.00179 0.006 0.57 7.3 8270E-SIM BENZO�A)PYRENE 0.0184 0.05 0.18 0.18 8270E-SIM BENZO(B)FLUORANTHENE 0.00153 0.006 1.1 21 8270E-SIM BENZO(B)FLUORANTHENE 0.0168 0.05 0.25 0.25 8270E-SIM BENZO(K)FLUORANTHENE 0.00215 D.006 11 230 827OE-SIM BENZO(K)FLUORANTHENE 0.0202 0.05 2.5 2.5 8270E-SIM BENZORG,H,I)PERYLENE 0.00177 0.006 HE HE 8270E-SIM BENZO(G,H,I)PERYLENE 0.0184 0.05 HE 8270E-SIM CHRYSENE 0.00232 0.006 110 21M 8270E-SIM CHRYSENE 0.0179 0.05 25 25 8270E-SIM DIBENZ(A,H)ANTHRACENE 0.00172 0.006 0.11 2.1 8270E-SIM DIBENZ(A,H)ANTHRACENE 0.016 0.05 0.025 0.025 Sites 1-5 8270E-SIM FLUORANTHENE 0.0022J 0.006 240 30M 8270E-SIM FLUORANTHENE 0.027 0.1 80 80 8270E-SIM FLUORENE 0.00205 0.006 240 30M 8270E-SIM FLUORENE 0.0169 0.05 29 29 8270E-SIM INDENO(1,2,3-CD)PYRENE 0.00181 0.006 1.1 21 8270E-SIM INDENO(1,2,3-CD)PYRENE 0.0158 0.05 0.25 0.25 8270E-SIM NAPHTHALENE 0.00408 0.02 2 8.6 8270E-SIM NAPHTHALENE 0.0917 0.25 0.12 0.12 8270E-SIM PHENANTHRENE 0.00231 0.006 HE HE 8270E-SIM PHENANTHRENE D.O18 0,05 HE 8270E-SIM PYRENE 0.002 0.006 180 23M 8270E-SIM PYRENE 0.0169 0.05 12 12 8270E-SIM 1-METHYLNAPHTHALENE 0.00449 0.02 18 73 8270E-SIM 1-METHYLNAPHTHALENE 0.0687 0,25 1.1 1.1 8270E-SIM 2-METHVLNAPHTHALENE 0.00427 0.02 24 300 8270E-SIM 2-METHYLNAPHTHALENE 0.0674 0,25 3A :A36 METALS METALS 6020B ARSENIC 0.02 20.4400 0.68 3 6020B ARSENIC 0.18 2 0.052 10 10 6020B BARIUM 0.0304500 22000 6020B BARIUM 0.381 2 380 2000 2000 6020B CADMIUM hilet) 0.01710,71 10 6020B CADMIUM 0.15 1 0.18 5 5 6020B CHROMIUM 0.0593HE HE 6020B CHROMIUM 1.24 2 Loa LOD Sites 1-5 3060A/7199* HEXAVALENT CHROMIUM 0.2550.3 6.3 7199 CHROMIUM 0.15 0.5 D.035 0.035 6020B LEAD 0.0198 800 6020B LEAD 0.849 2 15 15 15 7471B MERCURY 0.018 1.1 4.6 7470A MERCURY 01 0.2 0.063 2 2 6020B SELENIUM 0.035939 580 6020B SELENIUM 0.3 2 10 50 50 PCBs 8082A Aroclor-1016 0.00027 0.0005 0,14 10.14 8082A Aroclor-1221 000027 0.0005 0.0047 0.0047 8082A Aoclor-1232 0.00027 0.0005 0.0047 0.0047 This Section Intentionally Lek Blank 8082A Aroclor-1242 0.00027 0.0005 O.00lB O.00lB LSite 8082A Aroclor-1248 0.00017 0.0005 0.0078 0.0078 8082A Aroclor-1254 0.00017 0.0005 0.0078 0.0078 8082A Aroclor-1260 0.00017 0.0005 0.0078 0.0078 None.. MRT Former Mobile River Terminal MDL Laboratory Method Detection Limit RDL Laboratory Reporting Detection Limit Pace MDLs/ROLs provided by Pace Analytical National Center For Testing and Innovation MG/KG milligrams per kilogram 3 ,ol. micrograms per liter RSL US Environmental Protection Agency(EPA)Regional Screening Levels(Nov.2023) RSL' The Tapwater Screening Level(left justified)will be used as the RSL if a US EPA Maximum Contaminant Level is not available. Residential Soil US EPA Residential Soil Screening Level Industrial Soil US EPA Industrial Soil Screening Level VOCs Volatile Organic Compounds PAHs Polycydic Aromatic Hydrocarbons Sim Selected Ion Monitoring PCBs Polychlorinated Biphenvls 3060Ab199' Hexavalentchromium will be extracted by EPA Method 3060A and analyzed by EPA Method 7199. NE Not established -Constituent with MOL>RSL for Groundwater. Constitituent with an MCL r, Tapwater RSL;however,the MCL will be used for screening purposes. FIGURES h,t I I jp II i JI r _ 98 g617 f s u \\VVII � pEABR yr + YCMORIA t _ er•o i�+i�.sn r' .... '.xF_ - r'Ffo _ _ — i� I , e �J F '.u.- r• r[�I I � —�A._ etdayG • R + I a Sand lalsntl - ..\ ,island )I iCopyfighCO2013 Na Oonal Geographic 5ociely,i Obed Legend TALE: Site Location FIGURE NO. Topographic Map t O Property Boundary C LaBella PRO 23242 Mobile River Terminal 2 ECT NO. (Blue Creek Coal Terminal) Powered by partnership. oRawx BY VirginiaStreet Mobile,Alabama 'a"IH 528 MINERAL TRACE SCALE: DATEDRAWN 0 1,000 2,000 HOOVER,(205)9AL35244 n 05-25-2023 (205)985-08T4 r inch=2,o00 Leer - r i :1 lPOW " � 1 lit Source Lsr, Max,r. LarNsLar Geugrap P lcs.ail IFe GIS User Commur TrrLE: FIGURE NO. Lend Site Map with 2 O Property Boundary Property Boundary LaBelle PROJECT NO. Mobile River Terminal 22324232421.01 Powered by partnership (Blue Creek Coal Terminal) DRAM BY Virginia Street AJH Mobile Alabama 528 MINERAL TRACE eOALE: p 200 Qpp DATEDRAWN HOOVER,AL 35244 EMMMIiiiiiiiii05-25-2023 (205)9854874 1 inch=401 - f r _ .+ v Source-Esr[Maxar,Earthstar Geographlcs,and'the GIS User Cornmunit Legend RLE: G REND. Soil Boring 3 Location Map . Proposed Soil Boring LaBella RR0. . Location ^ Mobile River Terminal 22324232421.01 LEI Proposed Pond Soil Powered by partnership, (Blue Creek Coal Terminal) . oRawx er Sample Location Virginia Street AJH O Former Pond Area Mobile Alabama 528MINE ,AL TRACE SCALE: DATE DRAWN O Property Boundary HOOVER,AL 35244 p2121 05-25-2023 P Y rY (205)985-4874 n7oh=4m reer Rev: 12-18-2023 N 0 o O�aaQ o D 0 i Source:Esri,Maxao Earthstar Geogaphics,and the GIS User Community E: FIGURE NO. Legend TITLProposed Boring Locations 3A Site#1 Proposed Soil Boring• LaBella PROJECT NO. Location Mobile River Terminal 2232421.01 • Powered by partnership, (Blue Creek Coal Terminal) Step-Out Soil Boring oRawxl3Y Virginia Street AJH RFA Site Location#1 Mobile Alabama 528 MINERAL TRACE WALE: 9 10 25 DATEDRi OProperty Boundary HOOVER,AL 35244 EMMINEEMIR 05-25-2023 (205)9854874 1 inch=25feel N 0 0 Source:Esri,Macar,Earthstar Geographics,and the GIS User Community Toni FIGURE NO. Lend Proposed Boring Locations 3B Site#2 Proposed Soil Boring• C LaBella PROJECT NO. Location r1 Mobile River Terminal 22324232421.01 • ICI Step-Out Soil Boring Povrered by partnershiR (Blue Creek Coal Terminal) oRawx av Virginia Street AJH RFA Site Location#2 Mobile Alabama 528 TRACE SCALE: 0 10 25 DATE DRAWN HOOVER, Property Boundary HOOVER,, 44 AL 352 05-25-2023 (205)9854874 1inch=2sfeel N 0 0 e LS. [I , Lerlh�er Community TRLE: FIGURE NO. Lend Proposed Boring Locations 3C Site#3 • Proposed Soil Boring LaBella PRO.IEOT NO. Location Mobile River Terminal 2232421.01 Powered by partnership, (Blue Creek Coal Terminal) Step-Out Soil Boring D.rry I(!) Virginia Street AJH RFA Site Location#3 Mobile Alabama 528 MINERAL TRACE WALE: 0 10 25 DATEDMINN HOOVER,AL 35244 05-25-2023 (205)9854874 inch=26t N 0 o � a 0 dwbw LL� Source:Esri,Maxap Eahhstar Geogmphics,and[he GIS User CommunS TALE: FIGURE NO. Legend Proposed Bor ng Locations 3D Site#4 • Proposed Soil Boring C LaBella PR0.ECT . Location rr�� Mobile River Terminal 22324232421.01 rJ Powered by partnership (Blue Creek Coal Terminal) A Step-Out Soil Boring °R^w"i Virginia Street AJH O RFA Site Location#4 Mobile Alabama 528 MINERAL TRACE SCALE: DATEDRi HOOVER,AL 35244 0 10 25 (2os)985-08Ta � 05-25-2023 1Ihi 26 feel N 0 0 Source.Esri,Maxar,Eadhstar Geographics,and the GIS User Community Ti: FIGURE NO. Legend Proposed Boring Locations 3E Site#5 • Proposed Soil Boring C LaBella PR0.ECT . Location r� Mobile River Terminal 22324232421.01 r�l Povr minal)ered by partnership (Blue Creek Coal Ter e Step-Out Soil Boring °RA`TM'i Virginia Street AJH O RFA Site Location#5 Mobile Alabama 528 MINERAL TRACE SCALE: 0 10 25 DATEDRi HOOVER,AL 35244 05-25-2023 (205)9854874 c inch=25teel f _i N 14 Ill LlmageSource: Google Earth Historical Aerial - November 2020 T E: FIGURE NO. Legend Former Stormwater Collection 3F Pond Sampling Map • Proposed Pond Soil LaBella RR0. . Sample Location r--� Mobile River Terminal 22324232421.01 ICJ Povrereci by partnership (Blue Creek Coal Terminal) Former Stormwater oRawx BY Collection Pond Virginia Street AJH Property Bounds Mobile Alabama P rtY Boundary 528 MINERAL TRACE SCALE: p 25 50 DATE DRAWN HOOVER.AL 35244 EMMMEiiiia(205)9a5 1374 I inch=50feel 12-1-2023 t 4 ; ; - F - . �n G r _ tits te\ � f y T do t Source.Esri,Maxar.Earthstar Geog phi¢\a.hieo is munity Legend I E: FIGURE NO. Monitoring Well 4 Location Map Monitoring Well LaBelle PR0.23242IECT . Mobile River Terminal 2232421.01 O Property Boundary Povi by partnership, (Blue Creek Coal Terminal) DRawx BY Virginia Street AJH Mobile Alabama 528 MINERAL TRACE SCALE: 0 200 Qee DATEDMINN HOOVER,AL 35244 05-25-2023 (205)9854874 1 inch=4Wfect CLIENT: Alabama Port Authority File No.: 2232421.01 LOCATION: Former Mobile River Terminal Top of Riser Elevation: Ground Surface Elevation: Screened Interval: Date Installed: ELEVATION* (feet) LOCKING FLUSH MOUNT COVER GROUND SURFACE: 1 TOP OF RISER PIPE: RISER PIPE: 1"or 2" Diameter Sch. 40 PVC GROUT: Cement-Bentonite Mixture TOP OF SEAL: WELL SEAL: BOTTOM OF SEAL: Granular Bentonite TOP OF SCREEN: 4 BOREHOLE DIAMETER: To Be Determined GRADED SAND PACK: Filter Sand or Pre-Pack Screen on 1"wells SCREEN PIPE: 1"or 2" Diameter Sch. 40 PVC SCREEN SLOT SIZE: BOTTOM OF SCREEN: 10 Slot BOTTOM OF WELL SUMP: BOTTOM OF BOREHOLE: NOT TO SCALE LaBelle Associates Project: Former Mobile River Terminal 528 Mineral Trace Figure 5-Typical Type phase II ESA 11 LaBella Birmingham,Alabama 352" Monitoring Well Cross Section Project No: 2232421.01 Phone:(205)985-0874 6109123 Fax:(205)987-6080 Scale: N/A