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'tJ C 'tJ u I I ... (D ... s:c <' (") (D ...!.. C: = (D ,, r-- m R + R - OSH (D 3 A) El CC CT ci; ;... C RECEIVED (D (D C. C. ... - o., NO PE ::, 0 ... l>Q -. ,. ·1 ?002 C. 0 s: ,, m 0 0 .!.. 'E.z 0 y !o TRACKED 0 ::, r-- gm Rev,eweoo C.-·- .•r-- .,, ::XJ (D 0 M-1 L.L.C. Appleton Facility ::, .: (")m m :c =< 1130 East John Street - 0 -·- ~ C -m l> Cl) ~~ Appleton, Wisconsin R + R .. OSH 0 ,, ...0- p- ,, RECEIVED ::, (D (D -f (D 0 OCT 2 1 2002 '.,: >< A) y::,- Q ;· Cl) . . R . TRACKED ::, ~ Due D11 Igence evIew REVIEWED ~- WDNR ERP Case No. 02-45-181585 ...0 ;:ill;" ...'tJ 0 C. Prepared for: C (") M-1 L.L.C. - 1201 Louisiana, Suite 853 [P. 0. Box 42842, Houston, Texas 77242) C en -c Houston, Texas 77002 0 A) ... (") C CD C Cl) ,, 3 A)_ ...A) (D -· (D ::, 0 C. Prepared by: The Sustainable Company, Inc. -z ~ OCT ~ 3030 Bridgeway, Suite 305 ? ~ = l>~ I'\) ~ ::,- 0 ;- (D Sausalito, CA 94965 0 ...... 0 ~ en I m C 0 er Cl) 0 """" ...... ~ s·S' December 2000 C A) Document Number 2000-001.DDR C CT :D (D 0 < 0 Privileged and Confidential 2. 3 C ,, Attorney-Client Work Product A) 3 ::, (D ..... ~ 0 ::,- .(") w-

Volume 1 of 3 3030 Bridgeway, Suite 305 Sausalito, CA 94965 iti!i!i2,. JHe Sustainable Phone: (415) 339-3000 ~~-0 pany Fax: (707) 248-7405

Letter of Transmittal

ATTENTION: DATE: Ms. Jennifer Tobias October 18, 2002 Hydrogeologist Bureau for Remediation & Redevelopment Wisconsin Department of Natural Resources 625 East County Road Y, Suite 700 Oshkosh, Wl54901-9731

Originals Copies Contents Due Diligence Report 1130 East John Street, Appleton DNR ERP Case No. 02-45-181585

D Urgent D For Review D Please Comment D Please Reply D Please Recycle

Remarks:

Enclosed per your request and your discussions with David and Fred, please find Due Diligence report we prepared for M-I L.L.C. The Demolition and Decommissioning report will be sent on Monday for nd your receipt on Tuesday (October 22 ).

Please don't hesitate to contact us with any questions, at (415) 339-3001 or (415) 339-3002.

Sincerely,

~Anindya Kar Program Manager A, The Sustainable 't)f Co pany

TABLE OF CONTENTS

1.0 Introduction ...... 4 2.0 Description of Subject Property ...... 4 3.0 Historical Site Activities ...... 6 3.1 Non-M-1 Historical Operations ...... 6 3.2 M-1 Historical Operations ...... 7 3.3 Detailed History of Subject Property by Historical Resource ...... 9 3.3.1 Sanborn Fire Insurance Maps ...... 9 3.3.2 Historical Aerial Photographs and Postcards ...... 12 3.3.3 City Directories ...... 13 3.3.4 Historical Building Permits ...... 14 3.3.5 Historical Maps ...... 15 3.3.6 Chain of Title ...... 16 3.4 Previous Investigations Conducted by Miller Engineers and Scientists 16 4.0 Profile of Former Pulp Process Site Operations ...... 18 4.1 Pulp Production ...... 18 4.2 Bleach Plant ...... 19 4.3 Residual Wastes ...... 19 5.0 Aboveground Storage Tanks ...... 19 5.1 ASTs utilized by Non-M-1 Occupants ...... 19 5.2 ASTs Utilized by Barcon and M-1 ...... 20 6.0 Underground Storage Tanks ...... 22 7 .0 Hazardous Waste Generation ...... 22 8.0 Known Spills and Releases ...... 22 9.0 Wastewater Management ...... 26 10.0 Solid Waste Management ...... 28 11.0 Air Permits ...... 29 12.0 Chemical Reporting ...... 29 13.0 Off-Site Properties of Concern ...... 29 14.0 Other Site Observations ...... 30 15.0 Summary of Findings ...... 30 15.1 Chromium Impact ...... 30 15.2 Sulfate Impact ...... 32 15.3 Petroleum Hydrocarbons ...... 36 15.4 PCBs ...... 37 15.5 Dioxins, furans, and adsorbable organic halides ...... 37 15.6 PAHs ...... 38 16.0 References ...... 38

Report No. 2000-001.DDR Appleton, WI 2 A The Sustainable ~'co pany

FIGURES

Figure 1 Site Location Map Figure 2 Sources of Chromium (M-1) Figure 3 Potential Sources of Sulfate, VOCs, and PCB Contamination Figure 4 Photographs

APPENDICES

Appendix A Selected EDR Database Report Sections Appendix B Historical Sanborn Fire Insurance Maps Appendix C Historical Aerial Photographs, Postcards, and Maps Appendix D Chain of Title and Sublease Agreement (provided by M-1) Appendix E Historical City Directories Appendix F Historical Building Permit Records Appendix G Building Plans Provided by M-1 Appendix H Process Flow Diagrams Provided by M-1 Appendix I WDNR Web Pages on Lower Fox River NPL, EPA Pulp and Paper yol I Profile, and Pulp and Paper Dictionary Excerpt ---Appendix J Miscellaneous Documentation Provided by M-1 Appendix K Documentation From WDNR Appleton Field Station v \ i Appendix L Documentation From Wisconsin Dept. of Commerce, USTs 0 Appendix M Documentation From Appleton Fire Department Appendix N Documentation From WDNR Hazardous Waste Department ---=-Appendix 0 Documentation From WDNR Stormwater Department , , Appendix P Documentation From WDNR Wastewater Department v 01 ~ Appendix Q Documentation From WDNR Enforcement Department Appendix R Form R and Tier II Reporting Documentation

Report No. 2000-001.DDR Appleton, WI 3 60; The Sustainable Vco pany

Due Diligence Review of M-l's Appleton, Wisconsin Facility Located at 1130 East John Street

1.0 Introduction

THE SUSTAINABLE COMPANY, INC (TSCI) has prepared this report summarizing the results of our due diligence review of the property located at 1130 East John Street in Appleton, Wisconsin. TSCI conducted a series of visits to the subject property in relation to this due diligence effort, occurring during the weeks of August 7, 2000 and September 18, 2000. TSCI also reviewed available documentation at local and state regulatory and governmental agencies, as well as available information at the local libraries and historical society.

This report is organized in various sections, with references noted within the text of the letter by bracketed notation, e.g. [1], representing the catalogued reference noted in the References section (Section 16.0) of this report. Supporting documentation generated and utilized for the summary of data and conclusions presented herein are attached as appendices to this report.

Please note that all directions discussed in this report are not true, they are based upon the orientation of the subject property. Refer to the figures for this report for clarification.

2.0 Description of Subject Property

The subject property consists of odd-shaped parcels of land, bound by a fence line and Telulah Park to the north, a facility access road and Telulah Canal to the east, and the Fox River to south and west. The subject property encompasses approximately 23 acres. The subject property is currently improved by seven primary structures: the Office building, Front Warehouse,Titanyl Iron Sulfate Storage building, Jammer House, Paint Shed/Pump House, Warehouse and Plant building, and Tank Farm. The subject property land and buildings are owned by the Kaukauna Utilities and are leased by M-I L.L.C. (M-1), with the exception of the Titanyl Iron Sulfate Storage, and Warehouse and Plant buildings that are owned by M-1. The subject property is also improved by railroad lines, one mail line and four spurs. The main line is reportedly owned by Wisconsin Central, and the four spurs are owned by M-I, including maintenance responsibility [33).

The southernmost structure on the property, the Office building, has an approximately 3,000 square foot footprint, is one-story, and has a basement. The Office building was constructed on a concrete slab with a brick fagade. Interior finishes primarily consist of carpeting, vinyl and linoleum flooring in select areas, drop ceiling tile, and wallboard interior walls. The Office building was utilized at the time of the site visit for office operations at the subject property; however, the basement was formerly operated as an on-site laboratory for quality assurance testing of their products.

Report No. 2000-001.DDR Appleton, WI 4 ~, The Sustainable ~Co pany

The Front Warehouse, which was formerly operated as a part of the pulp mill by Consolidated Papers and its predecessors, is currently utilized by M-1 as a storage warehouse. It is located immediately north of the Office building. The Front Warehouse has an approximately 64,000 square foot building footprint, is two-stories with mezzanine areas. The Front Warehouse was constructed on a concrete slab of brick and cinderblock, with cinderblock, brick, and wallboard interior dividing walls, concrete and cinder block pulping process structures, and a wood truss roofing structure.

The Titanyl Iron Sulfate (TIS) building, which houses the former 30,000-gallon TIS AST utilized for wastewater storage, was constructed on a concrete slab, with cinder block exterior. The building encompasses 2,000 square feet. It is located on the west end of the property beyond a vacant grassy area previously developed with numerous structures associated with former pulp mill operations.

The Paint Shed/Pump House, which was not actively utilized by M-1 except for its function of pumping water from the Telulah Canal for on-site process use, for storage of mobile equipment, and for a transition point for city water service. The building has a 3,000 square foot building footprint and is equipped with a basement. The building was constructed on a concrete slab foundation, with cinder block walls. The building is located east of the TIS building.

The Jammer House, utilized for maintenance activities and storage of miscellaneous parts, has an approximate 18,000 square foot building footprint. The Jammer House is a one­ story building, with a mezzanine. The Jammer House was constructed on a concrete block foundation, with metal siding exterior walls and roof, interior wallboard walls in the break room area, interior cinderblock walls in maintenance area. The Jammer House is located east of the Paint Shed/Pump House.

The Warehouse and Plant building is located north of the TIS building. It was utilized at the time of the site visit for manufacturing operations associated with animal feed binder and drilling mud additive products. The southern portion of the joined structures is utilized as a warehouse ("Warehouse"), while the northern portion was utilized for manufacturing operations ("Plant"). The footprint of this structure is approximately 14,000 square feet. The Plant is three stories, while the Warehouse is a single story structure. The building was constructed on a concrete slab foundation, with aluminum siding walls and structural steel supports, and cinder block wall dividing the Plant and Warehouse.

The Tank Farm located north of the Warehouse and Plant building encompasses approximately 9,600 square feet. The superstructure of the Tank Farm consists of metal siding, a wood roofing structure, and six approximately 30,000-gallon interior cell ceramic tile lined tanks of concrete construction. The interior cell tanks are arranged in two rows of three tanks; separating the rows of cell tanks are two exterior ASTs.

At the time of TSCl's site visit, M-1, L.L.C. operated the facility primarily as a drilling mud additive and animal feed binder manufacturing facility. The facility also performed processing of lignin liquor and dry quebracho. The manufacturing and processing activities were performed in the Warehouse and Plant building and Tank Farm area, located in north portion of the subject property.

Report No. 2000-001.DDR Appleton, WI 5 A 1 The Sustainable Vco pany

3.0 Historical Site Activities

This section discusses the historical activities at the subject property, performed by pulp mill operators, Barcon, Dresser Magcobar, and M-1.

3.1 Non-M-1 Historical Operations

The subject property was originally utilized as a pulp mill in the 1860s, producing newsprint from manila, rag stock, and straw. The property was then converted through improvements from 1888 to 1891 to a Mitscherlich (sulfite) process pulp mill and was operated by The Manufacturing Investment Company. The property was purchased by Interlake Pulp and Paper Company in 1899, which operated the facility through 1916, when Consolidated purchased the property. Following the purchase by Consolidated, the property underwent improvements again, beginning with construction of a digester plant in 1928 and 1929 (nine digesters). These dig esters produced 160 tons per day of sulfite pulp. In 1920, a new acid plant and machine shop were constructed. In 1923, a bleach plant was constructed and the filter plant was improved (it is unknown when the filter plant was initially constructed). In 1931, a new bleach plant was constructed. In 1953, the facility began concentrating the liquor into fuel through evaporation; an evaporating plant was constructed. Two additional evaporators were installed in 1962 and 1967. This activity reportedly reduced spent sulfite liquor loading to the Fox River by 75%. In 1959, a boiler house was constructed.

The sulfite pulp process began with receiving logs by rail, which were stored on site until sent to the sawmill to be cut in half, debarked and converted to wood chips. The removal of lignin from the wood chips began in the digesters where the chips and calcium bisulfite acid were cooked with steam. Calcium bisulfite acid was produced on site by burning sulfur to produce sulfur dioxide, then the sulfur dioxide gas and water were passed through limestone in opposite directions to produce the acid. Reportedly, sulfur was received in railcars and stored on the ground surface west of the acid plant. This stockpiling practice appears on a pictorial depiction of the plant in M-l's office at the subject property.

The lignin liquor produced through the digestion process was removed from the pulp and then went to three evaporator units to reduce water content. Following evaporation, the liquor may have been burned to produce fuel (steam) and calcium sulfate ash, was discharged to the river as process waste, or was used as raw material in the Plant. Following construction of the on-site wastewater treatment plant, the liquor was treated before being discharged to the river. Pulp stock produced through digestion underwent further processing. This included cleaning and filtering to remove impurities. The pulp was then bleached. Bleaching likely consisted of a three-stage process known as CEH, consisting of chlorination (C), followed by alkaline extraction through reaction with sodium hydroxide (E), and reaction with calcium hypochlorite (H). The CEH bleaching process of reacting the pulp stock with chlorine in an acidic medium resulted in chlorinated and oxidized lignin. Residual lignin was then removed in an alkaline media. In the final phase of bleaching, chlorine was reacted with pebble lime slaking to produce a calcium hypochlorite solution that was then reacted with the lignin. This was reportedly done to remove residual color.

Report No. 2000-001.DDR Appleton, WI 6 ~* The Sustainable 'ul' Co pany

In the machine room, the pulp was dewatered on the Kamyr wet machine to form sheets of pulp. [26, 27, 30, 38]In August 1982, the pulp mill was shut down by Consolidated. The Barcon operation continued producing drilling fluid additives and animal feed binder (see M-I Historical Operations below). The buildings located central to the property and utilized solely for the pulp mill operations were subsequently removed. [25)

3.2 M-1 Historical Operations

Barcon, a subsidiary company of Dresser Magcobar (predecessor to M-I,LLC.) and Consolidated, began operation in 1959 and converted concentrated sulfite liquor into powdered concentrates, producing initially two products, Stapel (a binder) and Spersene (a dispersant). Consolidated operated the plant for a fee and used its 50% of plant capacity to produce Stapel, while Magcobar used its 50% capacity to produce Spersene. This continued until about 1980 when Consolidated ceased production of Stapel and Dresser Magcobar began producing the same product under the name, Magcopel. Through August 1982, the liquor was obtained from the abutting Consolidated plant (provided through overhead piping). Once the Consolidated pulp mill operation ceased in 1982, liquor was purchased from off-site vendors and delivered by rail car. In 1981, the Barcon plant produced an average high of 122 tons/day of dry lignin products. [25) Following Consolidated's shut down of the pulp mill operation, negotiations began and Dresser Magcobar purchased Consolidated's interest in Barcon on December 10, 1982. Dresser Magcobar began operation of the lignosulfonate plant on December 13, 1982.

Barcon, then Dresser Magcobar and later M-I, operated the lignosulfonate production facility in the Warehouse and Plant building, Titanyl Iron Sulfate (TIS) building, Jammer House, Paint Shed/Pump House, and stored bagged product in the Front Warehouse. It should be noted that M-I owns the Warehouse and Plant Building and the Titanyl Iron Sulfate (TIS) building, and the remaining buildings are leased to M-I by Kaukauna Utilities.

The Jammer House was the former site of train car maintenance and truck maintenance activities. During TSCl's visits to the property, the Jammer House was utilized as a maintenance shop for on site equipment. The Jammer House was originally constructed with a below grade work pit to facilitate work on the underside of train cars. The pit was concrete lined, extended approximately 20 feet long and 3 feet deep in the northern end of the building. Sometime prior to 1981,, the pit was filled with sand and covered with concrete. A floor drain had been previously located within the pit, but it is unknown where the floor drain discharged. [3c]

As Barcon, Dresser Magcobar and then M-I, , the facility has operated to produce additives for drilling fluids (chrome lignosulfonates, ferrochrome lignosulfonates, and chrome-free lignosulfonates, iron lignosulfonates), animal feed binder (calcium lignosulfonates), sodium lignosulfonates, and a tanning agent (sulfonated quebracho). Sulfite lignin liquor is no longer produced on site, but is received by railcar or truck.

Drilling fluids additives production processes begin with first removing calcium from lignin liquor by reaction with either sulfuric acid or ferric sulfate to form gypsum (calcium sulfate) that is then removed from the liquor by filtration.

Report No. 2000-001.DDR Appleton, WI 7 &:.1t The Sustainable "ill Co pany

This occurs in the "Phase A" reaction. The filtered liquor is then sent to the Phase B reactor, where it reacts, depending upon the type of additive being manufactured, with one of the following: titanium sulfate and hydrogen peroxide; sodium dichromate and dry sodium bisulfite; or sodium dichromate. The reactants are then partially neutralized using sodium hydroxide. Aluminum stearate/diesel defoamer is added as needed to both the Phase A and Phase B reactions. Following the Phase B reaction, no additional chemicals are added to the process. The liquid Phase B product is dried in spray dryers; separated from the dryer air using cyclone separators, and then bagged for the customers. These manufacturing activities take place in the Warehouse and Plant building. Bagged product was then either shipped from this building or transferred to the Front Warehouse for storage and later shipment.

Through July 1980, sodium dichromate was added in the Phase A reaction, where gypsum is formed. As a result, gypsum through that time contained chromium (chromium was reportedly allowed at landfills until 1980). Beginning in August 1980 the sodium dichromate was added in the Phase B reaction. The gypsum was disposed of as waste at a landfill.

From 1953 through 1980, chromium-containing gypsum was stockpiled on site, north of the Warehouse and Plant, within either the gypsum storage shed (concrete floor) or directly on the ground (the area was formerly unpaved). Gypsum sludge was collected on the floor inside the plant building (northwest corner), then moved by front-end loader to waste bins outside the plant building [6 - March 12, 1990 General Discharge Permit]. It is likely that gypsum stored on the ground may have remained in lower points on the property, as on-site personnel may not have been consistently diligent to ensure all gypsum was removed for off-site disposal [3a]. In addition, heavy equipment was used to place the gypsum in the north end of the facility, as a result likely tracking the waste throughout the north end of the facility

Through 1982, any wastewater that could no longer be utilized in the process would be treated in the on site wastewater treatment plant. Following treatment, the wastewater would be discharged into the Fox River. After 1982, the facility negotiated with the City of Appleton to discharge wastewater to them (as the wastewater no longer contained chromium). [3c]

The subject property formerly processed dry Quebracho, vegetable tannin, with sodium hydroxide and formic acid, resulting in liquid quebracho. The process consisted of augering the dry quebracho into the northeast cell tank (Tank 5) in the Tank Farm. Sodium hydroxide, water, and dry sodium bisufite were reacted and then the pH was adjusted with formic acid. The resulting, sulfonated liquid quebracho, was also stored in a separate AST in the Tank Farm. Finished product was piped from Tank 5 or the second AST into tank trucks in to the north and northwest of the Plant; this activity was reportedly done on asphalt. No significant spills of the quebracho finished product were known to have occurred; occasional spills of dry quebracho on asphalt paving were known to occur while augering the product into the cell tank.

The subject property also formerly processed lignin liquor, neutralizing the liquor for pH adjustment. No additional processing was performed on the liquor.

Report No. 2000-001.DDR Appleton, WI 8 lll£.1 The Sustainable 'fq/ Co pany

The table below presents information provided by Mr. Jim Cottington, Plant Manager, regarding QC analyses performed on their finished mud additive products [34]. QC analyses were not performed on their animal feed products.

Principal Products Significant Constituents (wt.% dry) Drilling Mud Additives Spersene (Chromium Calcium (0.8), chromium (4.5), sulfur (18-21), lignosulfonate) titanium (0.1), iron (0.2-0.7%) Spersene CF (Chromium Sulfur (23-24), calcium (0.8), titanium (2. 7), iron (0.6) free lignosulfonate) Spersene I (Ferrochrome Chromium (2.6), sulfur (20.5-21.5), calcium (0.8), lignosulfonate) iron (2.5) Animal Feed and Industrial Products Sodium Lignosulfonate Not available (NA) LX-3 Feed (Calcium NA lignosulfonate, CaLS with protein additive) Calcium Lignosulfonate NA Torch CL (CaLS) NA

According to a letter from Mr. Thomas F. Dowse, dated February 5, 1999, M-I conducted analytical testing to identify the sulfate ion concentration in the lignin liquor utilized on site. The testing indicated that total sulfur as sulfate was present as 9.77% of the liquor. Further, water soluble sulfate was present as 0.15% of the liquor product. M-I tested the FLAX Flamsperse desugared calcium lignosulfonate liquor produced by Flambeau Paper Corporation. Mr. Dowse considered these results representative of lignin liquor utilized on site. [35]

3.3 Detailed History of Subject Property by Historical Resource

3.3.1 Sanborn Fire Insurance Maps

1891: The Sanborn map depicts The Manufacturing Investment Company (pulp manufacturer) on site. The site's utilities include: heat supplied by steam, fuel supplied by coal and burning of waste, and power supplied by water. Furthest south, beyond the John Street bridge, is a small building; its use is not indicated. A Power House with five water wheels and two dynamos is located north of the bridge at the southern end of the property. A small storage building is depicted east of the Power House. Another small building is depicted northeast of the Power House.

Report No. 2000-001.DDR Appleton, WI 9 ~\The Sustainable Vco pany

Approximately 125 feet north of the Power House is the rectangular wash and machine room building ("machine room building") equipped with one wet machine and one paper machine, as well as stuff chests (pulp storage). This building is approximately 275 feet long and 125 feet wide. Immediately north of this building are two aboveground water tanks and the Digester Building. An artesian well is depicted between the aboveground water tanks. A conveyor or other delivery system appears to be depicted between the Digester Building and a Saw Mill and Power House building to the north. In the Saw Mill, shafting (method to transmit power or motion) is listed as being done on the first floor, with the mill on the second floor. This Power House includes three water wheels. Further north is the timber yard, and a log carrier extends from the timber yard into the Power House/Saw Mill building.

East of the Saw Mill is another building, its use is not clearly labeled, although a notation indicates that shavings may be stored there. East of the Digester Building are two aboveground acid tanks, their size is not indicated. Approximately 450 feet further east of these acid tanks, are two additional aboveground acid tanks on the river bluff, an acid tower, and two furnace buildings on either side of the acid tower. The Telulah Canal is depicted along the eastern boundary of the property, and the Fox River and canal are depicted to the west.

1895: The Sanborn map depicts The Manufacturing Investment Company on site. The changes noted from the 1891 map are discussed here. A platform over water has been constructed between the southern Power House and machine room building (hereafter called Front Warehouse). The small storage building east of the Power House is no longer present. A storage house building has been constructed on the southern end of the small building depicted northeast of the Power House. Outside the northwest corner of the wash and machine room, a small building housing drainers (storage of washed, bleach rag pulps over a period of days to enable water to drain) is depicted. Three drainers are depicted between the two aboveground water tanks and the machine room puilding. The Digester Building is depicted as housing eight digesters on the 2nd floor and digester bins on the 3rd floor. The building east of the Saw Mill is depicted as having a coal shed along the east end of this building.

1901: The Sanborn map depicts Inter-Lake Pulp and Paper Company pulp mill on site. A small building is depicted on the north end of the property, apparently for storage of logs prior to their placement on the log carrier to the Power House/Saw Mill building. The wash and machine room building is now called the wet machine room and paper pulp warehouse (Front Warehouse). The two furnaces on the far east portion of the property are now identified as sulfur burners. Pulp wood piles are depicted as being located on the north end of the property, along the east boundary of the property (beyond the Telulah Canal), and at the south end of the property, beyond the bridge.

1911: The Sanborn map depicts Inter-Lake Pulp and Paper Company pulp mill on site. The small building depicted on the north end of the property in 1901 is no longer shown. A wheel wright (water wheel) and wood preparing building is depicted abutting the northern Power House to the east. The building located furthest south, beyond the bridge, is no longer depicted.

Report No. 2000-001.DDR Appleton, WI 10 A The Sustainable ~'co pany

1924: The Sanborn map depicts Consolidated Water Power and Paper Company, an Inter-Lake Pulp and Paper Company Division pulp mill on site. The platform between the southern Power House and the wet machine room and paper pulp warehouse is now depicted as a pulp warehouse with a concrete floor (Front Warehouse). The storage house building northeast of the Power House (now east of the Front Warehouse) is now depicted as an office. A long storage building is depicted east of the Front Warehouse. The area north of this building has been modified significantly from that depicted in 1911, as discussed below.

A bleach plant is depicted on the northwest end of the Front Warehouse. North of the bleach plant are three acid tanks and a reclaiming tower. A concrete acid tower is north of the acid tanks, as well as an acid plant building. A sulfur conveyor is depicted extending from the north end of the acid plant building. A "car house" is depicted west of the acid plant. East of the Digester Building is a machine shop building. On the north end of the Digester Building is a chip bin, and depicted extending north from the chip bin to the wood mill building is a conveyor belt.

The northern Power House building is depicted to have expanded by about ¼ of its size, indicating increased production. The storage and coal shed building east of the wood mill also has a slightly altered shape, although it does not appear to have expanded in its footprint significantly. Northeast of the northern Power House is a hot pond for wood storage (where the logs are soaked in hot water to help loosen the bark and wash the dirt off the logs). A cable conveyor is depicted, extending north from the north end of the hot pond to a Saw Mill located 425 feet northeast of the hot pond. Pulp wood storage is depicted surrounding the Saw Mill, as well as to the east beyond Telulah Canal. The area south of the John Street Bridge is not depicted.

1950: The Sanborn map depicts Consolidated Water Power and Paper Company pulp mill on site. East of the wet machine room, a loading shed is depicted. Further east, abutting the loading shed, the ground is depicted as concrete paved in the former location of the long storage building. To the south of the concrete paved area is a water treatment plant. On the north end of Front Warehouse, in place of the Digester Building is a new bleach plant. West of the bleach plant is a washer building, and west of the washer building is a liquor storage building. A lime house is depicted abutting the north end of the liquor building. The acid plant and concrete acid tower is still present, however the acid tanks have been relocated to the east side of the acid plant, and only two tanks are present. Sulfur bins are depicted within the north end of the acid plant building.

North of the acid plant is the new Digester Building. Immediately north of the new Digester Building is a transformer. East of the Digester Building is the building formerly called the storage and coal shed, however is it now identified as the boiler house. A concrete ash hopper is depicted to the south of the coal shed. The coal bin is still depicted on the east end of the building. The northern Power House is no longer present. A Saw Mill is depicted northeast of the wood mill and boiler house. A hot pond is depicted northeast of the Saw Mill. Conveyor belts are depicted between the Saw Mill and the wood mill. North of the Saw Mill is a "pilot plant", unused settling basin, small pump house, and unused concrete settling tank. It is unknown what these structures were used for, and it is unclear if the settling basin was aboveground or in ground.

Report No. 2000-001.DDR Appleton, WI 11 6 1, The Sustainable 'Vr' Co pany

1970: The Sanborn map depicts Consolidated Water Power and Paper Company pulp mill on site. On the far south end of the property, beyond the East John Street Bridge, is a filtration plant consisting of a large concrete settling basin and a concrete building. The bleach plant has been expanded to the north and northeast, extending to the southern corner of the acid plant. A compressor room abuts the east side of the lime house and the north side of the liquor building. The acid plant has been expanded approximately 25 feet to the west. Two sweet liquor tanks (aboveground) are depicted west of the wood mill. An addition has also been constructed onto the north end of the wood mill, consisting of an evaporating plant and a boiler house on the far northern end. A liquor tank is depicted on the south end of the coal bin. A crane house ("Jammer House") is depicted east of the Saw Mill.

To the north of the boiler house is a new warehouse and Barcon plant ("Warehouse and Plant"). The Warehouse and Plant building is located in a former tailrace, which apparently was filled to allow for construction of the new building. Liquor storage tanks are depicted to the north of the Warehouse and Plant. A 15,000-gallon aboveground dichromate tank is depicted in the northern corner between the Warehouse and Plant. A propane tank and pump house are depicted north of the Warehouse Plant.

3.3.2 Historical Aerial Photographs and Postcards

1892: An 1892 postcard depicts the west end of the property, looking from the John Street Bridge. The area appears similar to the 1891 Sanborn map.

1908: A circa 1908 postcard depicts the west end of the property, looking from the John Street Bridge. The area appears similar to the 1911 Sanborn map.

1922: A circa 1922 postcard depicts the west end of the property, looking from the west bank of the Fox River. Th<:;3 area appears similar to the 1911 and 1924 Sanborn maps.1931: A 1931 postcard depicts the west end of the property, looking from the west bank of the Fox River. The area appears similar to the 1924 Sanborn map.

1938: The 1938 aerial photograph appears similar to the 1950 Sanborn map. Due to the resolution of the photograph, greater detail could not be gleaned.

1950: A circa 1950 aerial photograph appears similar to the 1950 Sanborn map. However, a third tank is depicted next to the two acid tanks abutting the acid plant.

1957: The 1957 aerial photograph appears similar to the 1970 Sanborn map. Due to the resolution of the photograph, greater detail could not be gleaned.

1967: The 1967 aerial photograph appears similar to the 1970 Sanborn map. Due to the resolution of the photograph, greater detail could not be gleaned.

1970: A circa 1970 aerial photograph appears similar to the 1970 Sanborn map. However, a small cluster of office or residence buildings are located in the present location

Report No. 2000-001.DDR Appleton, WI 12 .The Sustainable ~,. Co pany . of the Warehouse and Plant. Coal storage is evident in the coal bin located along the boiler house.

1971: The 1971 aerial photograph appears similar to the 1970 Sanborn map. However, the current office building located just below the bridge is depicted. In addition, there appears to be a third tank located next to the two acid tanks depicted in the 1970 Sanborn map just east of the acid plant. It also appears that the current train shed located on the north end of the Warehouse and Plant and the titanyl iron sulfate building are present. The Saw Mill depicted in the 1970 Sanborn map is also no longer present; the current paint shed is depicted.

1979: The 1979 aerial photograph appears similar to the 1971 aerial photograph. However, one additional large aboveground circular tank and two smaller circular aboveground tanks are visible in the wastewater treatment plant located at the south end of the property. In addition, the two 67,000-gallon ASTs are visible on the east boundary of the property.

1980: The 1980 aerial photograph appears similar to the 1979 aerial photograph. However, some kind of structure or possibly a log pile is apparent on the northeast corner of the property, beyond the Warehouse and Plant.

1992 and 1993: These aerial photographs depict the property following the removal of several Consolidated buildings. The improvements that remain are the office building to the south, the Power House, the Front Warehouse building, the Warehouse and Plant and liquor storage building, the Jammer House, the paint shed, the titanyl iron sulfate building, and the boiler house and wood mill. Due to the resolution of the photograph, it is not apparent what ASTs are present on site, although the 67,000-gallon ASTs are visible.

3.3.3 City Directories

1887-1888: Not listed

1891-1897: Manufacturing Investment Company.

1899-1900: The following are identified as being located near the John Street Bridge - Appleton Electric Ry. Company's Power House, Appleton Knitting Company, Wisconsin Tissue Paper Co.

1904: Interlake Pulp and Paper Company

1910: Interlake Pulp and Paper Company (address is 400 John Street)

1919: Interlake Pulp and Paper Company and Chas de Young (address is 400 John Street)

1921: Chas de Young (address is 400 John Street)

Report No. 2000-001.DDR Appleton, WI 13 /l!k1 The Sustainable ~'co pany

1928-1930: Interlake Pulp and Paper Company (address is 1137 E. John Street)

1932-1945: Interlake Pulp and Paper Company (address hereafter is 1130 E. John Street)

1947-1961: Consolidated Water Power & Paper Company

1963: Consolidated Papers, Inc.

1968: Consolidated Paper, Inc. and Interlake Credit Union

1974-1983: Consolidated Papers, Inc.

1984-1985: Dresser Magcobar

1989-1996: M-I Drilling Fluids Company [23]

City directories dated after 1996 were not available at the time of TSCl's visits.

3.3.4 Historical Building Permits

Various building permits were available for the subject property, dated 1949 to the present. The table below summarizes the permits identified for Consolidated for significant building construction or tank installation [15]

Building Permits held by Consolidated Year Description of Permit

1951 permit for a pump house and settling tank constructed of masonry and steel 1951 permit for bleach plant constructed of masonry and steel 1951 permit for evaporator plant building constructed of masonry and steel 1953 permit for Jammer House constructed of masonry 1953 installation of a metal 550-gallon gasoline underground storage tank 1953 building to house sulfur burning equipment 1958 warehouse building constructed of metal 1958 spray drier building constructed of masonry 1965 slasher building (paint shed) 1962 evaporating plant and neutralizing plant constructed of masonry 1962 a building addition

Report No. 2000-001.DDR Appleton, WI 14 A, The Sustainable Vco pany

Building Permits held by Consolidated Year Description of Permit 1965 installation of a 550-gallon gasoline underground tank 1966 addition to the evaporating plant 1966 office building 1973 installation of two 67,000-gallon steel tanks (these are noted to be underground on the permit, however, they are the two aboveground tanks located on the east boundary of the property); 1979 storage addition 1983 raze manufacturing building 1985 raze treatment tank

The following permits for Magcobar Minerals for significant building construction or tank installation were noted: installation of an 18,000-gallon liquid petroleum tank. [15] According to Mr. Tom Dowse, this 18,000-gallon tank was an on-site propane tank that was recommissioned. [38] In addition, a 1993 permit for the razing of a power plant and a 1995 permit for the replacement of a train shed were also noted; the operator of the facilities was not noted on the permits, although the owner was identified as the City of Kaukauna. [15] According to Mr. Dowse, the power plant permit was not for M-I or Magcobar Minerals, but for either Consolidated Papers or City of Kaukauna operations. [38]

3.3.5 Historical Maps

The following historical maps were identified that depicted the subject property.

1867: A map depicting the City of Appleton depicts a paper mill in the general vicinity of the subject property. No additional detail is provided in the map. [24]

1889: An 1889 City of Appleton atlas depicts Richmond Brothers as occupying the subject property. A long rectangular structure is depicted north of the wood bridge, and a small square structure is depicted south of the wood bridge. [17]

1898: An 1898 Outagamie County plat map does not depict improvements on the subject property. [18]

1917: A 1917 atlas map depicts Interlake Paper Company paper mill on the subject property. This atlas map does not provide a great deal of detail, other than providing an outline of the on-site improvements. It appears consistent with the Sanborn maps from 1911 and 1924. [19]

Report No. 2000-001.DDR Appleton, WI 15 ~Tu The Sustainable 'f4i' Co pany

3.3.6 Chain of Title

1899: Oliver Payne sold the property to Interlake Pulp and Paper Company

1921: Interlake Pulp and Paper Company sold the property to Consolidated

1927: GBMC leased the property to Interlake Pulp and Paper company

1951 : G BMC leased the property to Consolidated

1973: GBMC leased the property to the City of Kaukauna

Unrecorded date: GBMC leased the property to Consolidated

Unrecorded date: Consolidated leased the property to Barcon, Inc.

1980: City of Kaukauna leased the property to Consolidated

1985: Consolidated sold the property to the City of Kaukauna [22]

A Sublease Agreement was provided by Mr. Cottington, effective December 10, 1982 to June 30, 1990, between Consolidated Papers, Inc. and sublessee Magcobar Group, Dresser Industries, Inc. The Sublease Agreement discusses that on October 21, 1970, Green Bay and Mississippi Canal Company (lessor) entered into a lease agreement with Consolidated Papers, Inc. (lessee). [36]

3.4 Previous Investigations Conducted by Miller Engineers and Scientists

Beginning in February 1998, Miller Engineers & Scientists performed a number of investigation activities in an effort to understand the condition of the subject property. The following is a list of Miller's reports prepared to date, to TSCl's knowledge:

• March 2, 1998, Preliminary Evaluation and Remedial Investigation Work Plan for Sulfuric Acid and Sodium Bichromate Containment Structure. • June 8, 1998, Status Update. • September 4, 1998, Remediation Status Update. • December 16, 1998, Interim Remedial Investigation Report. • January 25, 1999, Miller Letter to WDNR Regarding Sampling Procedures. • February 16, 1999, Miller Letter to WDNR Regarding Summary of February 16, 1999 Meeting with WDNR. • September 23, 1999, Phase I Environmental Site Assessment of Property Leased by M-1.

Report No. 2000-001.DDR Appleton, WI 16 ~ 1 The Sustainable Vco pany

• September 23, 1999, Interim Remedial Investigation Report No. 2 for March­ August 1999 Investigation Activities. • December 27, 1999, Miller Letter to WDNR Regarding Ownership of Unplatted Lands in Block 56 and July Ground Water Sample Results • January 25, 2000, Remedial Investigation of Property Leased by M-1 LLC. • March 30, 2000, Status Update. • July 19, 2000, Status Update.

The January 25, 2000 letter report summarizes the significant findings of activities performed by Miller to that date. A total of 55 soil borings and 40 groundwater monitoring wells were completed at the property. Miller had focused their investigation on chromium and sulfate contamination, as their efforts were originated in response to an impact that was identified south of the secondary containment structure housing the sodium dichromate and sulfuric acid ASTs. The letter notes that the investigation had been focusing on sources of contamination that M-1 would have potentially contributed to as a direct result of their operations. Miller had evaluated groundwater contamination at three discreet depths (water table several feet below ground surface, groundwater immediately above the soil 0 bedrock interface at 20 feet below the ground surface, and groundwater in the bedrock ranging from 32.5 to 39.5 feet below ground surface). Groundwater flow was found to basically flow toward the Fox River, although flow directions may vary significantly in localized areas. Miller had estimated the horizontal distribution of chromium concentrations in groundwater at the water table and at the soil bedrock interface. This effort indicated that chromium concentrations in groundwater at the water table and soil­ bedrock interface were greatest at the plant and migrate primarily toward the Fox River. Miller believed that chromium contamination in excess of the Enforcement Standard extend onto Telulah Park, north of the property.

Miller's last sampling event did not identify chromium concentrations in excess of the enforcement standard in bedrock groundwater. · Sulfate contamination was found in excess of the Enforcement Standard inside the containment area south of the Warehouse and Plant. Miller postulated that a much larger area of sulfate contamination may exist in the location of the former sulfite pulp mill. Miller did not believe that sulfate contamination in excess of the Enforcement Standard had extended onto Telulah Park. Miller had also estimated the distribution of chromium in soil across various cross sections through the property. Miller found that the highest levels of chromium in soil under the existing sulfuric acid and sodium dichromate tanks. They further found that hexavalent chromium was not detected in samples collected from locations closest to the Telulah Park property line.

The 1999 Phase I found the following sources of chromium contamination: sodium dichromate tank; area near southeast corner of warehouse portion of the Warehouse and Plant building where railcars unloaded sodium dichromate; former location of sodium dichromate tank; chromium containing gypsum stored on the ground surface north of the Warehouse and Plant and tracked around site by heavy equipment; chromium containing particulate matter emitted from the dryer units deposited on the ground and roof surfaces; chromium-containing products stored on site.

Report No. 2000-001.DDR Appleton, WI 17 lfli.:1 The Sustainable ~'Co pany

Miller noted that any releases associated with the storage of chromium-containing gypsum and former sodium dichromate tank were not within the operational control of M-1 as they had not yet taken operational control of the property.

The 1999 Phase I found the following sources of sulfates contamination: sulfuric acid tank located within secondary containment; lignin liquor unloading/loading in the northern train shed; former digester, evaporator, and acid plants associated with Consolidated Papers' operations (sulfur stored on the ground and sulfur based cooking acid used in the digesters); lignin liquor processing operated by Consolidated; lignin liquor and lignosulfonate materials stored at the tank farm north of the Warehouse and Plant; the truck loading station along the west side of the tank farm north of the Warehouse and Plant where liquid quebracho is loaded; coal formerly stored along the east side of the former boiler house; and the titanyl iron sulfate storage tank. Miller notes that M-1 was not associated with the digester, evaporator, or acid plant operations as they were part of the pulp mill.

The 1999 Phase I further found that PCB contamination was possible at the current and former transformer locations, that there was the potential for petroleum hydrocarbon contamination in the areas of petroleum storage, and that potential dioxin, furan, and adsorbable organic halide contamination from the former bleaching operations associated with the pulp mill. Miller notes that several of these sources were generated as part of the pulp mill operations and were not generated by M-l's production of lignosulfonate products.

4.0 Profile of Former Pulp Process Site Operations

The information discussed in this section is based upon TSCl's review of the EPA Pulp and Paper Industry Profile.

4.1 Pulp Production

The initial process of wood handling/debarking and chip washing can be a significant source of effluent water containing solids, BOD, and color. Following preparation of wood for digestion, the digestion effluent and liquor evaporation condensate can be a source of concentrated BOD and reduced sulfur compounds. Pulp screening, thickening, and cleaning white waters can produce large volumes of water with suspended solids and significant BOD. Pulp process operations at the subject property reportedly included recycling of post bleaching wash waters in the bleach plant and pulp screening operations, thereby reducing the effluent generated.

Wood handling/debarking operations were performed at the saw/wood mills located on the north end of the property and central portion of the property (adjacent to the Paint Shed, south of the Telulah Canal inlet). Wood was stored throughout northern portion of the property, on land and within Telulah Canal. Digestion and evaporation activities were conducted in the currently vacant lot between the Front Warehouse and the TIS building. Pulp screening, thickening and cleaning was performed in the northern portion of the Front Warehouse and in out buildings located throughout the currently vacant land north of the Front Warehouse. [14, 25, 30, 31)

Report No. 2000-001.DDR Appleton, WI 18 /l!i:;.; The Sustainable ~l'co pany

Common air pollutants from pulp production included fly ash from on-site coal-fired boilers and sulfur oxides from the pulp mill operations. Volatile organic compound emissions were also common from chip digesters and liquor evaporation.

4.2 Bleach Plant

Dioxins, furans, and adsorbable organic halides (chlorinated organic compounds) are typically associated with bleached chemical pulp. The chlorination/extraction sequence of the pulp bleaching process is the primary source of these contaminants.

At the subject property, these contaminants may be found in the area of the former bleaching operations associated with Consolidated's operations. Two former bleach plants were identified, abutting the northwest and northeast corners of the Warehouse Building. The bleach plant located on the northwest corner was the first plant, present as early as 1924, and was replaced by the other bleach plant by as early as 1950. [14, 26, 30]

4.3 Residual Wastes

Significant waste streams from pulp mill operations would have included bark, wastewater treatment sludges, lime mud, lime slaker grits, liquor, liquor dregs, boiler and furnace ash, scrubber sludges, and wood processing residuals. Due to the tendency of chlorinated organic compounds (including dioxins) to partition from effluent to solids, wastewater treatment sludge likely contained such compounds. The on site wastewater treatment system consisted of an aeration tank, clarifier, thickener for the clarifier, and stabilization tank. Wastewater was apparently discharged to the Telulah Canal. The remaining wastes were reportedly sent to the municipal landfill or discharged directly to the Fox River or Telulah Canal (e.g. scrubber sludges). [3, 14, 26, 31]

5.0 Aboveground Storage Tanks

This section provides an inventory of known ASTs at the subject property. Releases associated with the ASTs are discussed in Section 8.0. This does not include a discussion of process batch tanks located within the Warehouse and Plant building. For a detailed listing of equipment utilized by M-1, refer to Appendix J.

5.1 ASTs utilized by Non-M-1 Occupants

One large concrete settling AST was housed in the southern end of the property (south of the College Avenue Bridge overpass) as part of the on-site wastewater filtration plant. The filtration plant was later converted to a wastewater treatment plant, which consisted of approximately three large ASTs, as well one smaller AST for ammonia storage. The wastewater treatment plant also accepted wastewater from M-1 operations. [3b, 14, 37]

An approximately 500-gallon AST is housed within the southeast corner of the machine and warehouse building. This AST is reportedly empty (formerly housed gasoline) and is owned by the City of Kaukauna. [2, 3a]

Report No. 2000-001.DDR Appleton, WI 19 lf!k,: The Sustainable 'f/il Co pany

Two acid ASTs were located east of the former Digester Building [14 - 1891 Sanborn]. These were removed/moved sometime prior to 1924 [14 - 1924 Sanborn].

Three acid ASTs were located north of the bleach plant in 1924. Two acid ASTs were present on site in 1950, on the east side of the acid plant [14 - 1950 Sanborn].

A liquor AST was housed in the south end of the coal bin in 1970. Two liquor ASTs were housed in 1970 west of the wood mill. [14 - 1970 Sanborn].

5.2 ASTs Utilized by Barcon, Dresser Magcobar and M-1

A 30,000-gallon titanium iron sulfate (TIS) AST (fiberglass construction) is housed within the TIS building. An underground culvert most recently served as a pipe chase for piping, transporting the TIS to the plant building; however, overhead pipes were previously utilized to deliver the material. [3a] TIS was delivered to the AST by tank truck approximately 20 feet from the door to the TIS building. [3d] At the time of TSCl's site visits, the AST was being utilized to house wastewater prior to off-site disposal or release into the City sewer system, as applicable.

Two 67,000-gallon diesel fuel oil ASTs (steel construction) were located on the east side of the property within a concrete containment vault. These ASTs were installed in approximately 1973, according to building permits. According to Mr. Stein, M-1 used the north AST for No. 2 fuel oil storage for a period of one to two years. The south AST was temporarily used by M-1 for unprocessed lignin storage, also for a period of one to two years. M-1 ceased using the ASTs when a leak was discovered approximately 10 years ago in the piping extending from the ASTs, south of the Jammer House. Mr. Cottington indicated that these ASTs were removed in the Fall 1999. They were reportedly cleaned prior to their removal by US Oil Company. Mr. Cottington did not believe that an assessment was conducted of the tank area in association with their removal. TSCI was provided with an August 17, 1995 letter from the City of Appleton Fire Department discussing a recent inspection at the subject property, indicating that they understood one of the two abandoned 67,000-gallon ASTs had not been cleaned. The Fire Department requested that the AST be cleaned.

Two ASTs were located within a concrete construction secondary containment area, located south of the Warehouse and Plant. The 30,000-gallon AST (carbon steel) housed sodium dichromate and the other 15,000-gallon AST (carbon steel) housed sulfuric acid. Piping from these ASTs ran aboveground into the adjoining plant building. These ASTs were removed from service July 6, 2000 and placed on the vacant lot located south of the Jammer House. M-1 cleaned the ASTs out prior to their removal by Dawes Crane. The sodium dichromate AST was filled by rail car and tank cars or trucks at the southeast corner of the Warehouse and Plant building.

The sulfuric acid AST was filled at the southeast corner of the Warehouse and Plant building prior to 1982 by rail car via the adjacent rail spur located on the east side of the Plant Building. The rail car utilized a fill port located near the southeast corner of the building, connecting to the AST through a hose that extended along the top of the exterior south wall of the Plant Building to the AST. After 1982, the AST was normally filled from

Report No. 2000-001.DDR Appleton, WI 20 ~ 1 The Sustainable Vco pany tank trucks, which would fill the AST via a hose connected directly from the truck to piping from the tank to the secondary containment wall. [3d] Product piping from this AST ran aboveground into the adjoining warehouse and plant building. [3a, 3c]

Formerly, an approximately 15,000-gallon AST was utilized for sodium dichromate storage, which was replaced at some point due to production demands for a larger tank. The AST was located in the current northwest corner of the Plant. The installation date of this AST is unknown, but was depicted on plant drawings as early as 1958 (as "chemical #2 storage" tank). The date of the tank's removal is unknown, however a "chemical #2 storage" tank is depicted on the south side of the Warehouse (approximately in the location of the current secondary containment storage area), but its capacity is not listed. It is unknown how the former 15,000-gallon sodium dichromate tank was filled; a rail line is located adjacent to the former location of this AST. Following its replacement with the 30,000-gallon AST, the AST was moved for storage, and its last known storage location was along the river in the vegetated area, northwest of the propane tank. The tank was stored horizontally, on two wooden support beams, just off the ground. No other storage locations have been identified for the AST. [3a, 3c]

A 560-gallon AST (steel) is housed within the paint shed. It is housed within secondary containment and was formerly used to house diesel fuel. The AST has been emptied except for approximately two inches of residual product left in the bottom of the tank. [3a]

During TSCl's initial visit to the subject property, a plastic 275-gallon waste oil AST was observed within the Jammer House.

A Tank Farm, consisting of eight approximately 30,000-gallon tanks, is located north of the Warehouse and Plant. Tanks 001, 002, 003, and 006, are concrete cell tanks housing lignin liquor. An additional approximately 14,000-gallon tank houses lignin, located in the center of two rows of cell tanks in the Tank Farm. An additional 14,000-gallon tank in the center row houses quebracho. In the north row of concrete cell tanks, the northeast cell tank (Tank 005) houses quebracho and the northwest tank (Tank 007) houses process wastewater.

An 18,000-gallon liquid propane AST is housed north of the Warehouse and Plant.

A 7,000-gallon hydrogen peroxide AST (aluminum, skid mounted) was housed north of the Warehouse and Plant. This AST was removed in June 2000. The AST was reportedly installed in approximately 197 4/1975. The hydrogen peroxide was needed when the facility began producing chromium-free drilling mud additives. The AST was initially leased from Dupont and was later purchased by M-1.

A former Phase B reactor tank, part of the drilling mud additive production process, was removed from service in 1996 and was observed onsite by TSCI, stored north of the propane tank. [3c]

Report No. 2000-001.DDR Appleton, WI 21 Sustainable pany

6.0 Underground Storage Tanks

Two 52,000-gallon concrete USTs were utilized onsite, southeast of the Warehouse and Plant. These reportedly stored No. 6 fuel oil and supplied the boilers for Consolidated's operations. The USTs were reportedly emptied, pressure washed, filled with cement slurry, and abandoned in place in approximately 1986. The abandonment of the USTs was observed by Mr. Donald Stein, Maintenance Manager. Manhole covers were observed by TSCI on site, which indicates the centerline of the two USTs. Mr. Stein further stated that there was a channel built around the outside of the USTs, designed to catch any spills from the tanks. It was located approximately 15 feet bgs. Mr. Stein stated that the channel was filled with mud during the abandonment. These USTs were listed as being owned by Consolidated Papers, Inc. [1 O] The product within the USTs was transferred to drums until used. According to Mr. Stein, these USTs were not utilized by Barcon/M-1. [1, 2, 3c, 1O]

One 500-gallon diesel steel UST was formerly located on-site, east of the Warehouse and Plant. This UST was reportedly removed in approximately 1982 [3c]. This tank was listed as being owned by Consolidated Papers, Inc. and was installed between 1953 and 1965. [10, 15]

One 500-gallon gasoline steel UST was formerly located on-site, east of the Warehouse and Plant. This UST was reportedly removed sometime prior to 1982 [3c]. This tank was listed as being owned by Consolidated Papers, Inc. and was installed between 1953 and 1965. [10, 15]

7.0 Hazardous Waste Generation

Consolidated Papers, Inc. was a registered generator of hazardous waste (WID006126072). Consolidated Papers, Inc. requested that they no longer be identified as a hazardous waste generator due to closure of their facility in 1982.

Liquid chromium waste (process and runoff wastewater) generated by M-l's operations is transported by Superior Special Services and is sent for disposal to the Superior Special Services facility in Port Washington, Wisconsin.

8.0 Known Spills and Releases

Reportedly the former sodium dichromate tank located immediately north of the Warehouse and Plant used to leak due to faulty pumps. The area was not contained; as a result any leaked material would spill directly onto the ground surface. Specific information regarding the amount of product that leaked or the timeframe that the leaks occurred was not available due to the historic nature of the releases. [3a]

Reportedly a spill of sulfuric acid occurred in the early 1970s. At that time, there was no containment area enclosing the AST. The ground was reportedly saturated. Lime was placed on the spill area to neutralize the acid. A bobcat was utilized to move the dirt around; no additional activities were conducted to cleanup the spill. [3b]

Report No. 2000-001.DDR Appleton, WI 22 I ~;; The Sustainable 'U1 Co pany

TSCI spoke with Mr. Stein, to further our understanding of the releases in the area of the former secondary containment area abutting the Warehouse building in the period around 1984. According to Mr. Stein, in approximately 1983, an environmental audit (included the placement of soil borings and the collection of soil samples) was conducted which identified impacted soil immediately south of the secondary containment area. Mr. Stein noted that the area within the secondary containment area was not addressed because the containment was recently constructed (August 1983) and it was not desired to disturb the integrity of the new structure. As a result of this audit, soils south of the containment area were excavated; no known spill was being addressed during this soil excavation activity (this is discussed further below). [3c]

Mr. Stein reported that a release occurred from the pump of the sodium dichromate tank stored within the containment structure in 1985. The released sodium dichromate was accumulated to a depth of approximately 4-5 inches, contained within the containment structure. The sodium dichromate was pumped from within the structure back into the tank. No additional investigation was conducted to determine if there was any impact to the surrounding subsurface. Mr. Stein noted that the concrete and associated structural joints were not sealed during initial construction. As a result, it is possible that sodium dichromate may have leaked through the containment structure to the surrounding soil. [3c]A Sodium Bichromate Cleanup Report and Disposal Plan was prepared for Barcon, Inc. in 1984, in accordance with the Remedial Action Plan for Sodium Bichromate Cleanup at the Barcon, Inc. Site in Appleton, Wisconsin submitted by Consolidated Papers, Inc. and Dresser Industries, Inc. and the conditional approval letter by the WDNR dated June 19, 1984. The originally proposed excavation area consisted of a 16 foot by 20 foot area immediately south and abutting the secondary containment storage area. As specified in the approval letter by the WDNR, this area was extended to the east and north, following along the exterior perimeter of the secondary containment walled area (see Figure 2). The contamination was identified during an environmental audit, which included the placement of soil borings and the collection of soil samples. This audit was conducted upon Dresser Industries, lnc.'s purchase of Consolidated Papers, Inc. 50% ownership of the capital stock of Barcon. The cleanup consisted of excavating the contaminated soils and removing these soils for off-site disposal.

During excavation in the original excavation area, a white plastic pipe approximately 8" in diameter was discovered on the north side of the excavation pit at a depth of 10 feet. This pipe was reportedly removed and a small amount of yellowish material was observed around and within the plastic pipe. The depth of the initial excavation in this area was 15 feet as proposed. The excavation was continued on the northeast side into the extended excavation area to a depth of 10 feet. A manhole was discovered in this area at a depth of 2 feet below ground surface. The manhole was constructed of concrete block, was approximately 8 feet deep and was filled approximately 2/3 full with brown colored liquid. The manhole was destroyed during the excavation and the liquid in the manhole flowed into the excavation pit. The white plastic pipe mentioned above was connected to this manhole. In addition, an old disconnected 6 inch gas line extending from the old boiler house to the gas island (presumably for the two 52,000-gallon USTs) was uncovered. An 8-inch iron sleeve enclosed the gas line. The gas line and sleeve were cut and removed, resulting in approximately 20 gallons of yellow liquid flowing out of the sleeve into the excavation. Analytical results of samples collected from the liquid in the manhole and the

Report No. 2000-001.DDR Appleton, WI 23 ,/J1,, The Sustainable "Ill Co pany sleeve indicated high concentrations of total chromium (425 mg/I and 12,300 mg/I respectively), as well as 106 mg/I of total chromium in the excavation pit groundwater. Approximately 12 inches of contaminated water remained in the excavated area.

Confirmatory soil samples, which were analyzed for total and hexavalent chromium, were collected from the west side of the originally proposed excavation area and from the east side of the extended excavation area, as well as the base of the extended area. In addition, a sample was collected of the contaminated water from the excavation and tested for total chromium. The analytical results indicated the presence of chromium in both excavation areas, as a result, the excavations continued to ensure removal of all chromium impacted soil. Prior to resuming the excavation work, the impacted water was pumped out of the pit and stored in an on-site storage tank.

The original excavation area was further excavated to a depth of 21 feet due to its exposure to the impacted water. The depth of the extended area excavation was increased to 13 ½ feet; concrete footings were encountered at this depth, which prevented further vertical excavation. The base of the extended area was resampled to determine if further excavation was necessary; analytical results indicated non-detectable levels of total and hexavalent chromium.

The excavation pit was backfilled with WDNR approval with pit run (fine-grained soil). The excavated soils were mixed and three composite samples were collected from the stockpiled soil. Two laboratories were utilized for the analysis (an internal Consolidated Papers, Inc. laboratory and Badger Labs), which indicated total chromium to exist within the collected samples at or below 2.60 mg/L. The soil was determined to be non­ hazardous, therefore the only treatment required prior to disposal was to add lime to the pile to neutralize the soil. Approximately 700 pounds of lime were added and mixed in with an endloader, resulting in a pH of approximately 9.5. The stockpiled soil was stored on an asphalt-paved surface, covered with tarp held in place by wooden pallets, prior to removal for disposal. The stockpiled soils were removed for disposal at Consolidated Papers, Inc. Wisconsin River Division landfill in Linwood, Wisconsin. [11]A leak occurred from underground piping of the two 67,000-gallon ASTs. The section of piping that experienced a leak extended south of the Jammer House. The leak was not immediately noticed as it apparently occurred over a weekend, and on-site personnel estimated that approximately 300 to 800 gallons were released. The release reportedly impacted the Telulah Canal, and this was visibly apparent due to the presence of a sheen on the water. It should be noted that reportedly the underground piping in the area of the release was left in place. [3c, 3d] It should also be noted that during one of her visits to the subject property, Ms. Huffman identified visibly stained soil and petroleum odors below the transfer piping connection to the former ASTs. Ms. Huffman could not visually verify if the tank area was floored with concrete or was simply on the soil surface due to the presence of soil, weeds, and thick brush. [8 - March 17, 2000 memo] Facility personnel had felt that staining was likely due to oily filters inadvertently placed on the ground in that area. [3a]

Reportedly, holes have been drilled in the floor of the warehouse portion of the Warehouse and Plant to drain rainwater out of the warehouse area into the ground. It is unclear when this occurred.

Report No. 2000-001.DDR Appleton, WI 24 A,The Sustainable ~ Co pany

These holes were reportedly approximately 5/8-inch to ¼-inch in diameter and apparently plugged up by spilled product or other debris soon after they were drilled. Mr. Cottington and Mr. Stein attempted to locate the drains but were unable to locate them due to the presence of dried product on the floor of the warehouse. [3a, 3d]

In approximately 1996/1997, the first floor trench drain pipe in the Plant (which collects process water including chromium and sulfates contaminated water from interior operations as well as exterior trench drains collecting runoff) reportedly had worn down through corrosion, resulting in wastewater collected through that pipe to settle into the ground for an unknown period (few to several months). It was unknown to plant personnel that the pipe was inoperable until they noted that the sewer sump pump was collecting rocks and debris. Soon after their identification of the problem, a new section of PVC pipe was installed within the trench drain. Reportedly, the surrounding area was not dug up to ascertain how much of the subsurface had been affected by the wastewater, although it was noted that the area of the trench drain surrounding the pipe was rotted down to approximately three feet as a result of receiving the process water .. [3c]

A sulfuric acid line ruptured on the north side of the Warehouse and Plant building, just above the 3rd floor fire door in September 1997. Mr. Arnold Van Hammond, Process Operator, noticed that acid was not coming through the line, and found the rupture in the line. Acid reportedly spilled out onto the north wall of the Plant and onto the paved area below. [3e]

According to Fire Department inspection records, during a routine inspection, a leak was noted from the sulfuric acid tank pump on April 3, 1997. According to Mr. Stein, the base of the tank pump was lined with limestone, thereby neutralizing any acid that spilled from the pump, minimizing the potential for the release to extend beyond the containment area. The Hazardous Materials team reportedly responded and WDNR was notified and took the lead on the case. No additional documentation regarding this leak was identified. [3d, 9 - April 3, 1997 inspection report]

Chromium contamination was identified in soil samples collected under the management of Miller Engineers in January 1998. The Substance Release Notification Form does not indicate where the samples were collected or what the actual results were. [8 - January 1998 State of Wisconsin Substance Release Notification Form]

A release was discovered on July 3, 1999 into the Fox River of a discharge of black material in the area near the liquid propane tank. The material was determined to be lignin, by Mr. Stein and Mr. Van Hammond (both employees called to the site by the Environmental Wardens). There were two sources that appeared to have contributed to the release. The first source of the lignin appeared to be from a roof drain that normally is directed through a floor drain in the roof to flow into the plant for reuse in the plant operations, but had been directed to flow into the cooling water weir, which discharges to the Fox River. The second source appeared to be surface water flow resulting from the heavy rains from the northern train shed area into the Fox River. [8 - July 3, 1999 memos]

On March 28, 2000, the facility experienced a release of 40 to 60 gallons of titanyl iron sulfate solution from their 30,000-gallon AST. The building formerly had two working

Report No. 2000-001.DDR Appleton, WI 25 6 1 The Sustainable ~lco pany drains leading to the Fox River, which were sealed with concrete some time ago. In March 2000 it was found that one of the drains had not been properly sealed and an erosion failure of a coupling connection resulted in the release. However, that drain was subsequently promptly sealed "water tight" with concrete. The majority of the fluid was contained within the building and housed in 50-gallon plastic drums, however, approximately 40 to 60 gallons were accidentally discharged to the Fox River. [6 - March 30, 2000 letter]

9.0 Wastewater Management

Consolidated operated a wastewater filtration plant at the south end of the subject property since at least 1970 through 1982. The filtration plant consisted of a single concrete aboveground settling tank. [3, 14] The filtration plant was reportedly converted to a wastewater treatment plant in approximately 1976 as a result of new regulations by the WDNR. [3d] The on site wastewater treatment plant consisted of an aeration tank, clarifier, thickener for the clarifier, and stabilization tank. [14] Wastewater from the plant was apparently discharged to the Telulah Canal. [3d, 14]

Through 1982, any wastewater generated by Barcon would be treated in the on site wastewater treatment plant. Following treatment, the wastewater would be discharge into the Fox River. In 1982, the facility negotiated with the City of Appleton to discharge wastewater to them (as the wastewater no longer contained chromium). [3c]

Prior to the construction of the wastewater filtration and treatment plants, wastewater generated by Barcon would be discharged directly into the Fox River through a single outfall located west of the Plant and Warehouse building.

It was further stated by Mr. Stein that in approximately 1976, sewers located within the subject property buildings that discharged to the Fox River or Telulah Canal were closed, with the exception of the Jammer House drains which would discharge into the T elulah Canal. [3d]

Historically, drains within the Warehouse and Plant and Front Warehouse buildings discharged to the Fox River. The drains within the Warehouse and Plant were plugged to end discharge to the Fox River following M-l's occupation of the property. The collected water was discharged into the sanitary sewer, however, the collected water is currently housed in the Titanyl Iron Sulfate (TIS) aboveground storage tank (AST), sampled for chromium content and then handled as appropriate (transported off-site for disposal if hazardous or discharged to the sanitary sewer). [3a]

The Warehouse and Plant building is equipped with an interior trench drain system which collects wastewater generated by Plant operations. The trench drain system also collects runoff from exterior trenches located along the Tank Farm and north side of the Plant. The trench drain system exits the Plant through the City Pit, where the wastewater (discharged to the City of Appleton sewer system) undergoes pH adjustment (5.5 pH required on discharges); no additional treatment is performed on the wastewater. Since 1982, the Plant reused their process wastewater during drying operations to limit the generation of wastewater.

Report No. 2000-001.DDR Appleton, WI 26 A 1 The Sustainable ~'co pany

Prior to installation of a collection trench beneath the two train shed unloading areas, any spilled material accumulated on the ground surface. The west train shed was formerly unpaved; any spilled material would seep directly into the ground. It was reportedly common practice to lay the connecting hose on the ground before turning off the valve, resulting in lignin liquor to deposit onto the ground surface. During Consolidated operations on-site pipe fitters were responsible for this task. Lignin is reportedly the primary raw material delivered in the north train shed. However, in the 1950s when the sodium dichromate tank was located in that area of the property, this material was delivered in the north train shed. [3a]

On July 9, 1993, Mr. Michael Reif, WDNR Wastewater Department, conducted a visit to the property based upon a complaint that lignin material was being discharged into the Fox River. Mr. Reif observed that waste lignin material was being stored on the ground along the plant adjacent to the Fox River. Mr. Reif observed that the stormwater being collected in a storm drain was being discharged to the waste lignin storage area, and this stormwater with waste lignin material was discharged to the Fox River. Mr. Reif estimated that stormwater was being discharged at a rate of 50,000 gallons per day. Mr. Reif sampled the discharge as it entered the Fox River. He informed Mr. Byron St. Louis, Former Plant Manager, that the discharge was not permitted and that he would formally request a solution to remedy the situation (notice of violation).

Cooling water is discharged to the Fox River via a storm sewer manhole located along the railcar unloading area by the Fox River. The cooling water is generated to cool vacuum pumps and fluid drives (to drive the pumps that pump product throughout the plant). [6 - 11/17/93 memo]

A March 28, 2000 letter from Ms. Cheryl Bougie, Stormwater Specialist of the WDNR, discusses that several of the analytical results provided with the Storm Water Chemical Analysis Report, Quarterly Visual Reports and Annual Facility Site Compliance Inspection Report were above the unenforceable EPA Benchmark Values, including BOD5, Total Fe, and Total Suspended Solids. [7 - March 28, 2000 letter] The facility has been issued a WPDES General Permit No. Wl-004938-4 for non-contact cooling water or condensate and boiler water, dated November 9, 1999. The permit set limits for Temperature Eligibility Values (TEVs), pH, and total suspended solids, as well as requiring quarterly sampling and annual reporting of those sampling events. [12]

The facility was issued an Industrial User Permit No. 98-11, which covers the discharge of wastewater from the facility into the city sewer system. The permit will expire May 31, 2001. One outfall (Outfall 001) is permitted, which consists of process wastes that enter manhole 1-17 near the former Newberry Street, located along the east border of the subject property. The effluent limitations include daily maximums of 7.0-mg/l total chromium and 4.5-mg/l hexavalent chromium. The facility is required to conduct sampling at least once a year for metals, with the exception of total and hexavalent chromium, which must be sampled for twice a year. Biochemical oxygen demand (BOD) and total suspended solids (TSS) must be sampled for five days per quarter. Flow and pH are required to be continuously logged with a flow meter. Reporting must be completed by July 15 and January 15 of every year to document the preceding sampling periods. [13]

Report No. 2000-001.DDR Appleton, WI 27 A The Sustainable "fll Co pany

In October 1993, the railway and surrounding asphalt were replaced, north of the Warehouse and Plant. This improvement was made in order to direct stormwater or spills during rail car unloading into the facility's lignin recycling pit, located east of the Warehouse and Plant. Stormwater channels were installed adjacent to the tank car unloading area and along the south truck/rail car shed, which feed into the lignin recycling pit. Mr. Reif felt that these improvements would limit the potential for lignin contaminated wastewater to combine with their cooling water discharge to the Fox River. He observed that a new city stormwater sewer system had been installed in this area (4" diameter pipes), which would also assist in curtailing the potential for lignin contaminated wastewater to runoff to the Fox River due to overflowing pipes. [6]

During a visit by Mr. Reif to the subject property in September 1994, he observed that runoff containing waste lignin had entered the Fox River (based upon his observation of black stained areas, about 1 to 2 feet in diameter) from the area of the waste lignin storage and transfer area. Mr. Reif informed Mr. St. Louis that this runoff was an unpermitted discharge and that this area needed to be quickly upgraded to prevent this from occurring again. The upgrade would consist of additional asphalt to better direct the runoff onto their property. The facility was issued a Notice of Violation on October 18, 1994. [6 - 9-27-94 memo]

Mr. Reif visited the property in August and November 1994, and confirmed that the stormwater issues in the areas north and west of the Warehouse and Plant had been addressed. He felt that the stormwater controls appeared to work well and contained contaminated wastewater to the facility. He observed the waste lignin bins immediately west of the plant to be housed within a containment area with two-foot high walls. He further noted that the effluent from the nearby Fox River outfall (001) appeared to be clear. He noted that the blacktop sloping to contain runoff between the waste lignin storage area and the railroad tracks and the sloping to redirect runoff near the east transfer area was complete. In addition, conveyors were installed to directly transfer the waste lignin into the waste bins. [6 - 8-26-94 and 11-28-94 memos] The facility was issued a letter in December 1995 indicating that the facility was in compliance with the Wisconsin statutes.

A February 21, 1994 proposal to M-1 and several subsequent invoices document the repavement of the area immediately north and east (east of unloading rail spur and under canopy) of the plant building and in the west train shed, as described to TSCI previously by M-1 personnel.

10.0 Solid Waste Management

Documentation regarding Consolidated Papers, Inc. generation of Barcon liquor storage tank sludge and stabilization tank sludge indicate these were non-hazardous wastes. Single samples collected from both sludge types indicate low levels of heavy metals, including chromium (0.49 mg/I in the Barcon liquor storage tank sample and 3.98 mg/I in the stabilization tank sample). The documentation indicated that the waste could be accepted at the Outagamie County Landfill, although at that time (July 1981 ), that landfill was not accepting new wastes in anticipation of a future expansion.

Report No. 2000-001.DDR Appleton, WI 28 ~ 1 The Sustainable ~'co pany

Consolidated Papers, Inc. was directed to contact Winnebago County Landfill for disposal for the time being. Consolidated had requested to have disposal activities conducted 2 to 4 times yearly. [11, - July 1981 letters]

Fly ash generated by the subject property during sulfite pulp operations would be disposed of at the Outagamie County Landfill, MacVille, or Menasha landfills.

Prior to 1998, solid waste was handled by the Outagamie County Public Works Department, which would transport the waste to the Outagamie County Landfill, including gypsum waste prior to 1981. Beginning June 1998, Waste Management began handling the subject property's waste, which would transfer the waste to one of their landfills (White Law or Ridgeview). [3a, 3c]

11.0 Air Permits

The facility holds an Air Pollution Control Operation Permit (445011600-P01 ), dated June 26, 2000. Permitted sources include the three spray dryers with wet scrubbers (installed in 1958, 1960, and 1962) and the York Shipley natural gas boiler installed in 1983.

12.0 Chemical Reporting

Per the Wisconsin Department of Natural Resources Toxic Release Inventory Program, the subject property reported discharges or emissions of the following chemicals 1987 through 1998: sodium hydroxide (air, 1987 and 1988 only); sulfuric acid (air); and chromium (air, water, and off-site disposal). [4]

Per the Wisconsin Tier Two Emergency and Hazardous Chemical Inventory, the subject property reported storing the following chemicals from 1987 through 1999: calcium lignosulfonate, chrome free (titanium) lignosulfonate, chrome lignosulfonate, ferrochrome lignosulfonate, tannic acid, ferric sulfate, sodium dichromate, sodium bisulfate, sodium hydroxide, lime, sulfuric acid, titanium sulfate, zirconium orthosulfate, aluminum stearate, hydrogen peroxide, gasoline, diesel fuel, propane liquid, formic acid, condensed tannin, collagen hydrolysate (1992, 1993), dry chrome humate (1987, 1988, 1989, 1990), soil humic acid (1988, 1989, 1990), soy bean oil (1987, 1988, 1989), defoamer (1987, 1989), sulfonated iron humate (1989), and sulfonated humate (1989). [5]

13.0 Off-Site Properties of Concern

No CERCLIS sites are located within ½-mile of the subject property. No other sites of concern were identified within the EDR database report or during TSCl's visual reconnaissance .of the surrounding area. [20] lt should be noted that the Lower Fox River is a proposed NPL site. The contaminant of concern is PCB, generated through the production and recycling of carbonless copy paper from 1954 to 1988.

Report No. 2000-001.DDR Appleton, WI 29 ~ The Sustainable Vco pany

The PRPs are known collectively as the Fox River Group and consist of the following companies: Fort Howard Corporation, NCR Corporation, Appleton Papers, Inc., P.H. Glatfelter Company, Riverside Paper Corporation, U.S. Paper Mills Corporation, and Wisconsin Tissue Mills, Inc. These seven companies signed a $1 0 million agreement with the state in January 1997 that allowed for a demonstration cleanup project in the fall of 1998 at one of the most contaminated PCB deposits in the river near the DePere Dam, acquisition of a wetland near Green Bay, and improvements to the 1,000 Island Environmental Center in Kaukauna. [21]

14.0 Other Site Observations

TSCI noted the interior flooring of the old machine room building and the Warehouse and Plant to be in very poor condition. Concrete etching and dark staining was evident throughout the facilities. Reportedly, the concrete floor has undergone patching in various areas where corrosion was significant. [3c]

15.0 Summary of Findings

The following is a summary of our findings, based upon this due diligence investigation.

15.1 Chromium Impact

This section discusses the areas of potential impact by chromium-containing products or wastes resulting from Barcon, M-1 Drilling Fluids, and M-1 LLC.

Sodium dichromate ASTs: A 30,000-gal AST was present south of the M-1 plant, until it was removed from service July 6, 2000. This AST was filled primarily by rail cars, which sat at the end of the rail spur extending along the east end of the Plant Building. The fill port for this AST was formerly located at the southeast corner of the Plant Building, but was later relocated to the east edge of the secondary containment wall. Aboveground hoses connected from the fill ports to the AST. Trucks were also utilized for transport of sodium dichromate, which would utilize the fill ports discussed above.

Mr. Stein reported that a release occurred from the pump of the sodium dichromate tank stored within the containment structure in 1985. The released sodium dichromate accumulated to a depth of approximately 4-5 inches, contained within the containment structure. The sodium dichromate was pumped from within the structure back into the tank. No additional investigation was conducted to determine if there was any impact to the surrounding subsurface. Mr. Stein noted that the concrete and associated structural joints were not sealed during initial construction. As a result, it is possible that sodium dichromate may have leaked through the containment structure to the surrounding soil.

Excavation of an impacted area was discussed in the Sodium Bichromate Cleanup Report and Disposal Plan prepared for Barcon, Inc. in 1984. This Plan was developed in accordance with the Remedial Action Plan for Sodium Bichromate Cleanup at the Barcon, Inc. Site in Appleton, Wisconsin submitted by Consolidated Papers, Inc. and Dresser Industries, Inc.

Report No. 2000-001.DDR Appleton, WI 30 /Ji.), The Sustainable Vco pany

The cleanup consisted of excavating the contaminated soils and removing these soils for off-site disposal. The area of the excavation was located immediately south of the secondary containment storage area abutting the M-1 warehouse and north of the former oil boiler house (now removed).

Results from the final round of confirmatory sampling revealed non-detectable levels of total and hexavalent chromium. Accumulated groundwater was pumped into an on-site storage tank. The excavation pit was backfilled with WDNR approval with pit run (fine­ grained soil). The excavated soils were mixed and three composite samples were collected from the stockpiled soil. Two laboratories were utilized for the analysis (an internal Consolidated Papers, Inc. laboratory and Badger Labs), which indicated total chromium to exist within the collected samples at 2.60 mg/I or below. The soil was determined to be non-hazardous, therefore the only treatment required prior to disposal was to add lime to the pile to neutralize the soil.

Barcon formerly utilized an approximately 15,000-gallon AST for sodium dichromate storage that was replaced at some point due to production demands for a larger tank. The AST was located in the current northwest corner of the Plant (the area of the AST was formerly not part of a building). Sodium dichromate was likely delivered to this AST via the northernmost train tracks, and unloaded in the area of the current northern train shed. Reportedly this AST used to leak due to faulty valves/fittings. The area was not contained; as a result any leaked material would have spilled directly onto the ground surface. Following its replacement with the 30,000-gallon AST, the AST was moved for storage, and its last known storage location was along the river in the vegetated area, northwest of the propane tank. The tank was stored horizontally, on two wooden support beams, just off the ground. No other storage locations have been identified for the AST.

Gypsum storage: Barcon generated gypsum which was chromium containing through July 1980. From 1953 through 1980, this gypsum was stockpiled on site by Barcon, north of the Barcon plant (extending to where the train tracks intersect), within either the gypsum storage shed (concrete floor) or directly on the ground (the area was formerly unpaved). Gypsum sludge was collected on the floor inside the plant building (northwest corner), then moved by front-end loader to waste bins outside the plant building. It is likely that gypsum stored on the ground may have remained in lower points on the property, as on­ site personnel may not have been consistently diligent to ensure all gypsum was removed for off-site disposal. In addition, heavy equipment was used to place the gypsum in the north end of the facility, as a result likely tracking the waste throughout the north end of the facility.

Air emissions: Chromium has been discharged through air emIssIons from plant operations by Barcon and M-1, which likely settled on the roof of the M-1 warehouse and plant, the adjoining tank farm, and the surrounding land surfaces. At this time it is not known specifically where it would have been likely for the emitted chromium to settle.

General production activities: Chromium utilized in the Barcon and M-1 production activities is likely present throughout the Plant. In addition, chromium is present in the finished product, which is stored in the Warehouse and Front Warehouse.

Report No. 2000-001.DDR Appleton, WI 31 ~ 1 The Sustainable Vco pany

Wastewater: Wastewater in the Plant is collected in a trench sewer system. It is possible that the piping carrying the wastewater to sanitary sewer, the sump, or throughout the plant may have had failures as a result of age and/or corrosion which could have resulted in releases to the concrete floor enclosing the piping but may have also over time impacted the subsurface.

In approximately 1996/1997, the first floor trench drain pipe in the Plant (which collects process water including chromium and sulfates contaminated water from interior operations as well as exterior trench drains collecting runoff) reportedly had worn down through corrosion, resulting in wastewater collected through that pipe to settle into the ground for an unknown period (few to several months). Soon after their identification of the problem, a new section of PVC pipe was installed within the trench drain. Reportedly, the surrounding area was not dug up to ascertain how much of the subsurface had been affected by the wastewater, although it was noted that the area of the trench drain surrounding the pipe was rotted down to approximately three feet as a result of receiving the process water.

Process and runoff wastewater is currently stored in the TIS AST. As the on-site process and runoff wastewater have the potential to contain chromium, the AST and piping leading to this AST are potential sources of impact to the property.

15.2 Sulfate Impact

ASTs: A 30,000-gallon titanium iron sulfate (TIS) AST is housed within the TIS building, which was utilized by Barcon and M-1. The building formerly had two working drains leading to the Fox River, which were sealed with concrete some time ago. TIS is delivered by tank car in the immediate area of the AST. The piping leading from the drains within the TIS building to the Fox River is a potential source of impact to the property. On March 28, 2000, the facility experienced a release of 40 to 60 gallons of titanyl iron sulfate solution from their 30,000-gallon AST due to an erosion failure of a coupling connection. The majority of the fluid was contained within the building and housed in 50-gallon plastic drums, however, approximately 40 to 60 gallons were accidentally discharged to the Fox River through an old floor drain that had been sealed with concrete (the concrete seal was not effective).

A 15,000-gallon AST housed sulfuric acid, utilized by Barcon and M-I, within a concrete construction secondary containment area, located south of the Plant Building. No known significant releases have been identified. According to Mr. Stein, prior to 1982, this AST was filled primarily by rail cars via the adjacent rail spur located on the east side of the Plant Building. The rail car was filled via a fill port located near the southeast corner of the building, connecting to the AST through a hose that extended along the top of the exterior south wall of the Plant Building to the AST. After 1982, the AST was filled via tank car, which would fill the AST via a hose connected directly from the tank car to the AST, laying the hose over and inside the secondary containment wall to prevent any possible leaks from the hose fitting from spilling outside the containment area. Product piping from this AST ran aboveground into the adjoining warehouse and plant building.

Report No. 2000-001.DDR Appleton, WI 32 l!iiki The Sustainable "1//l Co pany

This AST was removed from service July 6, 2000 and placed on the vacant lot located south of the Jammer House. M-I cleaned the ASTs out prior to their removal by Dawes Crane. [3a]

Reportedly a spill of sulfuric acid from the 15,000-gallon sulfuric acid AST occurred in the early 1970s during Barcon's operations. At that time, there was no containment area enclosing the AST. The ground was reportedly saturated. Lime was placed on the spill area to neutralize the acid. A bobcat was utilized to move the dirt around; no additional activities were conducted to cleanup the spill.

According to Fire Department inspection records, during a routine inspection, a leak was noted from the sulfuric acid tank on April 3, 1997. The Hazardous Materials team reportedly responded and WDNR was notified and took the lead on the case. According to Mr. Stein, the leak consisted of a drip from a line at the pump. The drip fell into an area lined with limestone, neutralizing the acid. Mr. Stein indicated that the faulty line was replaced, and no significant impact was experienced as a result of this leak. He further stated that WDNR came out to the site a couple days following the Fire Department's inspection and did not identify a significant concern.

Wastewater: Wastewater in the M-I (and Barcon) plant is collected in a trench sewer system. It is possible that the piping carrying the wastewater to sanitary sewer, the sump, or throughout the plant may have had failures as a result of age and/or corrosion which could have resulted in releases to the concrete floor enclosing the piping but may have also over time impacted the subsurface.

In approximately 1996/1997, the first floor trench drain pipe in the Plant (which collects process water including chromium and sulfates contaminated water from interior operations as well as exterior trench drains collecting runoff) reportedly had worn down through corrosion, resulting in wastewater collected through that pipe to settle into the ground for an unknown period (few to several months). Soon after their identification of the problem, a new section of PVC pipe was installed within the trench drain. Reportedly, the surrounding area was not dug up to ascertain how much of the subsurface had been affected by the wastewater, although it was noted that the area of the trench drain surrounding the pipe was rotted down to approximately three feet as a result of receiving the process water.

Gypsum storage: Barcon and M-I generated gypsum which was sulfate containing until operations ceased. From 1953 through 1980, this gypsum was stockpiled on site by Barcon, north of the Barcon plant (extending to where the train tracks intersect), within either the gypsum storage shed (concrete floor) or directly on the ground (the area was formerly unpaved). Gypsum sludge was collected on the floor inside the plant building (northwest corner), then moved by front-end loader to waste bins outside the plant building. It is likely that gypsum stored on the ground may have remained in lower points on the property, as on-site personnel may not have been consistently diligent to ensure all gypsum was removed for off-site disposal. In addition, heavy equipment was used to place the gypsum in the north end of the facility, as a result likely tracking the waste throughout the north end of the facility.

Report No. 2000-001.DDR Appleton, WI 33 /f&2 The Sustainable "Iii/I Co pany

General production activities: Sulfates (lignin liquor, sulfuric acid, titanium iron sulfate, sodium bisulfite, ferric sulfate) were utilized in the Barcon and M-I production activities for all products. As a result, sulfates are contained within all finished products stored on site. Finished dry products are stored in the Warehouse or Front Warehouse, and finished liquid products (processed quebracho and neutralized Fraser lignin liquor) are stored in the ASTs located on the north end of the Plant Building. Finished quebracho loading was conducted on the north end or northwest corner of the Plant Building. Finished dry product loading was conducted on the east end of the Plant Building, at the loading dock.

Lignin liquor: According to a letter from Mr. Dowse, dated February 5, 1999, M-I conducted analytical testing to identify the sulfate ion concentration in the lignin liquor utilized on site. The testing indicated that total sulfur as sulfate was present as 9.77% of the liquor product. Further, water soluble sulfate was present as 0.15% of the liquor product. M-I tested the FLAX Flamsperse desugared calcium lignosulfonate liquor produced by Flambeau Paper Corporation. Mr. Dowse considered these results representative of lignin liquor utilized on site.

Lignin liquor delivered and received (following neutralizing processing) by off-site vendors was unloaded during M-l's operations in the east and west train sheds. A trench system collected spilled material in the west train shed, which, was stored in the northeast AST (Tank No. 7, known as "Dirty Water" tank) in the Tank Farm. Lignin liquor unloaded in the east train shed is delivered by a hose connected inside the Tank Farm. As a result, any spilled lignin material is collected within the interior trench drain system. The interior drain system formerly consisted of individual sewer manhole inlets. According to Mr. Stein, the drain system was converted in 1993, in conjunction with the trench drain system installation around the exterior north end of the Plant Building.

The west train shed was unpaved prior to the improvements made in 1993 and 1994; any spilled material would seep directly into the ground. It was reportedly common practice to lay the connecting hose on the ground before turning off the valve, resulting in lignin liquor depositing onto the ground surface.

Prior to the shut down of Consolidated Papers' operations, Barcon utilized lignin liquor generated by Consolidated's operations. This lignin liquor was housed in the Tank Farm. Approximately 30,000-gallon tanks house lignin in this area. These ASTs were on-site since at least 1970. No known releases have been identified to date from this tank farm.

Lignin liquor is known to have been discharged to the Fox River adjacent to the liquid propane tank. A release was discovered on July 3, 1999 into the Fox River of a discharge of black material in the area near the liquid propane tank. The material was determined to be lignin, by Mr. Stein and Mr. Van Hammond (both employees called to the site by the Environmental Wardens). There were two sources that appeared to have contributed to the release. The first source of the lignin appeared to be from a roof drain that normally is directed through a floor drain in the roof to flow into the plant for reuse in the plant operations, but had been directed to flow into the cooling water weir, which discharges to the Fox River. The second source appeared to be surface water flow resulting from the heavy rains from the northern train shed area into the Fox River.

Report No. 2000'.001.DDR Appleton, WI 34 ~ 1 The SuS'tainable Vco pany

On July 9, 1993, Mr. Reif (WDNR Wastewater Division) conducted a visit to the property based upon a complaint that lignin material was being discharged into the Fox River. Mr. Reif observed that waste lignin material was being stored on the ground along the plant adjacent to the Fox River. Mr. Reif observed that the stormwater being collected in a storm drain was being discharged to the waste lignin storage area, and this stormwater with waste lignin material was discharged to the Fox River. Mr. Reif estimated that stormwater was being discharged at a rate of 50,000 gallons per day. Mr. Reif sampled the discharge as it entered the Fox River. He informed Mr. St. Louis that the discharge was not permitted and that he would formally request a solution to remedy the situation (notice of violation).

During a visit by Mr. Reif to the subject property in September 1994, he observed that runoff containing waste lignin had entered the Fox River (based upon his observation of black stained areas, about 1 to 2 feet in diameter) from the area of the waste lignin storage and transfer area. Mr. Reif informed Mr. St. Louis that this runoff was an unpermitted discharge and that this area needed to be quickly upgraded to prevent this from occurring again. The upgrade would consist of additional asphalt to better direct the runoff onto their property. The facility was issued a Notice of Violation on October 18, 1994.

Other known releases: A sulfuric acid line ruptured on the north side of the Barcon and M-1 plant building, just above the 3rd floor fire door in September 1997. Mr. Van Hammond noticed that acid was not coming through the line, and found the rupture in the line. Acid reportedly spilled out onto the north wall of the Barcon plant building and onto the ground below.

Finished product transfers: Finished product containing sulfates were bulk loaded by Barcon and M-1 in the southern train shed located south of the Barcon and M-1 plant.

Consolidated Acid Tanks/Plants: During Consolidated's operations at the property, several sulfuric acid tanks were located in the central portion of the site. An acid plant was located approximately central to the currently vacant land. This acid plant was surrounded at different times with acid tanks to the west and east. A concrete acid tower was located southwest of the acid plant. Sulfur bins were located on the north end of the acid plant. Former digesters were also located in this general area. The first Digester Building (present from at least 1891 through 1924, according to Sanborns), was situated south to north lengthwise. The second Digester Building, present from circa 1928 presumably through 1980, when Consolidated's operations ceased. As sulfates were a principal chemical utilized in the sulfite pulp process, sulfates were highly utilized during Consolidated's operations. Sulfur was reportedly received in railcars and stored on the ground surface west of the acid plant (south of the second Digester Building). Lignin liquor ASTs were present as early as 1970 to the north of the later Digester Building. A lignin liquor washer was present abutting the pulp mill to the north. As coal was the principal fuel along with burning waste liquor, the former location of the coal bin, boiler house, and fly ash hopper, located south of the acid plant and later Digester Building, present potential concerns for sulfates. In addition, the 1970 Sanborn depicts a lignin liquor AST on the southern end of the coal bin.

Report No. 2000-001.DDR Appleton, WI 35 6, The Sustainable ~"co pany

Consolidated utilized an evaporating plant (beginning in 1953), which was located south of the titanyl iron sulfate storage building and north of the paint shed, present as early as 1970. An acid tower, two acid ASTs, and sulfuric acid burning furnaces were located on the river bluff above the property from at least 1891 (operated by Manufacturing Investment Company) through at least 1911 (operated by Interlake Pulp and Paper Company).

15.3 Petroleum Hydrocarbons

USTs: Two 52,000-gallon concrete USTs, utilized by Consolidated for their boiler operations, were located southeast of the Plant Building and north of a former boiler house. These were reportedly utilized to store No. 6 fuel oil. These USTs were reportedly filled with sand and abandoned in place in approximately 1986. Mr. Stein observed that they were emptied, pressure washed, and filled with cement slurry. Mr. Stein further stated that there was a channel around the outside of the concrete tanks, to collect any leaked material, that extended to approximately 15 feet bsg. This channel was filled with mud when the tanks were abandoned. Mr. Stein speculated that the concrete USTs likely contained rebar. The former manhole covers present on site indicates approximately the centerline of the USTs, as they sit side by side. Mr. Stein stated that to his knowledge, there had been no releases from the USTs prior to their abandonment. These tanks are listed in the Wisconsin Department of Commerce UST database as being owned by Consolidated Papers, Inc.

One 500-gallon diesel steel UST was formerly located on-site, east of the Barcon plant and warehouse. This UST was reportedly removed in approximately 1982. This tank was listed as being owned by Consolidated Papers, Inc. and was installed between 1953 and 1965.

One 500-gallon gasoline steel UST was formerly located on-site, east of the Barcon plant and warehouse. This UST was reportedly removed a few years prior to 1982. This tank was listed as being owned by Consolidated Papers, Inc. and was installed between 1953 and 1965.

ASTs: Two 67,000-gallon diesel fuel oil ASTs were located on the south side of the property within a concrete containment vault. These ASTs were present on site since at least 1979. These ASTs were removed in the fall 1999. They were reportedly cleaned prior to their removal by US Oil Company. Mr. Cottington did not believe that an assessment was conducted of the tank area in association with their removal. Ms. Huffman identified visibly stained soil and petroleum odors below the transfer piping connection to the former ASTs. Facility personnel had felt that staining was likely due to oily filters inadvertently placed on the ground in that area.

A leak occurred from underground piping of the two 67,000-gallon ASTs. The section of piping that experienced a leak extended behind (southwest) the Jammer House. The leak was not immediately noticed as it apparently occurred over a weekend, and on-site personnel estimated that approximately 300 to 800 gallons were released.

Report No. 2000-001.DDR .Appleton, WI 36 /i&2, The Sustainable 't/;JJ Co pany

The release reportedly impacted the Telulah Canal, and this was visibly apparent due to the presence of a sheen on the water. It should be noted that reportedly the underground piping in the area of the release was left in place.

A 560-gallon AST is housed within the paint shed. It is housed within concrete walled and floored secondary containment and was formerly used to house diesel fuel. The AST has been emptied except for approximately two inches of residual product left in the bottom of the tank. As this AST is housed within a building and secondarily contained, it is not expected to pose a significant concern to the property.

An approximately 500-gallon AST is housed within a brick walled enclosure within the southeast corner of the machine and warehouse building. This AST is reportedly empty (formerly housed gasoline) and is owned and operated by the City of Kaukauna. This AST is the responsibility of the City of Kaukauna.

Maintenance Pit: The Jammer House was the former site of train car maintenance and truck maintenance activities. The Jammer House was originally constructed with a below grade work pit to facilitate work on the underside of train cars. The pit was concrete lined, extended approximately 20 feet long and 3 feet deep in the northern end of the building. Sometime after 1982, the pit was filled in with sand and surfaced with concrete. A floor drain had been previously located within the pit, but it is unknown where the floor drain discharged. A plastic 275-gallon waste oil AST is housed within the Jammer House, currently utilized by M-1 to collect waste oil generated from on-site maintenance activities. As this AST is located within the Jammer House building which is concrete floored, this AST is not expected to pose a significant concern to the property.

15.4 PCBs

Localized PCB contamination is possible in the areas of the former transformers (located outside the southeast corner of the M-1 and Barcon warehouse, located north of the second digester plant on the Consolidated portion of the property, and located north of the former wastewater treatment plant at the southern portion of the property) and electrical equipment. As PCBs were not known to be utilized as part of any of the various processes utilized on site, PCBs are not considered to pose a serious impact to the property.

15.5 Dioxins, furans, and adsorbable organic halides

According to the Handbook for Pulp and Paper Technologists by Gary Smook, dioxins, furans, and adsorbable organic halides (chlorinated organic compounds) are typically associated with bleached chemical pulp. The chlorination/extraction sequence of the pulp bleaching process is cited in the Handbook as the primary source of these contaminants. At the subject property, these contaminants may be found in the area of the former bleaching operations associated with Consolidated's operations. Two former bleach plants were identified, abutting the northwest and northeast corners of the Warehouse Building. The bleach plant located on the northwest corner was the first plant, present as early as 1924, and was replaced by the other bleach plant by as early as 1950.

Report No. 2000-001.DDR Appleton, WI 37 l/!k1 The Sustainable Vco pany

15.6 PAHs

Coal-fired boilers were present on the subject property, in association with Consolidated's operations. The boiler houses were located in the central portion of the subject property (currently vacant land), as well as coal storage areas. As a result, the potential exists for PAH impact to be present in these areas.

16.0 References

1. Wisconsin Department of Commerce, Underground Petroleum Product Tank Inventory, 52,000-gallon concrete tank, June 30, 1986

2. Consolidated Papers building plans

3. Interviews with on-site personnel, Jim Cottington (Plant Manager, a), Michael Day (Plant Foreman, b), Byron St. Louis (Former Plant Manager, c), Don Stein (Maintenance Manager, d), Arnold Van Hammond (Operator, e)

4. Wisconsin Department of Natural Resources, Toxic Release Inventory Program, Facility Chemical Details Report, 1987-1998

5. Wisconsin Tier Two Emergency and Hazardous Chemical Inventory, 1987-1999

6. Wisconsin Department of Natural Resources, Wastewater Division, records

7. Wisconsin Department of Natural Resources, Stormwater Division, records

8. Wisconsin Department of Natural Resources, Appleton field station, records

9. City of Appleton Fire Department records

10. Wisconsin Department of Commerce Tank Database records

11. Wisconsin Department of Natural Resources, Hazardous Waste Division records

12. Wisconsin Department of Natural Resources, WPDES General Permit No. Wl- 0044938-4, November 9, 1999

13. Industrial User Permit, City of Appleton, Department of Utilities, Wastewater Division, Central Building Maintenance Division, 2006 East Newberry Street, Appleton, WI 54915, May 29, 1998.

14. Sanborn fire insurance maps, dated 1891, 1895, 1901, 1911, 1924, 1950, and 1970. Environmental Data Resources, Inc.

15. City of Appleton Building permit records

Report No. 2000-001.DDR Appleton, WI 38 ~ 2 The Sustainable ~lco pany

16. 1889 City of Appleton atlas map, University of Wisconsin - Green Bay, Special Collections, Coffin Library, Green Bay, Wisconsin.

17. 1889 City of Appleton atlas map, University of Wisconsin - Green Bay, Special Collections, Coffin Library, Green Bay, Wisconsin.

18. 1898 Outagamie County Plat Map, University of Wisconsin - Green Bay, Special Collections, Coffin Library, Green Bay, Wisconsin.

19. 1917 Standard Atlas of Outagamie County, University of Wisconsin - Green Bay, Special Collections, Coffin Library, Green Bay, Wisconsin.

20. Environmental Data Resources, Inc. EDA-Radius Map with GeoCheck, 1130 East John Street, Appleton, Wisconsin, August 2, 2000.

21. Wisconsin Department of Natural Resources web page, Lower Fox River public documents from 1998.

22. Nationwide Environmental Title Research, Historical Chain of Title Report, 1130 East John Street, Appleton, Wisconsin, August 10, 2000.

23. City of Appleton Library, Polk City Directories dated: 1887-1888, 1891-1892, 1896-1897, 1899-1900, 1904,' 1910, 1919, 1921, 1925, 1928, 1930, 1932, 1936, 1940, 1945, 1947, 1949, 1955, 1961, 1963, 1968, 1974, 1979, 1983, 1984, 1985, 1989, 1990, and 1996.

24. City of Appleton Library, Appleton, Wisconsin Map dated 1867.

25. November 1971 Consolidated News

26. Consolidated building plans housed at M-1 LLC facility in Appleton, Wisconsin.

27. Miller Engineers and Scientists, Phase I Environmental Site Assessment, 1130 East John Street, Appleton, Wisconsin, September 23, 1999.

28. M-1 Drilling Fluids Appleton, Wisconsin Plant Block Flow Diagrams prepared by Mr. T. F. Dowse, August 14, 1994.

29. Letter from Mr. Thomas A. Dowse to Miller Engineers, Analytical testing to identify the sulfate ion concentration in the lignin liquor utilized on site, dated February 5, 1999.

30. Handbook for Pulp and Paper Technologists, Gary A. Smock, 1992

31. EPA Office of Compliance Sector Notebook Project, Profile of the Pulp and Paper Industry, September 1995

Report No. 2000-001.DDR Appleton, WI 39 4,The Sustainable ~' Co pany

32. Pulp and Paper Dictionary, John R. Lavigne, 1986

33. "Minutes of Meeting Between M-1 Drilling Fluids and Kaukauna Electric and Water Department on August 22, 1995", provided by Mr. Jim Cottington

34. Quality Control Tests performed on Drilling Mud Additives, performed 1998 through 2000, provided by Mr. Jim Cottington

35. "Sulfate Ion Concentration in Liquor", Letter from Mr. Thomas F. Dowse to Miller Engineers and Scientists, February 5, 1995

36. Sublease Agreement December, effective 10, 1982 to June 30, 1990, between the subleassor Consolidated Papers, Inc. and subleassee Magcobar Group, Dresser Industries, Inc., provided by Mr. Cottington

37. Aerial photographs and postcards, 1892, 1908, 1922, 1950, 1970 (Outagamie County Historical Society, Appleton, Wisconsin); 1938, 1967, 1979, 1992, 1993 (Wisconsin Department of Transportation, Madison, Wisconsin); 1971, 1980 (East Central Wisconsin Regional Planning Commission, Menasha, Wisconsin)

38. Commentary by Mr. Thomas F. Dowse, Consultant to M-1, L.L.C.

Report No. 2000-001.DDR Appleton, WI 40 r£~: The SUS'tainable ~. Co pany

FIGURES

FIGURE 1 SITE LOCATION MAP

FIGURE 2 POTENTIAL SOURCES OF CHROMIUM CONTAMINATION

FIGURE 3 POTENTIAL SOURCES OF SULFATE CONTAMINATION

FIGURE 4 OTHER POTENTIAL SOURCES OF CONTAMINATION

FIGURE 5 PHOTOGRAPHS

Report No. 2000-001.DDR DRAFT Appleton, WI Figure 1 7.5-Minute Topographic Quadrangle: Site Location Map Appleton, Wisconsin 3030 Bridgeway, Suite 305 Date: 1992 Sustainable Sausalito, California 94965 Scale: 1" = 2000 feet Illpany (415) 339-3000 M-1 LLC Due Diligence Review 1130 East John Street A Date: Project: ¢ = F 0 X R V E R

0 50 100 150

HYDRO ELEClRIC INTAKE SCALE IN FEET

@

WAREHOUSE

HYDRO ELEC C INTAKE

Q MH

EX{STlNGASPH/lll EXlSTlNGASPHALT

DlSTI NG CRASS/CRA\IEl.

\__ +")(5' STEEi.. 8~ DIA. PIPE INLE T CRA TE

2" OlA. PIPE TELULAH CANAL

BUILDING LEGEND 0 FRONT WAREHOUSE , «> FORMER LOADING SHED ~ FORMER LIQUOR WASHER ~ M-1 OPERATIONS BUILDING Ci) S FORMER LIME HOUSE ~ CONSOLIDATED OPERATIONS BUILDING {y FOOl,IER Ll.£0 FORMER BLEACH Pu.NT (1!1!19- 1980) BENCHMARK INFORMATION ~ CHROMIUM CONTAMINATION SOURCES IJNL FORMER MA.CHINE: SHOP ASSOCIATED 111TH M-1 I.LC. © ELEVATIONS ARE REFERENCED TO A HYDRANT ON THE SW CORNER OF JOHN STREET <-•976- 2000) AND WALDEN STREET WITH A ELEVATION OF 770.81 (U.S.G.S. DA TIJ~I) <8> FORMER ACID PLANT :;.r~~MUNG ll'ROCESs ~ o <{)FORMER DIGESTER BUILDING ® ~~~: BENCHMARK 1 ESTABLISHED ON PK NAIL IN THE SW FACE OF POWEil POLE NEAR THE lRANSFORMER, ELEVATION 713.37 0 FORMER COAL BOILER HOUSE © OlROlMIJJI ..INO 5\11:fAfE IH -BMOOl FIHISffl:D i'IIOOUCT 3030 BRIDGEWAY ( FORMER WOOD MILL BENCHMARK 2 ESTABLISHED ON HYDRANT NEAR JAMMER HOUSE ON THE TAGGED BOLT ON THE SE CORNER OF FLANGE, ELEVATION 716.97 SAUSALITO, CA 94965 FORMER EVAPORATING PLANT '(z} utiLOM.tlG .Al!EA :FOR ·DICJlRQMATE RECE!v:Et> IN ""tANKER "JRUOKS . (~1976- 2000) TlTANYL IRON SULFATE BUILDING @ SJORIIQ:: lA'NK f~ "llll!Tl' :11/ilER' R£\JSal lij PROCESS DUE DILIGENCE REVIEW <8> FORMER DIESEL BOU.ER HOUSE @OlltOOAL £)(~1/A"IJOII AREA, l ,IP.~CT IDEN1'FED OORIHO ALL UNDERGROUND UTILITY LOCATIONS SHOWN HEREON ARE BASED ON FIELD SURVEY, 1130 EAST JOHN STREET <§> PAINT SHED &: PUMP HOUSE - AlllllT ('198•) RECORD MAPS OR DIGGER'S HOTIJNE MARKINGS. THE EXACT LOCATION OF ALL UTILITIES APPLETON, WISCONSIN FORMER SAW MIU. @)•EXIDIDEll EXCAVAllON »lE,\. IMPACT Jt>(N11FIE!) !OUl!INQ MUST BE FIELD VERIFIED BY THE CONlRACTDR PRIOR TO BEGINNING ANY CONSlRUCTION. E!f,/ROl,1Eff"'1. .~11lllT ~911½) JAMMER HOUSE ~ QF l'IPE f 1'111fflE IDl:I£ l'O t!- - / !997) @ SCALE DATE BY SHEET <8> WAREHOUSE a: Pu.NT BUILDING 'REL.EA$€ Fl?OII SOOlOO illCIIROMAlE "TANK ?l,ll,IP ·(193+) @ HOR. 1 "=100'

HYDRO ELEClRIC 0 50 100 150 INTAKE SCALE IN FEET

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WAREHOUSE

@ HYDRO ELECTR C INTAKE

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12" ffiA.~P[ 12" 0tA..PIPE TELULAH CANAL

/

@ ~~GE ~ PULP S~ (-;~~1~90) BUILDING LEGEND @ FORMER LIQUOR WASHER •BAGGro FlNISHE() PROWCT (ao: 1950-2000, 158: 1~2000} Fa!MER SUl.fUft STORAGE INSll£ ANO CUTSIOE (-1924-1-) <§> FORMER LIME HOUSE ~ BOTH NON-t.a AND M-I OPERATIONS BUILlllNG @ @ ~ FORMER COMPRESSOR ROOM 0 AAtA a Pff rAIUIRE OUE m COIIROSK»I (1!.198/ 19~7) @ ABANOO @ fORM£11 RAil~ """"PIT ELEVATIONS ARE REFERENCED TO A HYDRANT ON THE SW CORNE• OF JOHN SlREET FORMER MACHINE SliOP @ BUJE- ASSOOA'TED WlH J.t-1 LLC. (3 FORMER UGNAL SUlFONAlE ASTa ANO WALDEN STREET WITH A ELEVATION OF no.a, (U.S.G.S. DAl\JM) POTENTIAL SOURCES OF SULFATE ('1SIBIL IN 1024 SAN80RN WAP) <8> FORMER ACID Pl.ANT @ A~~~~ mg: voes AND PCB CONTAMINATION =ICTO SECOl-lOAl!Y ~T~MENT CONS'IRUCl10N ® FORMER UGN,11. UQOUR AST (-1024-1980) BENCHMARK 1 ESTABLISHED ON PK NAIL IN THE SW FACE OF POWER POLE NEAR THE q)F'ORMER OIG£STER BUILDINO ® FORMER OICESTER BUI.DING OPERATIONS (1801-1024) TRANSFORMER, ELEVATION 713.37 3030 BRIOGEWAY 0 FORMER C0,11. BOIILR HOUSE @ ANO~JllE~&M993) SUITE 305 ~~~~~11~ REPORTED FORMER LOCATION OF 500 GAL GASOUI£ UST BENCHMARK 2 ESTABLISHED ON HYDRANT NEAR JAMMER HOUSE (1N THE TAGGED BOLT @ SAUSALITO, CA 94965 <8> FORLIER WOOD MIU. @ TANK FMM F.(f< VAA!OUS LIGHT SUlfOIIAlt !'ROllUCf (-1953 TO 1.. ,,_ 10"2) ON THE SE CORNER OF FLANGE, ELEVATION 716.97 @ REPORTED FCA.£R LOCA TIC>! OF 500 GAL DIESEL UST 0 FORMER EVAPORATING PLANT @ 'fflUCI< I.OAl)ING fOR UOUIO QUQIAAalO PRllOUCT . (-1""3 TO 196,,_19'!2) DUE DILIGENCE REVIEW ~ TITAN'rl. IRON SWATE BUIU>ING @ 811LI< l.OAlllNG CHl!OMlllM-Fl!eE PROOUCTS @ F~ER LOCATION Of 3 ACI> ASTt ('1Sl!I.£ IN 1924 SANBMN WAP) ALL UNDERGROUND UTILITY LOCATIONS SH0\\1'-1 HEREON ARE BASED ON FIELD SURVEY, 1130 EAST JOHN STREET <8> FORMER DIESEi. BOIILR HOUSE ® llTNllL JRGH 5UI.FATE ,>.ST @ FORMER COAi. BOUER HOUSE OPERA 11C>IS RECORD MAPS OR DIGGER'S HOTLINE MARKINGS. THE EXACT LOCATION OF ALL UTILITIES APPLETON, WISCONSIN <§> PAINT SHED & PUMP HOUSE @ SUU'A1£ .sr~· f\JEl Oil tj,1£ 8R£AI< (~1~00) (& EV-"'ORA110N OF UCNIN LICUOR {-19!!3-1980) ~ JAMMER HOUSE SCA!£ OAiE BY SHEET ISOBUTYI. TOLUDE GENERA TEO BY THE SUL,11£ ~ WAREHOUSE & Pl.ANT BUi.DING @ HOR. 1• =100' PULP1NG PROC£SS (-11!91 -1990) Joa CK <§) TANK FARM ® TWO 87.000-GALJ.ON DIESEL FUEL AST, (1973-19')9) PREPARED BY SCHOELL & MADSON, INC. VER. 1. View north of Warehouse and Plant, and titanyl iron sulfate building to the west. )

2. View east of Paint Shed/Pump House and Jammer House. u

Report No. 2000-001 Appleton, Wisconsin ,,

3. View northwest of titanyl iron sulfate building, west train shed, AST secondary containment structure, and Warehouse and Plant building. )

4. East end of AST secondary containment structure that formerly housed sulfuric acid and sodium dichromate.

Report No. 2000-001 2 Appleton , Wisconsin 5. West end of AST secondary containment structure that formerly housed sulfuric acid and sodium dichromate. ( )

l_) 6. View of abandoned hydrogen peroxide, sulfuric acid, and sodium dichromate ASTs on vacant land north of Front Warehouse.

Report No. 2000-001 3 Appleton, Wisconsin 7. View east of Jammer House, beyond is the concrete containment structure formerly housing two 67,000-gallon diesel ASTs. Just south of Jammer House is location of AST piping release. )

u 8. View of interior of 67,000-gallon AST concrete containment structure.

Report No . 2000-001 4 Appleton , Wisconsin Bfflsustainable IIWB!)any

9. View north of tank farm abutting M-1 Warehouse and Plant building. Area to the north and west of the Warehouse and Plant building is approximate storage location of former chromium containing gypsum. ( )

10. View north of 18,000-gallon propane tank and abandoned former Phase B reactor.

Report No. 2000-001 5 Appleton, Wisconsin 11. View south of Front Warehouse building from within Front Warehouse Building . )

12. View northwest of south end of Front Warehouse building and City of Kaukauna power generation facility.

Report No. 2000-001 6 Appleton, Wisconsin 13. View north of Front Warehouse building from Office building.

( )

14. View of City of Kaul

Repo1i No. 2000-001 7 Appleton, Wisconsin 15. View southwest of Office building and College Avenue Bridge overhead .

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16. View south of Office building and vacant land beyond that was formerly site of wastewater treatment operation.

. Report No . 2000-001 8 Appleton, Wisconsin 17. View southeast of vacant lot east of Office building, Telulah Canal beyond. )

18. View of interior of northern portion of the Front Warehouse, former location of pulping process.

Report No. 2000-001 9 Appleton, Wisconsin 19. View of water filtration beds located on east end of the northern portion of the Front Warehouse. )

20. View of interior of northern portion of the Front Warehouse, pulping process tank visible.

Report No . 2000-001 10 Appleton, Wisconsin n

21 . View south of doorway into southern portion of the Front Warehouse building, M-I product storage depicted on the left. ( )

22. View of miscellaneous parts storage in a former office/lab along the west wall of the Front u Warehouse building.

Report No . 2000-001 11 Appleton, Wisconsin )

23 . View of former office/lab along the west wall of the Front Warehouse building. )

24. View of 30,000-gallon titanyl iron storage tank located in the Titanyl Iron Storage Tank building. At the time of the site visit, the storage tank was being utilized for wastewater storage.

Report No . 2000-001 12 Appleton, Wisconsin 25. View of 560-gallon AST within secondary containment in the Paint Shed/Pump House building. The AST was unused at the time of the site visit, and formerly contained diesel fuel. )

26. View of basement of Paint Shed/Pump House building.

Report No. 2000-001 13 Appleton, Wisconsin 27. View of interior of Jammer House. A subgrade pit was formerly located beneath the train track depicted to facilitate maintenance of train cars. )

28. View of miscellaneous storage and plastic 275-gallon used oil AST in the Jammer House.

Report No. 2000-00 ·1 14 Appleton, Wisconsin 29. Inside Warehouse and Plant building, view of process batch tanks on third floor and No. 2 Spray Dryer. ( )

u 30. Inside Warehouse and Plant building, view of No. 1 Spray Dryer on third floor.

Report No . 2000-001 15 _Appleton , Wisconsin 31. Inside Warehouse and Plant building, view of No. 1 process area. )

32 . Inside Warehouse and Plant building, view of No. 1 Phase B Reactor and batch tanks, and No. 2 u Spray Dryer beyond.

Report No . 2000-001 16 Appleton, Wisconsin 33. Inside Warehouse and Plant building, view of Powder Storage Bin on the second floor.

)

34. Inside Warehouse and Plant building, view of dryer process cyclones.

Report No. 2000-001 17 Appleton, Wisconsin 35. Inside Warehouse and Plant building, view of city pit access, located on southwest corner of Plant building, first floor. ( )

(_) 36. Outside Warehouse and Plant building, view of east train shed.

Report No. 2000-001 18 Appleton, Wisconsin 37 . Inside Warehouse and Plant building, view of west train shed (train car present for loading).

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38.View of quebracho spilled on asphalt at the north end of Warehouse and Plant building, in the area of (_J quebracho unloading was formerly conducted.

Report No. 2000-001 19 Appleton, Wisconsin