Environmental Status Overview October 10, 2013

Substantial environmental investigation work has already been completed at this site. Tank removals and contaminated material excavations are summarized in the Demolition Summary. This document describes the nature and proposed schedule for ongoing and upcoming environmental work as well the envisioned remedial action strategy.

Current Site Contaminants  Soil – Predominant chemical compounds detected in site soil at concentrations that exceed WDNR Residual Contaminant Levels (RCLs) include the following: 1. Petroleum compounds ‐ benzene, 1,2‐dichloroethane , ethylbenzene, , naphthalene, toluene, trimethylbenzenes, and xylenes 2. Polynuclear aromatic hydrocarbons (PAHs ) – multiple, see tables 3. Inorganics ‐ arsenic and lead  Groundwater – 1. Petroleum – benzene, 1,2‐dichloroethane , ethylbenzene, naphthalene, toluene, trimethylbenzenes, and xylenes 2. PAHs ‐ benzo(a)pyrene, benzo(b)fluoranthene, and chrysene – low concentrations 3. Inorganics – arsenic – relatively low concentrations

Chlorinated compounds were generally not detected in site soil or groundwater samples.

Upcoming Site Investigation Work  Install 2‐3 additional monitoring wells southwest of MW‐10 – late October  Complete 2 additional asbestos test pits near sidewalk – late October

Remedial Action Strategy and Notes:  4‐Part Remedial Action Strategy supported by WDNR: 1. Excavate/dispose of asbestos contaminated soil (RACM to complete – early November) 2. Vapor Intrusion (VI) Study / Vapor Mitigation Measures (Developer to complete) 3. Soil management & capping to address direct contact issues (Developer to complete) 4. Natural attenuation monitoring (Ongoing, RACM will attempt to complete prior to land sale)  Submit Final Site Investigation / Remedial Action Plan Document to WDNR – Early 2014  Receive written approval of SI/RAP from WDNR – Spring 2014  Remedial Action NA monitoring (Part 4) will be ongoing during RACM ownership, though may need to continue after land transfer  Developer will be responsible for preparing a VI Study based on their development plan. Vapor mitigation and monitoring may be required (depending on the proximity to impacted soil and groundwater ) as part of the build out.  Developer will be responsible for preparing and adhering to a soil management plan and implementing the final WDNR –approved remedial action (likely capping) to address direct contact issues sitewide.  Developer will be responsible for achieving WDNR case closure. RACM will share environmental data obtained during its ownership to developer for their use and can provide some technical assistance.