Rationale for No Action Required

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Southeast Region Headquarters Jim Doyle, Governor 2300 N. Dr. Martin Luther King, Jr. Drive Matthew J. Frank, Secretary Milwaukee, Wisconsin 53212 Gloria L. McCutcheon, Regional Director Telephone 414-263-8500 FAX 414-263-8606 TTY 711 Rationale for No Action Required

Date reviewed: 02/02/09

Name and description of site: CP Rail Systems- 504 SLayton Blvd, Milwaukee, WI FlO# 241441750

Description of contamination: On July 1, 1997, WDNR was notified of a release. In November of 1997, a Site Investigation Report was received. In September of 1998 a Remedial Action Plan was received. In December of 2000, a LUST site was transferred to DCOM (03-41-494911 ). That LUST site references this site. On June 26, 2002, DCOM closed LUST site 03-41-494911. On August 5, 2004, WDNR closed ERP site (02-41-0011 00) which is owned by CP Rail and located in the same area. On March 6, 2001, WDNR closed ERP site (02-41-183125). On February 2, 2009, WDNR closed ERP site (02-41-515224). Both 02-41-515224 and 02-41-001100 are/will be on the GIS Registry.

Conclusions: Assign No Action Required status to this activity. The contamination associated with this activity has been addressed by the actions taken at the other sites in the area.

BRRTS #09·41·152873 FID#2414417L ,-~ Signed: ..it Andrew F Boettcher

Cc: Frances Koonce

www.dnr.state.wi.us Quality Natural Resources Management www.wisconsin.gov Printed on Through Excellent Customer Service Recycled Paoer Boettcher, Andrew F - DNR

From: Boettcher, Andrew F- DNR Sent: Tuesday, February 03, 2009 8:55AM To: 'Hubbes, Ted' Subject: CP Rail Sites - Milwaukee

Attachments: CP Rail Systems Final Closure Letter w Industrial Use LUC.pdf; CP Rail- No Action Required Rationale Sheet.pdf

Hi Ted:

I have reviewed the files for the Canadian Pacific Rail Systems sites in the area of the former Harvester Yard (CP Rail Systems- 504 SLayton Blvd, Milwaukee, WI FID# 241441750). I have found 3 different activities that are still open on our database. I have reviewed the case files and database records. Based on my review, the following changes will be made.

02-41-173165 This site is in the same area and was co-mingled with contamination from 02-41-001100. The submittals regarding 02-41-001100 also addressed the contamination associated with this activity, therefore, the closure letter dated August 5, 2004 and the clarification letter dated January 24, 2007 also apply to this activity. A copy of this email will be added to the GIS packet of that site located on the WDNR's Registry of Contaminated Properties available at http://dnrmaps.wisconsin.gov/imf/imf.jsp?site=brrts2 Also, our database has been updated to reflect this decision.

02-41-515224 This site has been closed with an industrial land-use control and will be placed on the WDNR's Registry of Contaminated Properties available at http://dnrmaps.wisconsin.gov/imf/imf.jsp?site=brrts2 Here is a copy of the final closure letter: ~ ~ CP Rail Systems Final Closure ...

03-41-152873 This site is in the same area and appears to be co-mingled with contamination from 03-41-494911 which was closed by the Wisconsin Department of Commerce on June 6, 2002. Because it appears that the contamination associated with this activity has been addressed {by actions taken regarding 02-41-001100 and 03-41-.494911) the WDNR has determined that no action is required regarding this site. The WDNR has changed the activity type to "No Action Required" and the BRRTS# has been changed to 09-41-152873. ~ CP Rail - No Action Required R...

Please pass this email along to the appropriate people at CP Rail. Our online databases will reflect these changes in the next few days. If you have any questions about these sites, please let me know.

Thanks!

Andy

Andrew F Boettcher Hydrogeologist Remediation and Redevelopment Program Wisconsin Department of Natural Resources Milwaukee, WI 53212-3128 (414) 263-8541 [email protected] RR Program Website: http://dm~wi.gov/orglawlrrl

1 State of Wisconsin\ DEPARTMENT OF NATURAL RESOURCES Southeast Region Headquarters Jim Doyle, Governor 2300 N. Dr. Martin Luther King, Jr. Drive Matthew J. Frank, Secretary Milwaukee, Wisconsin 53212 Gloria L. McCutcheon, Regional Director Telephone 414-263-8500 FAX 414-263-8606 TTY 711

February 2, 2009 In Reply Refer To: FlO# 241441750 County of Milwaukee BRRTS# 02-41-515224

Ms. LeeAnn Thomas Canadian Pacific Railway 501 Marquette Avenue Minneapolis, MN 55402

SUBJECT: Final Case Closure with Land Use Limitations or Conditions, CP Rail Systems Site, 504 S Layton Blvd, Milwaukee, WI

Dear Ms. Thomas:

On January 29, 2009, the Wisconsin Department of Natural Resources (Department) reviewed the above referenced case for closure. This Department reviews environmental remediation cases for compliance with state laws and standards to maintain consistency in the closure of these cases. On December 11, 2008, the Department was contacted by Ted Hubbes at Braun lntertec Corp. on your behalf. Mr. Hubbes asked for help in resolving the status of open sites on this property.

Based on the information contained in the case file, it appears that your case meets the requirements of ch. NR 726, Wisconsin Administrative Code. The Department considers this case closed and no further investigation or remediation is required at this time.

GIS Registry

The conditions of case closure set out below in this letter require that your site be listed on the Remediation and Redevelopment Program's GIS Registry. The specific reasons are summarized below:

• Residual soil contamination exists that must be properly managed should it be excavated or removed • Before the land use could be changed from industrial to non-industrial, additional environmental work must be completed

Information that was submitted with your closure request application will be included on the GIS Registry. To review the sites on the GIS Registry web page, visit the RR Sites Map page at http://dnr.wi.gov/org/aw/rr/gis/index.htm. If your property is listed on the GIS Registry because of remaining contamination and you intend to construct or reconstruct a well, you will need prior Department approval in accordance with s. NR 812.09(4)(w), Wis. Adm. Code. To obtain approval, Form 3300-254 needs to be completed and submitted to the DNR Drinking and Groundwater program's regional water supply specialist. This form can be obtained on-line http://dnr.wi.gov/org/water/dwg/3300254.pdf or at the web address listed above for the GIS Registry.

www.dnr.state.wi.us Quality Natural Resources Management www.wisconsin.gov Printed on Through Excellent Customer Service Recycled Pacer Closure Conditions

Please be aware that pursuant to s. 292.12 Wisconsin Statutes, compliance with the requirements of this letter is a responsibility to which you and any subsequent property owners must adhere. If these requirements are not followed or if additional information regarding site conditions indicates that contamination on or from the site poses a threat to public health, safety, welfare, or the environment, the Department may take enforcement action under s. 292.11 Wisconsin Statutes to ensure compliance with the specified requirements, limitations or other conditions related to the property or this case may be reopened pursuant to s. NR 726.09, Wis. Adm. Code. It is the Department's intent to conduct inspections in the future to ensure that the conditions included in this letter including compliance with referenced maintenance plans are met.

Remaining Residual Soil Contamination

Residual soil contamination remains at the site as indicated in the information submitted to the Department of Natural Resources. If soil in the specific locations described above is excavated in the future, then pursuant to ch. NR 718 or, if applicable, ch. 289, Stats., and chs. 500 to 536, the property owner at the time of excavation must sample and analyze the excavated soil to determine if residual contamination remains. If sampling confirms that contamination is present the property owner at the time of excavation will need to determine whether the material would be considered solid or hazardous waste and ensure that any storage, treatment or disposal is in compliance with applicable standards and rules. In addition, all current and future owners and occupants of the property need to be aware that excavation of the contaminated soil may pose an inhalation or other direct contact hazard and as a result special precautions may need to be taken to prevent a direct contact health threat to humans. '

Industrial Residual Soil Standards

Soil samples that are representative of currently remaining residual soil contamination on this property were collected on June 14, 2001 and November I, 2002, and contained several Polycyclic Aromatic Hydrocarbons (PAHs) in concentrations that met the site-specific industrial soil standards developed for this site. Therefore, pursuant to s. 292.12{2){c), Wis. Stats., the property described above may not be used or developed for a residential, commercial, agricultural or other non-industrial use, unless (at the time that the non-industrial use is proposed) an investigation is conducted, to determine the degree and extent of Polycyclic Aromatic Hydrocarbons (PAHs) contamination that remains on the property, and remedial action is taken as necessary to meet all applicable non-industrial soil cleanup standards. If soil in the specific locations described above is excavated in the future, the property owner at the time of excavation must sample and analyze the excavated soil to determine if residual contamination remains. If sampling confirms that contamination is present the property owner · at the time of excavation will need to determine whether the material would be considered solid or hazardous waste and ensure that any storage, treatment or disposal is in compliance with applicable statutes and rules. In addition, all current and future owners and occupants of the property need to be aware that excavation of the contaminated soil may pose an inhalation or other direct contact hazard and as a result special precautions may need to be taken during excavation activities to prevent a health threat to humans. Please be aware that pursuant to s. 292. i 2 Wisconsin Statutes, compliance with the requirements of this letter is a responsibility to which you and any subsequent property owners must adhere. If these requirements are not followed or if additional information regarding site conditions indicates that contamination on or from the site poses a threat to public health, safety, welfare, or the environment, the Department may take enforcement action under s. 292. i i Wisconsin Statutes to ensure compliance with the specified requirements, limitations or other conditions r~lated to the property or this case may be reopened pursuant to s. NR 726.09, Wis. Adm. Code. It is the Department's intent to conduct inspections in the future to ensure that the conditions included in this letter including compliance with referenced maintenance plans are met.

The Department appreciates your efforts to restore the environment at this site. If you have any questions regarding this closure decision or anything outlined in this letter, please contact Andy Boettcher at (4 i 4) 263-854 i. s~U:~ James A Schmidt SER Remediation & Redevelopment Team Supervisor

CC: Ted Hubbes, Braun lntertec Corp.- By email State of Wisconsin\ DEPARTMENT OF NATURAL RESOURCES

Date reviewed: 02/02/09

Name and description of site: CP Rail Systems- 504 SLayton Blvd, Milwaukee, WI FID# 241441750

Conclusions: Assign No Action Required status to this activity. The contamination associated with this activity has been addressed by the actions taken at the other sites in the area.

BRRTS #09-41-152873 FID#2414417L ,.-u-- Signed: /t Andrew F Boettcher

Cc: Frances Koonce

www.dnr.state.wi.us Quality Natural Resources Management www.wisconsin.gov Printed on Through Excellent Customer Service Recycled Paoer t

Braun lntertec Corporation BRAUN S/.\ 2831 Larson Street La Crosse, Wisconsin 54603-1814 INTERTEC 608-781-7277 Fax: 781-7279 Engineers and Scientists Serving the Built and Natural Environments

September 14, 1998 Project CMXX-97-0371

Mr. Michael Farley Wisconsin Department of Natural Resources I[D) ~ ©~ u rrr rn ffi! 4041 North Richards Street P.O. Box 12436 1JU SEP 1 7 1996 ~; Milwaukee, WI 53212 Dear Mr. Farley: By=··<:f~:c_ ' Re: Workplan for Remedial Investigation, Canadian Pacific Railway--:-Cutoff Yard, 504 So -baytem-Bet~~Milwaukee, Wisconsin, BRRTS# 03-41-152873; Facility ID# 241441750 ~

oration (Braun Iritertec) is pleased to present this workplan for conducting a remedial investigation at the above referenced site. A release of petroleum product at the site was reported to the Wisconsin Department of Natural Resources (WDNR) in the November 21, 1997 UST Site Investigation Report.

If you have any questions or comments regarding this workplan, please contact Paul Hester or Don Huff at (608) 781-7277.

Sincerely,

Paul B. Hester Environmental Geologist

Attachments: Workplan Figure 1 Site Location Map Figure 2 Proposed Monitoring Well Locations Braun lntertec Corporation BRAUN"' 2831 Larson Street La Crosse, Wisconsin 54603-1814 INTERTEC 608-781-7277 Fax: 781-7279 Eng ineers and Scientists Serving the Built and Natural Environments Site Investigation Workplan Canadian Pacific Railway Cutoff Yard Milwaukee, Wisconsin September 14, 1998

This workplan is for a remedial investigation at a reported petroleum release site which was discovered during the removal of an underground storage tank (UST). This workplan is intended to meet the requirement of Wisconsin Administrative Code NR-716.09.

Site Name, Address, and Location

The reported petroleum release site is located in the Canadian Pacific Railway (CPR) Railyard facility at 504 South Layton Boulevard in Milwaukee, Wisconsin. The property is owned by CPR. The site is also defined as the Northeast quarter of the northeast quarter of Section 36, Township 7 North, Range 21 East, Milwaukee, Wisconsin. Site location is shown on Figure 1.

Responsible Party

CPR is the responsible party for this remedial investigation. Mr. Tom Parsons is acting as the Railway's primary contact.

Soo Line Railroad/Canadian Pacific Railway 105 South 5th Street Room 1390 Minneapolis, MN 55440 (612)347-8442

Background Information

Stained soil was observed during the abandonment of a 2,000-gallon UST which was used as fuel oil storage for heating a lunch building. One soil sample was collected from beneath the tank and analyzed for diesel range organics (DRO). DRO were detected at 500 mg/kg in the soil sample. Braun lntertec Corporation BRAUN SM 2831 Larson Street La Crosse, Wisconsin 54603-1814 INTERTEC 608-781-7277 Fax: 781-7279 . Engineers and Scientists Serving th e Built and Natural Environments Site Investigation Workplan Canadian Pacific Railway Cutoff Yard Milwaukee, Wisconsin September 14, 1998

Site Name, Address, and Location

Responsible Party

CPR is the responsible party for this remedial investigation. Mr. Tom Parsons is acting as the Railway's primary contact.

Soo Line Railroad/Canadian Pacific Railway 105 South 5th Street Room 1390 Minneapolis, MN 55440 (612)347-8442

Background Information

Site Physiography and Geology

The site is located in the Menomonee River Valley which is at an elevation approximately 60 feet below the surrounding topography. The Menomonee River curves around the southeast side of the site and is located approximately 1,400 feet to the east and approximately 1,600 feet to the south. The river water elevation is approximately 10 feet below the surface elevation of the site. Groundwater was noted entering the UST excavation which had a depth of 6 feet below ground surface (bgs). Based on the approximate groundwater and surface water elevations at the two locations, a groundwater flow to the east and/or south towards the Menomonee River is expected.

Because the site is located in the river valley, the surficial soil deposits are most likely fluvial in nature. Typical soil types found in shallow soil borings placed in the river valley (approximately 2,100 feet to the southeast of the site at Harvester yard) consists of clayey silt with seams of silty sand to a depth of 16 feet bgs.

Sampling and Analyses Strategy

The field investigation will be a subsurface soil and groundwater sampling and analyses effort. Discrete subsurface soil samples will be collected at 2.5-foot intervals from the surface to termination depth of 10 to 15 feet from five borings completed around the UST basin. Three of the borings will be completed as monitoring wells upon reaching the termination depth.

In-situ hydraulic conductivity testing will be obtained from two of the monitoring wells upon completion of well development using the methods of Bower and Rice (1976) and Hvorslev (1951).

During the UST site investigation, soil sample analysis revealed low levels of DRO analytes above detection limits. The soil and groundwater samples collected during the remedial investigation will be analyzed for PVOCs and DRO.

A maximum of two soil samples from each boring will be analyzed for PVOCs and DRO. Groundwater samples will be collected from each of the three monitoring wells and analyzed for PVOCs and DRO. Canadian Pacific Railway Project CMXX-97-0371 September 14, 1998 Page 3

Scope of Work

The following tasks will be completed as part of this workplan:

• Collect soil samples for field screening at 2.5-foot intervals from five locations near the release area (Figure 2).

• Complete three, 2-inch diameter PVC, groundwater monitoring wells near the release area (Figure 2).

• Screen soil samples for the presence of organic vapors using photoionization detector (PID) or flame ionization detector (FID) headspace methods.

• Collect two laboratory analytical soil samples from each boring at the depth interval yielding the highest headspace reading and at least two feet above the groundwater interface.

• Analyze up to ten soil samples for DRO and PVOCs. Laboratory analytical testing will be performed at a State of Wisconsin certified environmental laboratory (NR-149).

• Conduct In-situ hydraulic conductivity testing in two of the monitoring wells upon completion of well development using the methods of Bower and Rice (1976) and Hvorslev (1951).

• Collect groundwater samples from the three monitoring wells. Groundwater samples will be analyzed for DRO and PVOCs. A trip blank will also be analyzed for DRO and PVOCs as part of quality assurance/quality control (QA/QC).

• Prepare a remedial investigation report detailing the methods, procedures, conclusions and recommendations for further work, if necessary. Canadian Pacific Railway Project CMXX-97-0371 September 14, 1998 Page 4

Schedule

September 1998 - Field Investigation, Installation and sampling of three monitoring wells

December 1998 - Site Investigation Report CONTOUR INTERVAL 10 FEET NATIONAL GEODETIC VERTICAL DATUM OF 1929 DEPTH CURVES AND SOUNDINGS IN FEET-DATUM IS 578 FEET

SITE LOCATION MAP 1-._!.!,;IN~T-+~O~A..!..T=.E---l war ou"" ar:LMS 10-13-97 CP Rail Systems v>'o er: LMS 10-13-97 ., 504 South Layton Boulevard iNS"D Ill! Milwaukee, Wisconsin ""' .... CMXX-97-0371 owe ••· P:\ Projects """"' SCU.£: 1 : O(XY WB FliT.~ ·IIA.H IB FliT. !1oWH ,_.,. ' ·~· :.:;..<}~1' 3::•''"""''""'

OPTION #1 PROPOSED TRACK CHANGES AT MILWAUKEE CUT -OFF tJr Pro/osioL MILWAUKEE, WISC. Bor i ;\-" WATERTOWN SUB. MP 87.1 LO""-+i ...... s SCALE 1'' = 100' 1-23-97 REVISED 9-04-97 'ROJ\MIL 'w'C-0\SURVEY\CUTOFFl 9-4-97 1:07:03 PM EST

INT DATE SHEET BRAUN~ Site Plan DRAWN BY: PBH 09/11/98 Cut-off Yard Work Plan APP'D BY: DRH 09/11/98 OF Canadian Pacific Railway JOB NO. CMXX·97.Q371 INTERTEC Milwaukee, WI DWG. NO. FIGURENO. 2 SCALE • Braun lntertec Corporation :s 11 A lJ }rM 6875 Washington Avenue South P.O. Box 39108 Minneapolis, Minnesota 55439-0108 INTERTEC _-:;--~{\ 612-941-5600 Fax: 942-4844 \ -' ;:;, ~ I ' I ,~ I ~ I, _ ( I I l ~::i I •. -, ' J Engineers and Scientists Serving MAR 171998 [ the Built and Natural Environmen/5'"

::~~9:o= :,,- I~ Canadian Pacific Railway 105 South Fifth Street, Room 1390 PO Box 530 Minneapolis, Minnesota 55440

Dear Ms. Thomas:

Re: Work Plan for Subsurface Investigation at the Soo Line Railroad Company/Canadian Pacific Railway Barrel Storage Area, Harvester Yard, Milwaukee, Wisconsin

Braun lntertec Corporation (Braun Intertec) is pleased to present this work plan for conducting .a subsurface investigation at the above referenced site. The scope of work detailed below is based on the WAC NR 700 series, Wisconsin Department of Natural Resources (WDNR) environmental protection regulations regarding the investigation and remediation of environmental contamination. The objective of the work is to define the magnitude and extent of soil and potential groundwater contamination and evaluate the local geological and hydrogeological conditions. The results of this investigation will be used to determine an appropriate remedial response.

Background

The Soo Line Railroad Company, doing business as Canadian Pacific Railway (CPR), conducts railroad operations at the Harvester Yard facility, located at 504 Layton Boulevard in Milwaukee,Wisconsin. This area occupies the northwest quarter of Section 31, Township 7 North, Range 22 East, and is within a heavily industrialized portion of the Menomonee River Valley (Figure 1).

The site, at this point, is defined by the footprint of a barrel storage facility constructed by CPR in 1997 (Figure 2). The site is adjacent to an active locomotive fueling facility, which included a 100,000-gallon above-ground storage tank (AST), pumphouse and above-ground and underground piping. These structures were all removed in 1997; during the removal operations evidence of petroleum-impacted soil was observed and a petroleum release was reported to the WDNR in July, 1997. Locomotive fueling presently occurs through direct truck transfer.

CPR has also been actively investigating a historic petroleum release associated with an oil/water separator system just south of the barrel storage building. A waste-oil underground storage tank (UST), which stored both waste oil from site operations and the skimmed product collected by the oil/water separator system, was excavated in 1996. Soil and groundwater impacts have been documented from both soil borings and monitoring wells. - Canadian Pacific Railway Project No. CMXX-97--0842 March 6, 1998 Page 2

On December 8 and 9, 1997, the site was excavated in order to lay the foundation of a barrel storage facility. The excavated subsurface material consisted of sand and gravel fill with some construction debris and railroad ties to approximately 3 feet below ground surface (bgs). Clays and silts with fine sand layers were encountered to the bottom depth of the excavation, at approximately 5 feet bgs. A portion of a concrete footing was located within the excavation footprint. This concrete was demolished and removed off site by the excavating contractor. Soils were excavated only to the extent necessary for construction of the barrel storage building. No groundwater was observed; but groundwater levels from 10 to 17 feet bgs were observed during installation of the monitoring wells for the oil/water separator investigation. Perched water was observed at a depth of 4 feet bgs in the fill soils during the oil/water separator investigation.

Some of the excavated soil was stained and displayed a strong petroleum odor. Braun Intertec personnel collected three soil samples from the bottom of the excavation, which were analyzed for Diesel Range Organics (DRO). The laboratory results indicated concentrations of DRO above the WDNR action level of 10 milligrams per kilogram (mg/kg). Two of the soil samples were also above the 250 mg/kg WDNR GRCL for clayey soils. Affected soils were segregated, stockpiled on, and covered with 6-mil polyethylene sheeting on site.

Drums containing petroleum products were formerly stored on the ground within the footprint of the excavation area. These drums were removed by CPR personnel prior to the start of construction activities.

An additional potential source of site petroleum impacts was discovered during excavation activities. At approximately 5 feet bgs, near the base of excavation, an orphan 4-inch-diameter black iron pipe with a roughly north-south orientation was uncovered. The soil around this piping was noticeably more stained than the shallower soil. The existence and historic use of this piping was not known to CPR personnel, and it does not appear on railroad engineering maps. While the site has been part of an active rail yard for more than 100 years, CPR has only owned the site since 1985, and has limited information on historic operations at the site.

Scope of Work

Based on the site history and status of adjacent investigations, Braun Intertec proposes the following scope of work:

• Conduct three soil borings to approximately 20 feet bgs at the locations shown in Figure 2. Soil samples will be collected at 2.5-foot intervals for headspace screening and possible laboratory analysis. From each borehole, the soil sample with the highest field screening result and the soil sample beneath that with less than 10 parts per million (ppm) detected with the field-screening instrument will be sent to the laboratory for analysis. If field screening indicates non-detectable or less 10 ppm volatile organic vapors, then one sample will be collected at the soil/groundwater interface. Canadian Pacific Railway Project No. CMXX-97-0842 March 6, 1998 Page 3

• Visually classify the soil in accordance with ASTM D 2487 "Standard Test Method for Classification of Soils for Engineering Purposes" and ASTM D 2488 "Standard Practice for Description and Identification of Soils (Visual-Manual Procedure)." This will be done by a Braun Intertec geologist.

• Install monitoring wells in the above-mentioned soil borings if, based on field observations, groundwater impacts are evident. Since perched water may be encountered, there is a potential need for nested wells.

• Develop, stabilize and sample the groundwater monitoring wells in accordance with WDNR "Groundwater Sampling Field Manual (PUBL-DG-038, Sept. 96)" and "Groundwater Sampling Desk Reference (PUBL-DG-037, Sept 96)."

• Perform quarterly water level measurements at the monitoring wells.

• Analyze soil samples for volatile organic compounds (VOCs) - EPA Method 8021, polynuclear aromatic hydrocarbons (PAHs) - EPA Method 8310 and diesel DRO.

• Perform in-situ hydraulic conductivity tests in each of the monitoring wells.

• Conduct three rounds of quarterly groundwater sampling.

• Analyze groundwater samples for VOCs, PAHs and DRO, with laboratory analytical testing performed at a State of Wisconsin certified environmental laboratory (NR 149). Assuming that any contamination encountered is petroleum related, the second and third round of sampling will be for PVOCs and DRO.

• Analyze groundwater samples for the following bioattenuation parameters: dissolved oxygen, oxygen reduction potential, specific conductivity, alkalinity, total N as nitrate+nitrite, total sulfate and total iron+manganese.

• Survey the location of monitoring wells and borings and revise the established site map prepared for the adjacent oil/water separator site.

• Review data from the adjacent environmentally impacted areas on site where investigations are currently being performed and incorporate the information into the Braun Intertec report.

• Prepare a subsurface investigation report, as per NR 716.15, detailing the methods, procedures, conclusions and recommendations for further work, if necessary.

Soil cuttings from the performance of the soil borings will be placed on the existing stockpile, to be disposed of once the analyses of the soil is completed. Groundwater from monitoring well development will be placed in 55-gallon drums and labeled as non-hazardous until the analyses are completed. Based on the results of the analyses, disposal of the soil and groundwater will be handled appropriately. Canadian Pacific Railway Project No. CMXX-97-0842 March 6, 1998 Page 4

If you have any questions or comments regarding this work plan, please contact Ron Weaver at (800) 279-6100 or Don Huff at (800) 856-2098. o? Michelle L. Freimund, P.G. H ydrogeologist

Ronald C. Weaver Senior Project Manager c: Wisconsin Department of Natural Resources, Southeast District Don Huff, Braun

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!NT DATE ~M((J SITE LAYOUT MAP o••w• IT: BKH 7-24-93 BRAUN'· Work Plan .4.PP'O 9'r: BKH 7-24-93 Canandian-Pacific Railway Systems Barrel Storage Area RVS'O 9Y; "' INTERTEC 504 South Layton Boulevard JOB••------~----· CMXX-97-0842 Milwaukee, Wisconsin SITEMAPS.DWG '""' 1 "=4D' 2