draft copy – do not file boeing property—boeing draft€¦ · 08/09/2017 · the boeing...

DRAFT COPY – DO NOT FILE Boeing Property—Boeing Draft

(ABOVE SPACE RESERVED FOR RECORDER’S USE) Document Title: Environmental Covenant Document Date: Holder: The Boeing Company

Environment, Health and Safety P.O. Box 516, MC S270-3900, St. Louis, MO 63166-0516

Grantor: The Boeing Company

Environment, Health and Safety P.O. Box 516, MC S111-2491, St. Louis, MO 63166-0516

Department: Missouri Department of Natural Resources

P.O. Box 176, 1101 Riverside Drive, Jefferson City, Missouri 65102

Legal Description: See attached Exhibit B

Environmental Covenant The Boeing Company-Boeing Property of 15

ENVIRONMENTAL COVENANT

This Environmental Covenant (“Covenant”) is entered into by and between the Grantor, The Boeing Company (“Owner”), the Grantee, The Boeing Company (“Holder”), and the Missouri Department of Natural Resources (“Department”) pursuant to the Missouri Environmental Covenants Act, Sections 260.1000 through 260.1039, RSMo. Owner, Holder, and the Department may collectively be referred to as the “Parties” herein.

RECITALS

WHEREAS, Owner is the owner in fee simple of certain real property commonly known and numbered as The Boeing Company, Tract 1, 153 & 163 James S. McDonnell Boulevard and 5220, 5230, & 5240 Banshee Road, Hazelwood, MO 63042, shown on the site map attached hereto as Exhibit A, and legally described as shown in the attached Exhibit B (the “Property”);

WHEREAS, the Property is situated in St. Louis County, Missouri;

WHEREAS, Owner desires to grant to the Holder of this Covenant for the purpose of subjecting the Property to certain activity and use limitations as provided in the Missouri Environmental Covenants Act;

WHEREAS, the Department of Natural Resources enters into this Covenant as a “Department” pursuant to the Missouri Environmental Covenants Act, Sections 260.1000 through 260.1039 RSMo, with all the attendant rights of a “Department” under such Act, which include, but are not limited to, having a right to enforce this Covenant;

WHEREAS, The Boeing Company enters into this Covenant as a “Holder” pursuant to the Missouri Environmental Covenants Act, with all the attendant rights of a “Holder” under such Act, which include, but are not limited to, acquiring an interest in the Property and a right to enforce this Covenant;

WHEREAS, Holder owned or leased the property referred to as The Boeing Company, Tract I (“Tract I”) located at James S. McDonnell and Lindbergh Boulevards in Hazelwood, Missouri, and consisting of about 210 acres;

WHEREAS, the Holder sold a portion of the Property, consisting of approximately 76 acres of land located south of Banshee Road, to the Airport on December 17, 2001;

WHEREAS, the Holder sold approximately 88 acres of Tract I located north of Banshee Road to GKN Aerospace in 2001, 43 acres of which remains subject to the Permit;


WHEREAS, the Holder continues to own the Property, consisting of two parcels of land located north of McDonnell Boulevard consisting of approximately 14 acres and 3 parcel of land located south of Banshee Road consisting of approximately 5 acres, all as depicted in Exhibit A;

WHEREAS, Tract I and the Property are subject to a Missouri Hazardous Waste Management Facility Permit, Permit Number MOD 000 818 963, dated [TO BE INSERTED WHEN PERMIT IS RE-ISSUED] (“Permit”), and the Permit requires Holder to perform certain environmental response actions at Tract I, including but not limited to subjecting the Property to the activity and use limitations set forth in this Covenant;

WHEREAS, the Holder has conducted certain environmental response actions at Tract I and at the Property, including the following activities:

· Investigations of historic releases of environmental contaminants, which investigations were documented in the Resource Conservation and Recovery Act (“RCRA”) Facility Assessment, dated August 14, 1995, and the RCRA Facility Investigation Report, dated December 2004, which have been approved by the Department, and which have concluded that (i) impacts to the soil and groundwater have been adequately identified and extent has been determined, and (ii) impacts are confined to the site and do not extend off-site.

· All interim status and permitted regulated hazardous waste management units have been closed or deferred to the corrective action process governed by the Permit. All closure certifications submitted pursuant the Permit have been accepted by the Department. The final closure certification was accepted August 5, 2002.

· Human health risk assessments and an ecological risk assessment (“Risk Assessments”) were performed for Tract 1 to determine whether contaminants identified on any portion of Tract I posed unacceptable risk to human health or the environment and required additional investigation or corrective measures. For purposes of the Risk Assessment, Tract I was divided into nine areas and several sub-areas, which are depicted on Exhibit A. The following areas and sub-areas evaluated by the Risk Assessments are located on the Property: Areas 4 and 5, Sub-Areas 8A, 8B, and 8C, and Area 9, all as depicted in Exhibit A.

· The Risk Assessments are documented in the Risk Based Corrective Action Report, Boeing Tract 1, dated September 2004, and nine addenda thereto, prepared for Holder by the Risk Assessment & Management Group, Inc., which the Department approved August 24, 2009, and in the Final Risk


Assessment Report, Boeing Tract I Facility, dated March 31, 2008, prepared for the U.S. Environmental Protection Agency (“EPA”) by Tetra Tech EM Inc.

· The Risk Assessments concluded that the calculated risks to human health and the environment for all areas of the Property are within acceptable levels for all current and expected future exposure and use scenarios.

· Holder prepared a Focused Corrective Measures Study Report (“FCMS”), dated July 22, 2014, which the Department approved July 24, 2014, and which evaluated the environmental condition of Tract I and alternative remedial response actions available to address such conditions; and

· Based on the FCMS, the Department has selected the preferred alternative remedial response actions to be implemented to address environmental conditions existing at Tract I, and the Department has amended the Permit to require implementation of the preferred alternative remedial response actions, referred to herein as Corrective Measures Implementation (“CMI”).

WHEREAS, chemicals of concern (“COCs”), which include, but may not be limited to metals, volatile organic compounds(VOCs), and total petroleum hydrocarbons (TPH), will remain on the Property above levels that allow for unrestricted use of the Property; and

WHEREAS, the environmental response project described above is deemed protective if, and only if, the activity and use limitations described in this Covenant remain in place for as long as the COCs remain at the Property above levels that allow for unrestricted use of the Property.

NOW THEREFORE, Owner, Holder, and the Department agree to the following:

1. Parties. The Owner, Holder, and the Department are parties to this Covenant, and may enforce it as provided in Section 260.1030, RSMo.

2. Activity and Use Limitations. Owner hereby subjects the Property to, and agrees to comply with, and to require its tenants, agents, contactors and invitees to comply with, the following activity and use limitations:

A. No Residential Use: The Property shall not be used for residential purposes, which for purposes of this Covenant include: single family homes, duplexes, multiplexes, apartments, condominiums, schools, retirement or


senior/child-care facilities, or any land use where persons can be expected to reside.

B. No Agricultural Use: The Property shall not be used for agricultural purposes or other uses which may result in routine dermal contact with soil by individual non-residential workers. This restriction shall not preclude construction work on the Property notwithstanding that construction workers may have routine dermal contact with surficial soils, nor does this restriction preclude work involving grounds maintenance, installation and maintenance of landscaping and ornamental gardens, and/or installation and maintenance of irrigation systems associated with the foregoing.

C. Implementation of Soils Management Plan: The Owner or Transferee shall implement the Soil Management Plan (“SMP”) attached hereto as Exhibit C, and including any amendments or modifications thereto approved by Owner, Holder and the Department, whenever it disturbs, excavates, or moves such soil on or at the Property for which the SMP provides restrictions.

D. Restriction for Surface Soil: Except in Area 9, all pavement existing as of the effective date of this Covenant shall be maintained in place and/or, if required due to redevelopment of the Property, replaced with an equivalent pavement or cover to prevent direct contact by non-residential workers at the Property with potential COCs in the soil. Allowable replacement coverings include but are not limited to asphalt, concrete, gravel, decorative vegetation, topsoil, or building structure. Removal and/or replacement of pavement or other cover shall be conducted in accordance with procedures in the Soil Management Plan, as applicable. Areas currently consisting of a gravel surface, landscaping, grass, or non-paved areas may remain in place.

E. No Drilling or Use of Groundwater: In addition to any applicable state or local well use restrictions, the following restrictions shall apply to the Property:

1) Groundwater at the Property shall not be consumed or otherwise used for any purpose, except as approved by the Department or as provided for by the FCMS or CMI for the collection of groundwater samples for environmental analysis purposes, collection or treatment of groundwater for remedial purposes, or collection or treatment of groundwater as part of excavation or construction activities.


F. Construction Restrictions: Any enclosed building intended for human habitation and proposed for new construction on the Property in Sub-Area 8A, as shown on Exhibit A, shall be evaluated for vapor intrusion from volatile COCs. If an Owner/ Transferee desires to construct a new enclosed, habitable building on the Property in Sub-Area 8A, then such Owner/Transferee shall demonstrate to the Department that the vapor intrusion pathway has been reasonably evaluated, and if necessary, mitigation measures taken (including but not limited to vapor barriers incorporated in the building design or remediation in conjunction with construction).

If any person desires in the future to use the Property for any purpose or in any manner that is prohibited by this Covenant, the Department and the Holder must be notified in advance so that a Modification, Temporary Deviation, or Termination request can be considered as described below. Further analyses and/or response actions may be required prior to any such use.

3. Running with the Land. This Covenant shall be binding upon Owner and Owner’s heirs, successors, assigns, and other transferees in interest (collectively referred to as “Transferees”) during their period of ownership (except that the obligation described below in paragraph 17 to re-direct any misdirected communication shall continue beyond an Owner/Transferee’s period of ownership), and shall run with the land, as provided in Section 260.1012, RSMo, subject to amendment or termination as set forth herein. The term “Transferee(s),” as used in this Covenant, shall mean any future owner of any interest in the Property or any portion thereof, including, but not limited to, owners of an interest in fee simple, mortgagees (subject to applicable lender liability protections prescribed by law), easement holders, and/or lessees. The Owner and any Transferee shall be responsible for compliance with this Covenant only on that portion of the Property in which the Owner or Transferee, as the case may be, has an ownership interest.

4. Location of Files and Records. Records of this environmental response project for the Property are currently located at the Department’s offices in Jefferson City, Missouri and EPA’s offices in Lenexa, Kansas. Information regarding the environmental response project may be obtained by making a request to the Department pursuant to the Missouri “Sunshine Law”, Chapter 610, RSMo, by referencing the site identification name of Boeing Tract I, Hazelwood, EPA ID # MOD 000 818 963, and/or to EPA pursuant to the United States Freedom of Information Act, 5 U.S.C. § 552.

5. Enforcement. Compliance with this Covenant may be enforced as provided in Section 260.1030, RSMo. The EPA (and any successor agencies) is expressly granted


the power to enforce this Covenant. Failure to timely enforce compliance with this Covenant or the activity and use limitations contained herein by any party shall not bar subsequent enforcement by such party and shall not be deemed a waiver of the party’s right to take action to enforce any non-compliance. Nothing in this Covenant shall restrict any person from exercising any authority or rights under any other applicable law.

In addition to or in lieu of any other remedy authorized by law, prior to taking legal action to enforce this Covenant, the Department may require Owner/ Transferee to submit a plan to investigate and/or correct any alleged violation of this Covenant, in which case the Department shall provide written notification to the Owner. If such Owner/Transferee fails to act within the required timeframe or if the Department finds a proposed remedy unacceptable, the Department may pursue any remedy authorized by law. In such event, the Department shall provide written notification to the Owner, prior to or contemporaneously with any legal action taken to enforce this Covenant. Should EPA decide to exercise its right to enforce this Covenant, EPA shall so notify the Department and the Owner at least 30 calendar days in advance of taking formal action to do so.

6. Right of Access. Owner, on behalf of itself and any Transferees, hereby grants to Holder, Department, and EPA, and their respectively authorized agents, contractors, and employees, the right to access the Property at all reasonable times subject to timely prior notice and compliance with the Owner’s security and safety requirements for implementation, monitoring, inspection, or enforcement of this Covenant and the related environmental response project. Nothing herein shall be deemed to limit or otherwise impede the Department’s or EPA’s rights of access and entry under federal or state law or other agreement.

7. Compliance Reporting. Owner/Transferee shall submit to Holder and the Department, by no later than January 31st of each year, documentation verifying that the following activity and use restrictions were in place and complied with during the preceding calendar year: Activity and Use Limitation 2.D, Restriction for Surface Soil, and Activity and Use Limitation 2.F, Construction Restrictions. The Compliance Report shall include the following statement, signed by Owner/Transferee:

I certify that to the best of my knowledge, after thorough evaluation of appropriate facts and information, the information contained in or accompanying this submission is true, accurate and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

Environmental Covenant The Boeing Company-Boeing Property of 15 8. Additional Rights.

None Specified.

9. Notice upon Conveyance. Each instrument hereafter conveying any interest in the Property or any portion of the Property shall contain a notice of the activity and use limitations set forth in this Covenant, and provide the recording reference for this Covenant. The notice shall be substantially in the following form:

THE INTEREST CONVEYED HEREBY IS SUBJECT TO AN ENVIRONMENTAL COVENANT, DATED ___________, 20__, RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS OF _____________ COUNTY, ___________, ON ___________, 20__, AS DOCUMENT ____, BOOK___, PAGE ____.

Owner/Transferee shall notify the Holder, Department and EPA within ten (10) days following each conveyance of an interest in any portion of the Property. The notice shall include the name, address, and telephone number of the Transferee, and a copy of the deed or other documentation evidencing the conveyance.

10. Representations and Warranties. Owner hereby represents and warrants to the Holder and Department that:

a) Owner has the power and authority to enter into this Covenant, to grant the rights and interests herein provided and to carry out all of Owner’s obligations hereunder;

b) this Covenant will not materially violate or contravene or constitute a material default under any other agreement, document or instrument to which Owner is a party or by which Owner may be bound or affected; and

c) Owner is the sole owner of the Property and holds fee simple title to the Property, and to the actual knowledge of Owner, based on its review of reasonably available property records in its possession, custody, or control, the Property is subject to the existing leases, easements, and other encumbrances (“Encumbrances”) listed in Exhibit D. Concurrent with entry of this Covenant, Owner has notified the holder of each of the respective Encumbrances of Owner’s intent to enter this Covenant by mailing to such holders a notice substantially in the form of Exhibit E.

11. Amendments, Termination, and Temporary Deviations. This Covenant may be amended or terminated by approval of the Department, Holder, and the current Owner/Transferee of record at the time of such


amendment or termination, pursuant to section 260.1027 RSMo. Any other Parties to this Covenant hereby waive the right to consent to any amendment to, or termination of, this Covenant. Following signature by all requisite persons or entities on any amendment or termination of this Covenant, Owner/Transferee shall record and distribute such documents as described below.

Temporary deviations from the obligations or restrictions specified in this Covenant may be approved by the Department in lieu of a permanent amendment to this Covenant. Owner/Transferee may submit a written request to the Department to temporarily deviate from specified requirements described herein for a specific purpose and timeframe, which shall not exceed ninety (90) days. Any such request shall be transmitted to the Holder and the Department as described below. The request must specifically invoke this paragraph of this Covenant, fully explain the basis for such temporary deviation, and demonstrate that protection of human health and the environment will be maintained. The Department will evaluate the request and convey approval or denial in writing. Owner/Transferee may not deviate from the requirements of this Covenant unless and until such approval has been obtained.

12. Severability. If any provision of this Covenant is found to be unenforceable in any respect, the validity, legality, and enforceability of the remaining provisions shall not in any way be affected or impaired.

13. Governing Law. This Covenant shall be governed by and interpreted in accordance with the laws of the State of Missouri.

14. Recordation. Within thirty (30) days after the date of the final required signature upon this Covenant or any amendment or termination thereof, Owner shall record this Covenant with the appropriate recorder of deeds for each county in which any portion of the Property is situated. Owner shall be responsible for any costs associated with recording this Covenant.

15. Effective Date. The effective date of this Covenant shall be the date upon which the fully executed Covenant has been recorded with the office of the recorder of each county in which the Property is situated.

16. Distribution of Covenant. Within thirty (30) days following the recording of this Covenant, or any amendment or termination of this Covenant, Owner/Transferee shall, in accordance with Section 260.1018, RSMo, distribute a file- and date-stamped


copy of the Covenant as recorded with the appropriate recorder of deeds (including book and page numbers) to: (a) each of the Parties hereto; (b) each person holding a recorded interest in the Property, including any mortgagees or easement holders; (c) each person in possession of the Property; (d) each municipality or other unit of local government in which the Property is located; (e) EPA; and (f) any other person designated herein.

17. Contact Information. Any document or other item required by this Covenant to be given to another party hereto shall be sent to:

If to Owner/Transferee: The Boeing Company Environment, Health and Safety P.O. Box 516, MC S270-3900 St. Louis, MO 63166-0516 And Remediation Manager Environment, Health and Safety The Boeing Company 2201 Seal Beach Blvd. Seal Beach, CA 90740-5603 And The Boeing Company c/o MBG Consulting Inc. Boeing Lease Administration Team 980 N. Michigan Avenue, Suite 1000 Chicago, IL 60611-4521

If to Holder: The Boeing Company Environment, Health and Safety P.O. Box 516, MC S270-3900 St. Louis, MO 63166-0516 And


Remediation Manager Environment, Health and Safety The Boeing Company 2201 Seal Beach Blvd. Seal Beach, CA 90740-5603 And The Boeing Company c/o MBG Consulting Inc. Boeing Lease Administration Team 980 N. Michigan Avenue, Suite 1000 Chicago, IL 60611-4521

If to Department:

Project Manager – MOD 000 818 963 - Boeing Tract 1, Hazelwood Missouri Department of Natural Resources Hazardous Waste Program, Permits Section P.O. Box 176 Jefferson City, MO 65102-0176

If to EPA:

Director, Air and Waste Management Division U.S. Environmental Protection Agency, Region 7 11201 Renner Blvd. Lenexa, KS 66219

The Owner/Transferee, Holder, Department or EPA may change their designated recipient of such notices by providing written notice of the same to each other. If any notice or other submittal under this Covenant is received by a former Owner/Transferee who no longer has an interest in the Property, then such former Owner/Transferee shall notify the Department, Holder, EPA, and the current Owner/Transferee of the Property regarding the mis-directed communication.

18. Reservation of Rights. This Covenant is a necessary component of the environmental response project described above. Nothing in this Covenant shall be construed so as to relieve any Owner/Transferee from the obligation to comply with this Covenant during their period of ownership, or the obligation to comply with any other source of law. This Covenant is not a permit, nor does it modify any permit, order, agreement, decree, or judgment issued under any federal, State, or local laws or regulations, and the Department does not warrant or aver in any manner that an Owner/Transferee’s compliance with this Covenant will constitute compliance


with any such requirements. The Department and EPA reserve all legal and equitable remedies available to enforce this Covenant or any other legal requirement, and/or to address any imminent and substantial endangerment to the public health or welfare or the environment arising at, or posed by, the Property. Nothing herein shall be construed so as to prevent the Department, Holder or EPA from taking any independent actions as allowed by law.

The undersigned represent and certify they are authorized to sign this Covenant on behalf of their respective Parties.

IT IS SO AGREED:

Environmental Covenant The Boeing Company-Boeing Property of 15 FOR OWNER: By: ______________________________________ Date: _____________________ Name : Marc Poulin Title: Environment, Health and Safety Address: The Boeing Company

P.O. Box 516, MC S270-3900 St. Louis, MO 63166-0516

STATE OF MISSOURI ) ) CITY OF ST. LOUIS )

On this _____ day of ___________________, 201__, before me a Notary Public in and for said state, personally appeared ______________________________(Name), __________________________(Title) of ____________________________(Corporate Name), known to me to be the person who executed the within Covenant on behalf of said corporation and acknowledged to me that he/she executed the same for the purposes therein stated.

____________________________________ Notary Public

My Term Expires:

Environmental Covenant The Boeing Company-Boeing Property of 15 FOR HOLDER: By: _______________________________________ Date: _____________________ Name : Marc Poulin Title: Environment, Health and Safety Address: The Boeing Company

P.O. Box 516, MC S270-3900 St. Louis, MO 63166-0516

STATE OF MISSOURI ) ) CITY OF ST. LOUIS )

On this _____ day of ___________________, 201__, before me a Notary Public in and for said state, personally appeared ______________________________(Name), _________________________(Title) of _____________________________(Corporate Name), known to me to be the person who executed the within Covenant on behalf of said corporation and acknowledged to me that he/she executed the same for the purposes therein stated.

____________________________________ Notary Public

My Term Expires:

Environmental Covenant The Boeing Company-Boeing Property of 15 FOR DEPARTMENT: By: ______________________________________ Date: _____________________

John D. Juergensmeyer, Director Missouri Department of Natural Resources Hazardous Waste Program PO Box 176 Jefferson City, MO 65102-0176

STATE OF ________________________ ) ) COUNTY OF ______________________ )

On this _____ day of ___________________, 201__, before me a Notary Public in and for said state, personally appeared John D. Jurgensmeyer, Director of the Hazardous Waste Program of the Missouri Department of Natural Resources, a state agency, known to me to be the person who executed the within Covenant on behalf of said agency by authority of its Director and acknowledged to me that he executed the same for the purposes therein stated.

____________________________________ Notary Public

My Term Expires:

2B

2C

3C

3A

8B

9

1

2A4

53E

3G3D

3D 3H

45

48

42 2

142

8C

8A

6D6C

6B

Cold

water

Creek

Banshee Rd

Banshee Rd

Lindb

ergh

Blvd

McDonnel Blvd

2929A

27A

34

32

33

0 500 1,000250Approximate Scale in Feet ±

Exhibit A

Property Subject to Activity and Use Limitations

Boeing Tract 1, Hazelwood, MissouriMay 2015 Proj No: 054517

Roads Buildings

Area under Permit Area 7 and Subarea 6A removed from the Permit

8B

45

8C

8A

Cold

wate

r Cre

ek

Banshee Rd

Lindb

ergh

Blvd

McDonnel Blvd

2

27

2929A

45

48

42

27A

21

25

51

34

32

4

45K

52

22

33

39

41

28

0 500250Approximate Scale in Feet ±

Exhibit ABoeing Property Subject to Activity and Use

LimitationsBoeing Tract 1, Hazelwood, Missouri

May 2015 Proj No: 054517

Roads Buildings

Area under Permit

153 James S. McDonnell Blvd. Hazelwood, MO 63042 (Building 220)

A tract of la:nd situated in United States Survey 5 of the Marais Des Liards Common Fields in Townships 46 and 47 North, Range 6 ·Ji:ast, St, Louis County, Missouri, and described as beginning at a point in the line dividing United States Surveys 5 az;d 7 • said point being South 52 degrees 43 minutes 30 seconds East, 900 feet from its intersection with the southeasterly line of United States Highway No. 66 (known as Lindbergh Boulevard); said point also being the most southern corner of property described in deed to General Motors Corporation recorded in Book 3236, page 515, St. Louis County Recorder' s office; thence North 37 degrees 38 minutes East 638 .08 feet aJ.ong the eastern line of said General Motors Corporation property to a point of curve; thence continuing mortheastwardly 103.89 f'eet along said General Motors Corporation property , along a curve to the right having a radius of 269. 94 feet to a point being the most eastern corner of said General Motors Corporation property; thence South 30 degrees 18 minutes 53 seconds East 7, 00 feet along a radial line of said curve and along the southern boundary of property described in deed to Wabash Railroad Company recorded in Book 3249, page 45, St. Louis County Recorder• s Office; thence along the southern boundary of said Wabash Railroad Company property northea.stwardly, eastwardly and southeastwardly 28:2.47 feet along a curve to the right: having a radius of 262.94 feet and having the same center as the last mentioned curve, to a point of tangency; thence continuing along said southern .boundary South 58 degrees 46 minutes East 53 .56 feet to a point of curve; thence continuing along said southern boundary southeastwardly 82.18 feet along a curve to the right having a radius of 739 .49 feet to a point; thence South 52 degrees 22 minutes East 228 .55 feet along said southern boundary of property of the Wabash Railroad Company described in Book 3249, page 45, to a point in the most northwesterly line of property described in deed to Wabash Railroad Company recorded in Book 3222, page 142, St. Louis County Recorder' s Offiee; thence South 37 degrees 38 minutes West 906.82 feet along the said most northwesterly lin1;, of said Wabash Railroad Company property as described in Book 3222, page 142, and along. the northwesterly line of property described in lease to Hill-Behan Lumber Company dated October 12, 1:953, to a point in the line dividing said United States Surveys 5 and 7; thence North 52 degrees 43 minutes 30 seconds West 504.41 feet along said line dividing United States Surveys 5 and 7 to the point of beginning; the southwesterly 20 feet of the above described tract being subject to the interests of the public in Brown Road; said tract containing 10.09 acres, inclusive of the 20 foot strip in Brown Road, according to a survey made by Pitzman's Company of Surveyors & Engineers on April 21, 1955.

163 James S. McDonnell Blvd. Hazelwood, MO 63042 (Building 221)

A tract of land located in United States Survey 5 of the Marais Des Liards Common Fields in Townships 46 and 47 North, Range 6 East, St. Louis County, Missouri, being more particularly described as follows:

Beginning at a point in the line dividing United States Surveys 5 and 7, said point lying South fifty-two degrees, forty-three minutes, thirty seconds East (S 52° 43' 30" E) nine hundred C 900) feet from the intersection of said line dividing United States Surveys 5 and 7 with the Southeasterly line of United States Highway 66; thence North thirty-seven degrees, thirty-eight minutes East CN37° 38' E) six hundred thirtyeight and eight hundredths (638.08) feet to a point of curve; thence on a curve to the right having a radius of two hundred sixty-nine and ninety-four hundredths (269.94) feet, which curve is tangent to last described course at last mentioned point a distance of one hundred three and eighty-nine hundredths (103.89) feet; thence North thirty degrees, eighteen minutes, fifty-three seconds West (N 30° 18' 53" W) along a radius of siid curve produced, twenty-eight (28) feet; thence North fifty-two degreees, forty-three minutes, thirty seconds West (N 52° 43' 30" W) ninety-four and ninety-eight hundredths (94.98) feeti thence South sixty-nine degrees, twenty-seven minutes, thirty seconds West (S 69° 27' 30" W) four hundred twenty-nine and sixteen hundredths (429.16) feet to a point in the Southeasterly line of a tract of land conveyed to International Harvester Company by Wabash Motor Transit Company by deed dated May 16, 1951; thence South thirty-three degrees, thirty-four minutes West CS 33° 34' W) along said Southeasterly line of land so conveyed three hundred eighty-seven and fifty-eight hundredths (387.58) feet to a point in the line dividing United States Surveys 5 and 7, said point being the most Southerly corner of said tract of land conveyed by said deed of May 16, 1951; thence South fifty-two degrees, forty-three minutes, thirty seconds East CS 52° 43" 30" E) along said line dividing United States Surveys 5 and 7 three Hundred (300) feet to the point of beginning, containing an area of 4.59 acres, more or less, subject to so much of Brown Road as lies within the boundaries of said tract; said tract lying within the limits of a survey executed by Elbring Surveying Company during May and June of 1945, plat of which is recorded in the office of the Recorder of Deeds of aforesaid St. Louis County in Plat Book 38, page 60.

Being the same premises conveyed to General Motors Cor.porat:ion by deed dated March 18, 1954, recorded March 26, 1954, in Book 3236 page 515 St. Louis County Records.

SPECIAL WARRANTY DEED

29thTHIS DEED, made and entered into this / day of November,

1984, by and between THE MUTUAL BENEFIT LIFE INSURANCE COMPANY, a

corporation organized and existing under the laws of the State of

New Jersey, with its principal office at 520 Broad Street, Newark,

New Jersey 07101, Party of the First ?art, and McDONNELL DOUGLAS

CORPORATION, a corporation organized and existing under the laws of

the State of Maryland, with its principal office at P. o. Box 516,

·. St. Louis, Missouri 63166, Party of the Second Part,

538 W I T N E S S E T H

That the said Party of the First Part for and in consideration

of the sum of One Hundred Dollars ( $100. 00 I , and other valuable 1

considerations to it paid by the said Party of the Second Part, the

receipt of which is hereby acknowledged, and pursuant to authority

given by the Board of Directors of said Party of the First Part, does,

by these presents, BARGAIN ANO SELL, CONVEY AND CONFIRM unto the

said Party of the Second Part, the following described real estate,

situated in the county of St. Louis, State of Missouri, to-wit:

A tract of land located in United States Survey 5 of the Marais Des Liards Common Fields in Townships 46 and 47 North, Range 6 East, St. Louis County, Missouri, being more particularly described as follows:

Beginning at a point in the line dividing united States Surveys 5 and 7, said point lying South fifty-two degrees, forty-three minutes, thirty seconds East (S 52° 43' 30" El nine hundred (900) feet from the intersection of said line dividing United States Surveys 5 and 7 with the Southeasterly line of United States Highway 66; thence North thirty-seven degrees, thirty-eight minutes East CN37° 38' El six hundred thirtyeight and eight hundredths (638.08) feet to a point of curve; thence on a curve to the right having a radius of two hundred sixty-nine and ninety-four hundredths (269.941 feet, which curve is tangent to last described course at last mentioned point a distance of one hundred three and eighty-nine hundredths (103.891 feet; thence North thirty degrees, eighteen minutes,

fifty-three seconds West (N 30° 18' 53" W) along a radius of said curve produced, twenty-eight (28) feet; thence North fifty-two degreees, forty-three minutes, thirty seconds West (N 52° 43' 30" W) ninety-four and ninety-eight hundredths < 94. 98) feet1 thence South sixty-nine degrees, twenty-seven minutes, thirty seconds West (S 69° 27' 30" W) four hundred twenty-nine and sixteen hundredths (429.16) feet to a point in the Southeasterly line of a tract of land conveyed to International Harvester Company by Wabash Motor Transit Company by deed dated May 16, 1951; thence South thirty-three degrees, thirty-four minutes West CS 33° 34' W) along said Southeasterly tine of land so conveyed three hundred eighty-seven and fifty-eight hundredths (387.58) feet to a point in the line dividing United States Surveys 5 and 7, said point being the most Southerly corner of said tract of land conveyed by said deed of May 16, 1951; thence South fifty-two degrees, forty-three minutes, thirty seconds East (S 52° 43" 30" E) along said line dividing United States Surveys 5 and 7 three Hundred (300) feet to the point of beginning, containing an area of 4.59 acres, more or less, subject to so much of Brown Road as lies within the boundaries of said tract; said tract lying within the limits of a survey executed by Elbring Surveying Company during May and June of 1945, plat of which is recorded in the office of the Recorder of Deeds of aforesaid St. Louis County in Plat Book 38, page 60.

Being the same premises conveyed to General Motors Corporation by deed dated March 18, 1954, recorded March 26, 1954, in Book 3236 page 515 St. Louis County Records.

Subject to zoning, building laws and ordinances.

TO HAVE AND TO HOLD same, together with all rights and

appurtenances thereto, unto the said Party of the Second Part, its

successors and assigns forever.

The said Party of the First Part hereby covenants that it will

WARRANT AND DEFEND title to the said real property unto the said

Party of the Second Part, its successors and assigns forever against

the lawful claims of all persons claiming by, through or under the

said Party of the First Part, but none other, excepting, in all

events, the general taxes for the calendar year 1984 and thereafter,

and any special taxes becoming a lien after the date hereof.

IN WITNESS WHEREOF, the said Party of the Fist Part has caused

these presents to be executed by a Vice President and attested by

. .

an Assistant Secretary, and its corporate seal to be affixed, the

day and year first above written •

ATTEST: Assistant Secret;:;;=r

STATE OF NEW JERSEY ss.

COUNTY OF ESSEX

On this __h! day of Novem ber , 1984, before me appeared

Robert W. Kopchains , to me personally known, who, being by me Se n ior

duly sworn, did say that he is alvice-President of THE MUTUAL BENEFIT

LIFE lNSURANCE COMPANY, a corporation of the State of New Jersey,

and that the seal affixed to the foregoing instrument is the corporate

seal of said corporation, and that said instrument was signed and

sealed in behalf of said Corporation by authority of its Board of

Directors; and said f obert W. Kopchai ns acknowledged said

instrument to be the free act and deed of said corporation.

IN TESTIMONY WHEREOF, I have hereunto set my hand and affixed

my official seal in the City of Newark, State of New Jersey, the day

and year first above written.

My Commission Expires:

ary Public

,

SOIL MANAGEMENT PLAN for

GKN TECHNOLOGIES AND THE BOEING COMPANY-OWNED PORTIONS

of THE TRACT I PERMITTED HAZARDOUS WASTE

MANAGEMENT FACILITY

DRAFT

27 July 2016

Boeing Defense, Space & Security – St. Louis

Environment, Health and Safety

Soil Management Plan Draft - 27 July 2016

TABLE OF CONTENTS

Page

1.0 Introduction ................................................................................................................. 1

2.0 Process for Implementing the SMP ........................................................................... 2

3.0 Field Procedures.......................................................................................................... 5

4.0 Additional Requirements ......................................................................................... 11

FIGURES Figure 1 Sub-Areas with Risk Exceedances, Boeing Tract I, Hazelwood, MO Figure 2 Soil Management Plan Process for Soil Disturbance Activities on the

Permitted Tract I Facility TABLES Table 1 Primary Chemicals and Routes of Exposure that Cause Risk and

Hazard Index Exceedances Appendix A: Corrective Action Record List Appendix B: Exposure Unit Areas and Subareas of the Permitted Tract I Facility Appendix C: Survey Coordinates for Mapping Points Appendix D: Environmental Covenant (to be inserted upon completion) Appendix E: Outline: Health and Safety Plan Appendix F: Work Plan for Future Drilling and/or Well Installation Activities Appendix G: Facility-Specific Comparison Values (FSCVs) Appendix H: Outline: Work Plan for Characterization and/or Remediation Activities

Soil Management Plan 1 Draft - 27 July 2016

1.0 Introduction

1.1 Purpose This Soil Management Plan (SMP) sets forth the processes and guidelines to be followed for any disturbance of soil located on portions of the property referred to as The Boeing Company (Boeing), Tract I Facility (‘the Facility’), located at James S. McDonnell and Lindbergh Boulevards in Hazelwood, Missouri, and which are subject to the requirements of the Missouri Hazardous Waste Management Facility Part I Permit, Permit Number MOD 000 818 963, dated August 2016 (Permit). This includes portions of the Tract I property now owned by The City of St. Louis (the City), the Tract I property now owned by GKN Technologies (GKN), and the remaining portions of the Tract I property now owned by Boeing. This SMP is site-specific to the GKN and Boeing-owned portions of the Tract I property, henceforth referred to as ‘the Property’. This SMP has been updated and revised to reflect the various remedial investigations, risks assessments, and corrective measures studies that have been completed for the Facility and approved by MDNR. Appendix A includes a list of relevant documents. This SMP supersedes all prior SMPs. The overall objective of the SMP is to 1) mitigate the potential risks associated with workers being exposed to residual chemicals in soil or groundwater that could be encountered during soil disturbance activities, and 2) provide information on procedures for the characterization, remediation (if necessary) and the disposition of soil. Such soil disturbances may be conducted by the current or future owners, lessees, or tenants of the Property. 1.2 Property Background The permitted Tract I Facility was divided into exposure unit Areas and Subareas for the purpose of conducting risk assessments. These Areas and Subareas are described in Appendix B. A map showing the Facility property and the location of each exposure unit Area and Subarea, is provided as Figure 1. Appendix C includes a figure and table providing the location and survey coordinates for identified mapping points across the Facility. The approved risk assessments (RAM, 2004 and Tetra Tech, 2008; see reference in Appendix A) did not find any risk exceedances associated with subsurface soil concentrations. However, risk exceedances associated with groundwater were identified in Subarea 6B, currently located on GKN Property. The identified risks are described in Table 1. 1.3 General Requirements The owner of the property where soil disturbance activity will take place shall have primary responsibility for the soil disturbance related activities and for implementing this

2

SMP. Boeing may elect to be represented in the field during any soil disturbance activities, including any sampling and excavation, by an owner or operator, or their employees, contractors, or consultants, provided, however, that Boeing’s access to the Property, where applicable, shall be subject to the requirements of the Real Estate Access Easement Agreement between GKN and Boeing. However, the unavailability of Boeing’s representative would not require that the project be delayed.

2.0 Process for Implementing the SMP Figure 2 presents a step-by-step process for implementing the SMP described below: Step 1: Project Review Prior to initiating soil disturbance activities to which this SMP is applicable, the Property Owner will identify the planned footprint of the soil disturbance, estimated depth of disturbance, the estimated quantity of soil planned to be disturbed, and the restrictions on the particular project footprint as set forth in the Environmental Covenant. For ease of reference, the current Environmental Covenant is provided in Appendix D. The SMP and the procedures herein only apply to projects located within the bounds of the Property and for any activity that involves soil disturbance of one or more cubic yards of soil. The SMP does not apply to routine landscaping or minor repairs to irrigation systems or to projects executed in areas where previous soil disturbance activities have confirmed the absence of soil impacts. Irrespective of these conditions, the Property Owner will be responsible for ensuring that any soils excavated from within the bounds of the Facility and taken offsite are properly characterized and disposed. Step 2: Notification Requirements For projects, partially or completely, located in Subarea 6B (referred to herein as the Notification Area) and to which this SMP applies, GKN will provide notification to Boeing as soon as feasible. This will allow Boeing to promptly and timely evaluate the project and coordinate with GKN to determine necessary actions, if any, prior to project commencement (unless in case of an emergency; see Step 2a) to minimize delays to the project schedule. Notification regarding planned projects shall be made to: EHS Department EHS Remediation Project Manager The Boeing Company P.O. Box 516, Mailcode S111-2491 St. Louis, MO 63136 Email: [email protected]

3

The notification should include the project location, its purpose, and a complete description of the anticipated extent of soil disturbance. Preferably, the notification should include a figure(s) showing the project limits with respect to property lines, building footprints, and/or other reference points. For projects that are not located in the Notification Area, the Property Owner shall provide a brief notification to Boeing of the planned activities and will proceed with the project following the requirements of the SMP outlined in Section 3.0. The following identify other measures that shall be implemented for projects within the Notification Area:

Step 2a - Emergency Projects: There may be circumstances under which it may not be possible to provide notice prior to implementing a project. Examples of such emergency projects could include utility line breaks that must be repaired immediately or hazardous substance spills where excavation of impacted soil is time critical. Under such conditions, the notification can be deferred until the emergency situation is controlled. Step 2b - Health and Safety Planning for Exposure Pathways: The risk assessments indicated that cumulative risks were within acceptable levels for all scenarios except for the construction worker for the following exposure pathways within Subarea 6B:

· Potential dermal contact with groundwater.

· Outdoor inhalation of vapors from groundwater. For soil disturbance activities below three feet in the Notification Area, GKNor its contractor shall develop and implement a Health and Safety Plan (HASP) that addresses specific personal protective equipment (PPE) to protect workers who may be exposed to groundwater by dermal contact or by outdoor inhalation of vapors. An example HASP is attached as Appendix E. GKN, or its contractor, is responsible to develop and implement the HASP in accordance with OSHA requirements and those described in this section. The HASP should address the following as applicable:

A. Project specific PPE requirements,

B. Project specific medical monitoring requirements,

C. Project specific training requirements, and

D. Project specific emergency procedures. Step 2c - Future Drilling and/or Well Installation Activities: As stated in the Environmental Covenant for the Property (see Appendix D), any drilling or penetration of groundwater that is planned in the Notification Area must be performed in

4

accordance with a work plan approved by the MDNR, unless the work is conducted in accordance with the SMP or with the Work Plan for Future Drilling and/or Well Installation Activities, provided as Appendix F. The intent of this SMP and the Work Plan in Appendix F is to allow execution of pre-approved well drilling and groundwater penetration in a timely manner without requiring MDNR’s approval for specific procedures (e.g. procedures related to soil screening, well installation, HASP, etc.). Instead, a simple email or memo may be submitted electronically to MDNR with the location and number of samples, the analytical methods to be used, and the schedule for the identified work. GKN will follow-up any electronic notifications with a paper copy submittal to MDNR. GKN will provide the notification for work and allow sufficient time for MDNR review in accordance with the process identified in Step 6 below.

Step 3: Evaluation of the Planned Project After the details of the project have been determined, the Property Owner will evaluate the project against available site information to determine whether any characterization samples will be collected. To a large extent this decision will be based on professional judgment. Appendix A includes a list of available documents that contain site information and may help with this decision. Step 4: Characterization Sampling Characterization samples may be collected by the Property Owner based on review of available information. Characterization sampling may be scheduled prior to the commencement of the project (to avoid delays) or during soil disturbance activities. Sampling matrix (i.e., soil, soil gas, or groundwater) and chemical analysis will be determined based on the evaluation conducted in Step 3 and/or for planning the disposition of any removed media. The number and location of samples will be determined by the Property Owner on a case-by-case basis. Boeing may elect to be represented in the field by an employee or contractor during sampling and/or other project activities. Boeing’s access to the Property shall be subject to the requirements of the Real Estate Access Easement Agreement between GKN and Boeing. Boeing may also elect to notify MDNR of the planned project and MDNR may elect to be represented in the field to observe. Step 5: Evaluation of Sample Results Characterization sample results will be compared with the Facility-specific comparison values (FSCVs) that have been developed for the chemicals of concern (COCs). The flowchart (Appendix G, Figure 1) and associated tables provided in Appendix G identify the steps for selecting applicable FSCVs.

5

The FSCVs will be used to (1) delineate the nature and extent of residual impacts, and (2) determine whether remediation is necessary (if groundwater, soil or soil vapor concentrations exceed the FSCVs). Step 6: Path Forward If characterization sample results do not exceed the applicable FSCVs, the Property Owner may proceed with the planned project following the field procedures identified in Section 3 of this SMP. If the FSCVs are exceeded in one or more samples, the Property Owner will document these results and submit the results and a work plan to address the exceedances in the context of the planned project to MDNR. Next steps may include extended characterization or excavation activities following the guidance provided in this SMP. Appendix H provides an outline of the types of information that should be included in a work plan. Work plan approval requests must be submitted (electronically when possible) to the MDNR at least 15 working days prior to performing the work. When possible, requests should be grouped together and consolidated. The MDNR Project Manager will confirm MDNR’s receipt of the request. Within 15 working days, MDNR will notify the requestor Project Manager by phone or e-mail if the request is approved or if MDNR has questions. If MDNR’s approval is verbal, that approval will be confirmed by the Property Owner in a letter or e-mail within 5 working days. If approval is not received within 15 working days, the Property Owner’s Project Manager will contact MDNR to resolve any issues related to the request and obtain approval within 5 working days of the verbal approval. Upon MDNR’s concurrence with the work plan, the Property Owner will implement the work plan and document the work conducted in a report to MDNR and Boeing. It is understood that all work will be done in the context of the planned project. Sampling, characterization and remediation will be required only to the extent necessary to implement the planned project with the recognition that the Facility risk assessment has already determined that undisturbed areas have been addressed adequately. If impacts are identified during the course of project activities that extend beyond the planned project bounds, the Property Owner will notify Boeing. Boeing will address these issues on a case-by-case basis and in a manner that limits interference with the planned project. This may include coordinating with the Property Owner’s ongoing field efforts to extend the bounds of excavation to address impacted soils (i.e., soil concentrations greater than the FSCVs) in a manner consistent with the procedures defined in this SMP.

3.0 Field Procedures Field procedures include screening disturbed soil for indications of residual impacts, characterizing suspected impacts, and managing soil with confirmed impacts. These procedures apply to all areas of the Property.

6

3.1 Soil Screening Screening of disturbed soil for indications of contamination will generally involve visual and olfactory observations. Soil may also be screened for organic vapors using a calibrated photoionization detector (PID). During soil disturbance activities, field personnel should observe uncovered soils for signs of potential impacts such as soils that appear wet or saturated, soils that appear stained or discolored, odors in ambient air, and/or features such as piping or sumps that may be indicative of potential past chemical use (hereafter referred to as Potential Indicators). It should be noted that although odors may be indicative of a potential environmental impact, nothing in this SMP should be construed as encouraging field workers to “sniff” soil samples to detect odors. In the context of this SMP, the odors referred to are those that may be noted in ambient air when impacted soil is first exposed. If Potential Indicators are detected, near-surface “grab” soil samples will be collected periodically for headspace screening for volatile organic chemicals (VOCs) using a calibrated PID in the area of the Potential Indicators. Grab samples will be collected in areas with Potential Indicators and at other randomly selected locations within the soil disturbance area. All PIDs used during field screening will be calibrated per manufacturer’s specifications. Where required, soil samples for headspace screening will be collected from at least six inches below ground surface (bgs) to help ensure they are representative of in-situ VOC conditions. Approximately six ounces of soil will be sealed inside a one-pint Zip-Lock-type freezer bag or one-pint glass jars and agitated to promote the volatilization of VOCs, if any, into the headspace. After allowing two minutes for VOCs to volatilize and equilibrate, the PID probe will be inserted into the headspace and the peak and/or steady PID reading recorded. A PID reading of 100 parts per million by volume (ppmv) will be considered indicative of a potential VOC impact that will require further assessment. The PID readings, date, time, and location of soil samples collected for headspace screening will be recorded on field data logs for inclusion in final documentation of field activities. 3.2 Boeing Impact Notification If the project is completed without any indication of soil impacts, there are no further reporting obligations. However, if Potential Indicators are observed and follow-up headspace screening indicates an impact for further assessment, Boeing shall be notified as soon as practicable in accordance with Section 2.0, Step 2. The notification should include the project location, the depth at which the actual or suspected impact was encountered, and a brief summary of the observed conditions. Upon being notified of an actual or suspected soil impact, Boeing may:

7

• Have a representative visit the project site, in conformance with the requirements of the Real Estate Access Easement Agreement, to observe the actual or suspected impact and evaluate it in the context of available site assessment data and/or institutional knowledge of the Facility.

• Notify MDNR.

3.3 Impact Assessment If Potential Indicators are encountered during soil disturbance activities, it may be appropriate for the Property Owner to collect one or more representative samples for laboratory analysis, to verify whether impacted soils are present, characterize the type of impact, and determine if remediation is warranted or whether special handling will be needed for removed soils. The number of soil samples collected and the analysis performed will be determined by the Property Owner based on the results of soil screening, the scope of the proposed project, and existing site assessment information. Utility clearance for lateral and vertical extent sampling will be coordinated with the Property Owner’s contractor. Sample locations will be documented using GPS and/or land surveying equipment.

The specific samples to be collected, methodology, and chemical analysis will be based on field observations and a review of known COCs in the respective Focused CMS risk assessment Subarea. For example, if PID readings exceed 100 ppmv, the soil sample(s) will be analyzed for VOCs. If the planned project includes construction of a building within 50 feet of the impacted location, soil gas samples may be collected in lieu of or in addition to soil samples. The sample concentrations will be compared with FSCVs as outlined in Appendix G and discussed in Section 2.0, Step 5. If an impact above the FSCVs is identified, then the lateral and vertical bounds of the impact will be delineated to the extent necessary to implement the planned project. This may include collecting samples in an iterative manner until the extent has been defined to concentrations at or below the FSCVs. The Property Owner shall document impact assessment activities and submit a report to Boeing that includes, at a minimum, the following information: the area where soil was disturbed, the depth of disturbance, the number and location of samples collected, analytical results, comparison of results with the FSCVs, and any other relevant information. 3.4 Groundwater The need for groundwater impact assessment will primarily be triggered by soil impacts identified during field screening of soil disturbance activities. However, the potential exists that groundwater may be encountered during subsurface activities. Depending on

8

the results of soil screening and impact assessment activities, a field decision may be made whether a groundwater sample should be collected to assess impacts to groundwater. If such impacts are identified, it is anticipated that remediation will be addressed as per the Focused CMS (RAM Group, 2014). The groundwater remedy identified in the Focused CMS incorporates Activity and Use Limitations (AULs) to protect against groundwater from below the site being used for drinking water purposes and the use of monitored natural attenuation (MNA) to confirm that VOC mass and concentrations in groundwater decline over time. The Focused CMS also includes a contingency planning provision for specific measures to be taken if changed conditions are observed that are inconsistent with the ongoing MNA program. Therefore, if impacts to groundwater are identified during the course of a planned project, impacts will be assessed to determine if the existing remedy, consisting of AULs and MNA, will be sufficient to address the impact(s) or if contingency actions will be considered. Section 5.4.7 of the Focused CMS provides further details on the conditions that may trigger contingency actions and examples of actions that may be considered. It is also possible for groundwater to be encountered during trenching or excavation and for groundwater to seep into the excavation. If groundwater is collected for discharge (e.g., dewatering of an excavation), a water sample will be analyzed by the Property Owner so that the collected water is properly characterized for disposal. 3.5 Remediation If soil impacts are identified, it is anticipated that those impacts will be excavated and managed by the Property Owner as described in Sections 3.5.1 through 3.5.3, if such excavation is needed by the planned project. However, nothing in the SMP requires current or future owners, developers, or tenants to excavate or remediate contaminated soil to depths or in areas greater than those required for the project. If impacts are identified during the course of project activities that extend beyond the planned project bounds, the Property Owner will notify Boeing. Boeing will address these issues on a case-by-case basis and in a manner that limits interference with the planned project. This may include coordinating with the Property Owner’s ongoing field efforts to extend the bounds of excavation to address impacted soils (i.e., soil concentrations greater than the FSCVs) in a manner consistent with the procedures defined in this SMP. 3.5.1 Soil Excavation and Management within the Planned Project Area If impacted soil or soil suspected of being impacted is excavated from within the lateral and vertical bounds of the planned project area, it may be reused onsite if it meets the reuse criteria set forth below or must be transported offsite for treatment and/or disposal. The following provides general guidance on excavation, segregation, and related dust control procedures.

9

A. During the excavation process, soil should be segregated, to the extent practical, from non-impacted soil. Segregation may be based on results from soil screening.

B. To the extent practical, foreign objects such as demolition debris should be segregated from soil with Potential Indicators to simplify its subsequent management.

C. Soil with Potential Indicators with different characteristics (e.g., chlorinated solvents versus petroleum hydrocarbon impacts) should be segregated and stockpiled or containerized separately. The additional assessment costs to segregate the soils are justified to prevent “cross-contamination” between stockpiled or containerized soil, resulting in more soil than necessary having to be transported offsite.

D. Limit stockpile size to a maximum of 100 cubic yards and container size to a maximum of 40 cubic yards to minimize the potential for a small volume of contaminated material to impact the larger volume of excavated material, resulting in increased disposal costs.

E. At a minimum, stockpiles of soil with Potential Indicators shall be placed on heavy duty polyethylene sheeting. Ideally, the stockpiles will be located in paved areas to prolong the life of the polyethylene ground cover, make stockpile removal easier, and to prevent clean soil in unpaved areas being impacted.

F. Stockpiles and containers of soil with Potential Indicators shall be covered with heavy duty polyethylene sheeting to minimize volatilization of VOCs, generation of dust, or dispersion via precipitation. Covers should be weighted down (e.g., with sand bags) to prevent the cover being blown off and potentially becoming foreign object debris (FOD) in the context of aircraft operations at or near the Property.

G. Covered stockpiles should be surrounded by sediment control socks or similar materials to minimize the potential for eroded sediment being transported beyond the stockpile limits.

H. Transport and disposal of soil shall be conducted in accordance with applicable regulations.

It is noted that after soils with Potential Indicators have been characterized and the ultimate disposition of the impacted material established, excavated material may be “direct-loaded” into trucks for offsite treatment or disposal thereby bypassing the stockpiling process.

10

3.5.2 Onsite Soil Reuse The Property Owner will determine if the potential exists for the excavated soil to be returned to the original excavation or used elsewhere on the permitted property. To minimize soil handling and disposal requirements, excavated soil should be reused onsite as fill or backfill whenever feasible, so long as that reuse is protective of human health and the environment and an appropriate location is available. For reuse evaluation and waste profiling purposes, a minimum of two composite soil samples will be collected from each stockpile or container of excavated soil. Stockpile and container samples will be analyzed for the COCs likely to be present based on the data pertaining to the source excavation(s). Sample results will be compared against the FSCVs (see Appendix G). If other, non-Facility specific COCs are identified by the chemical analysis, sample results may be compared with background levels presented in the Geochemical Survey of Missouri, R. Tidball, 1984 or other authoritative references and procedures. If it is determined by the Property Owner that excavated soils cannot be reused onsite because sampling has established that the soils contain a COC above the FSCVs, the results of the chemical analyses may be used for waste profiling for proper management and disposal of the soils. If sampling establishes that all COCs are below the FSCVs, but above background levels, and it is determined that excavated soil is anticipated by the Property Owner to be reused onsite, the following steps will be followed:

A. The Property Owner will identify the location for temporary management and replacement of the excavated soil. In most cases, soil is expected to be returned to the location from which it was excavated.

B. If the soil is to be reused in a location other than the original excavation, the

specific location must be identified. The following general criteria are applicable when impacted soil will be placed in a location other than the original excavation:

1. Location must be on the Facility and not accessible to the general public.

2. The soil must contain no visible free liquids (e.g., groundwater) and must be

sufficiently dry so as to not produce free liquids following placement.

3. The location of the soil placement must be consistent with any and all of the activity and use limitations placed on the permitted property (Appendix D).

i. Analytical data is required to support the onsite reuse of any impacted

soil. This data may come from existing data and/or from any additional pre- or post-excavation soil sampling and analysis.

ii. When impacted soil is approved for backfill into the excavation, a clean

layer of soil, or other appropriate capping material such as gravel,

11

asphalt, concrete, or a combination must be placed at grade on top of the backfilled soil. The clean soil layer shall be a minimum of one (1) foot thick and be free of COC concentrations above the FSCVs; (see Appendix G). Any impacted soil which is not used as backfill must be managed and disposed of in accordance with all applicable local, state, and federal requirements.

C. Impacted soil reused onsite must be free of debris and piping. Adequate controls

must be in place to ensure soil reuse does not create contamination issues at the proposed reuse location.

D. The Property Owner will maintain information of all soil management activities on

its portion of the permitted property. This information will contain locations and amount of soil reused onsite, locations of soil removed for disposal, method of disposal, and analytical data collected during soil management activities.

3.5.3 Groundwater in Excavations During subsurface activities, such as trenching or excavation, groundwater may be encountered and seep into the excavation. Unless previous sampling has already determined that the groundwater does not contain COCs, if groundwater is collected for discharge, a sample must be analyzed and the collected water must be properly disposed. Requirements of this section do not apply to water accumulation in a trench or excavation area that is the result of a break, leak or ruptured water line, where the sole purpose of the excavation is to repair or replace the damaged water line, unless such water is to be disposed off-site.

4.0 Additional Requirements 4.1. Additional Requirements

A. Characterization sampling/analysis and subsequent excavation activities on the permitted property could lead to the discovery of additional solid waste management units (SWMUs) and/or areas of concern (AOCs). Any SWMUs/AOCs and/or new releases from known SWMUs/AOCs discovered by Boeing, or reported to Boeing by the Property Owner, must be reported to MDNR and the U.S. Environmental Protection Agency (USEPA) by Boeing in accordance with Corrective Action Conditions III and IV of the Permit, as applicable. Notification by Boeing of discovery of situations that may require stabilization action(s) are also required by the Permit.

B. Waste soil and/or groundwater from the Property that is determined to be

hazardous waste will be managed by the Property Owner, except that waste soil and/or groundwater determined to originate from Boeing’s historical operations.

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Such soils will be promptly and timely shipped offsite for disposal at a Boeing-approved waste disposal facility under the USEPA and MDNR ID number assigned to Boeing for the Facility. Any offsite shipments utilizing the Boeing ID number will be promptly and timely reviewed by Boeing prior to shipment, with Boeing responsible for waste profiling, manifesting, and regulatory reporting associated with such shipments.

C. Boeing is not responsible for any reporting or remediation of any condition not

caused by Boeing, although the Property Owner shall be obligated to inform Boeing of any future contamination events.

D. Boeing must be notified in advanced of planned excavation in areas where Boeing groundwater monitoring wells are located so that wells can be closed and/or moved as necessary in compliance with MDNR requirements. See Figure 1 for locations of all wells. Boeing shall close any well within 15 working days of notification, contingent upon receiving MDNR approval.

Soil Management Plan Draft - 27 July 2016

FIGURES

McDonnel Blvd

South Tract

8C

8B

8A

7

6C

6D

6B

6A

3A

3B

3D

3C3F

3G

3E3H

4

9

5

1

2C

2B2A

Banshee Rd

North Tract

32

221

220

33

34

39

28

22

2929A

27

21

48A

48

42

43

1

3

2

4

6

5

11

11A

13

12

14

27A

Lin

dber

gh B

lvd

RAM Group (054517)July 2014/BR

RAM Group of Gannett Fleming, Inc.

5433 Westheimer, Suite 725, Houston, TX 77056

Figure 1Sub-Areas with Risk Exceedances Boeing Tract 1, Hazelwood, MO

N

00 400 800

Approximate Scale in Feet

Existing Building

Exposure UnitNo.

No.Exposure

Unit Description

1

2

3

4

5

6

7

8

9

Runway Protection Zone

Demolished Area

Retained Area

Power Plant

Industrial Water Treatment Plant

GKN Facility

Engineering Campus

Office Complex North

Gun Range

Shallow Monitoring Well/

Piezometer (Total 56)

Abandoned/Damaged Well (Total 36)

Deep Well (Total 8)

Intermediate Well (Total 9)

Sub-Area 2B: Exceedances per

RAM Risk AssessmentSub-Area 2C & 3H: Exceedances

per EPA Risk Assessment

Sub-Area 6B: Exceedances per

both RAM and EPA RiskAssessment

Is the projectwithin or partially within the

bounds of the permittedfacility?

Proceed with the planned project

No

Does the project include soil disturbance of >1 yd3 of soil?

No

Yes

Is the Qualifying Projectin a Notification Area?

Yes = Qualifying Project

No

Property Owner to: 1) notify Boeing and 2) evaluate the project against available

site information.

Will characterizationsamples becollected?

Project Owner to collect characterization samples prior to or in

conjunction with soil disturbance activities.

Yes

No

Yes

Proceed with the planned project following the Field

Procedures in Section 3of the SMP

Is impacted soil encountered during soil

screening activities?

Yes

No further action or reporting requirements

No

Do concentrationsexceed the applicable

FSCVs? A

FSCV – Facility-specific comparison values

A Refer to Appendix F, Figure F-1 – Steps to Select Applicable Facility-Specific Comparison Values

Yes

No

Develop workplan for further characterization and/or recommendation

of an appropriate remedial action. Implement the workplan upon MDNR

concurrence.

Can impacted soilsbe addressed through

implementation ofthe SMP?

Implement SMP to address impacted soils.

Yes

No

Document results and notify MDNR and Boeing.

Document work conducted and submit report to MDNR and

Boeing.

FIGURE 2: SOIL MANAGEMENT PLAN PROCESS FOR SOIL DISTURBANCE ACTIVITIES ON THE PERMITTED TRACT I FACILITY

Step 1

Step 2

Step 3

Step 4

Step 5

Step 6

Soil Management Plan Draft 27 July 2016

TABLES

Area COC Media Exceedance Due to Risk Assessment

Benzo(a)anthracene GW Dermal contact with groundwater by future construction worker RAM Group

1,2-dichloroethene (total) GW Outdoor inhalation of vapors from groundwater by future construction worker

Benzene GW Outdoor inhalation of vapors from groundwater by future construction worker

Trichloroethene (TCE) GW Outdoor inhalation of vapors from groundwaterDermal contact with groundwater by future construction worker

Vinyl chloride GW Outdoor inhalation of vapors from groundwater by future construction worker

Mercury GW Outdoor inhalation of vapors from groundwater by future construction worker

Aroclor 1254 GW Dermal contact with groundwater by future construction worker

TPH-GRO Aliphatics >C5 to C8 GW Outdoor inhalation of vapors from groundwater by future construction worker

TPH-GRO Aromatics >C9 to C18 GW Outdoor inhalation of vapors from groundwater by future construction worker

TPH-DRO Aromatics >C9 to C18 GW Outdoor inhalation of vapors from groundwater by future construction worker

Notes:TPH: Total petroleum hydrocarbonsGRO: Gasoline range organicsDRO: Diesel range organicsC: Carbon rangeGW: Groundwater

July 2014/BR RAM Group (054517)

Table 1Primary Chemicals and Routes of Exposure that Cause Risk and Hazard Index Exceedances

Boeing Tract 1, Hazelwood, MissouriCombined RAM Group and Tetra Tech Risk Assessments

Sub-area 6BTetra Tech


APPENDIX A

CORRECTIVE ACTION RECORD LIST

Record Date Author

5/29/1997 Environmental Science & Engineering,

Inc., St. Louis, MO

RCRA Facility Investigation Workplan for McDonnell Douglas,

Hazelwood, Missouri Facility, Volume I

12/18/1997 Heritage Environmental Services, Inc.,

Chicago, IL

Interim Measures Completion Report, McDonnell Douglas Aerospace,

U.S. EPA ID No. MOD000818963, Tract I Facility, Hazelwood, Missouri

4/20/2001 Harding ESE, Inc., St. Louis, MO RCRA Facility Investigation Workplan Addendum II for McDonnell

Douglas, Hazelwood, Missouri

9/27/2002 Harding ESE, Inc., St. Louis, MO Environmental Field Investigation Statement of Work for Boeing Tract I

South Property, Hazelwood, Missouri

10/29/2002 Harding ESE, Inc., St. Louis, MO Annual monitoring Report for Solid Waste management Unit 17,

McDonnell Douglas, Hazelwood, Missouri

3/2003 Golder Associates, Inc., St. Charles,

MO

Environmental Baseline Survey, Boeing Tract I South Facility,

Hazelwood, MO

11/7/2003 MACTEC Engineering and Consulting,

Inc., St. Louis, MO

Environmental Investigation Report for Boeing Tract I South Property


Inc., St. Louis, MO

Enhanced Bioremediation Pilot Test Report for Boeing Tract I,

Hazelwood, Missouri

9/2004 Risk Assessment & Management

Group, Inc., Houston, TX

Risk‐Based Corrective Action Report, Boeing Tract I, St. Louis, Missouri,

Volumes I and II

**

12/2004 MACTEC Engineering and Consulting,

Inc., St. Louis, MO

RCRA Facility Investigation Report for McDonnell Douglas, Hazelwood,

Missouri

**


Inc., St. Louis, MO

Interim Action Remedial Excavation Workplan, Solid Waste

Management Unit 17, McDonnell Douglas, Hazelwood, Missouri


Inc., St. Louis, MO

TPH Soil Vapor Sampling Workplan, Boeing Tract I, Hazelwood,

Missouri


Inc., St. Louis, MO

Interim Action Remediation Excavation Completion Report, Boeing

Tract I, McDonnell Douglas, Hazelwood, Missouri

6/2006 MACTEC Engineering and Consulting,

Inc., St. Louis, MO

Interim Measure Completion Report, Solid Waste Management Unit

17, McDonnell Douglas, Hazelwood, Missouri

3/2008 Tetra Tech EM, Inc., Lenexa, KS Final Risk Assessment, Boeing Tract I Facility, St. Louis, Missouri **

4/7/2010 RAM Group of Gannett Fleming, Inc.,

Houston, TX

Quality Assurance Project Plan, Boeing Tract 1, Hazelwood, Missouri


Houston, TX

Final Corrective Measures Study Work Plan, The Boeing Company

Tract 1, Hazelwood, Missouri


Houston, TX

Ground Water Gauging and Sampling‐ Spring 2010, Boeing Tract 1,

Hazelwood, Missouri


Houston, TX

Ground Water Gauging and Sampling‐Fall 2010, Boeing Tract I,

Hazelwood, Missouri


Houston, TX

Ground Water Gauging and Sampling‐ Summer 2011, Boeing Tract I,

Hazelwood, Missouri


Houston, TX

Revised Interim Measures Work Plan, Sub‐areas 2B and 6B, The Boeing

Company, Tract I, Hazelwood, Missouri

Corrective Action Administrative Records

The Boeing Company Tract I Facility, Hazelwood, Missouri

Title

APPENDIX A

Page 1 of 2

Record Date Author

Corrective Action Administrative Records

The Boeing Company Tract I Facility, Hazelwood, Missouri

Title

APPENDIX A


Houston, TX

Ground Water Gauging and Sampling‐ February 2012, Boeing Tract I,

Hazelwood, Missouri


Houston, TX

Ground Water Gauging and Sampling‐ September 2012, Boeing Tract I,

Hazelwood, Missouri


Houston, TX

Ground Water Gauging and Sampling‐ March 2013, Boeing Tract I,

Hazelwood, Missouri


Houston, TX

Interim Measures Sub‐Areas 2B and 6B, The Boeing Company, Tract I,

Hazelwood, Missouri


Houston, TX

Ground Water Gauging and Sampling‐ October 2013, Boeing Tract I,

Hazelwood, Missouri


Houston, TX

Semi‐annual Groundwater Monitoring ‐ April 2014, Boeing Tract I,

Hazelwood, Missouri


Houston, TX

Focused Corrective Measures Study, The Boeing Company Tract 1,

Hazelwood, Missouri

**


Houston, TX

Semi‐annual Groundwater Monitoring‐ October 2014, Boeing Tract I,

Hazelwood, Missouri


Houston, TX

Semi‐annual Groundwater Monitoring ‐ March‐April 2015, Boeing

Tract I, Hazelwood, Missouri


Houston, TX

Semi‐annual Groundwater Monitoring ‐ September 2015, Boeing Tract

I, Hazelwood, Missouri

** Indicates this document may be a good source and/or reference for evaluating available site information.

Page 2 of 2


APPENDIX B

EXPOSURE UNIT AREAS AND SUBAREAS OF THE PERMITTED TRACT I FACILITY

November 2011/AMS 1 RAM Group (054517)

APPENDIX BDESCRIPTION OF AREAS/SUB-AREAS

BOEING TRACT 1, HAZELWOOD, MISSOURI

AREA 1: RUNWAY PROTECTION ZONE

The Runway Protection Zone is an Area approximately 1,500 feet long by 600 feet wide. Within this Area, there were 23 buildings or structures, in addition to portions of two buildings, and a small parking lot. All buildings within this Area have been demolished. As per FAA regulations, no buildings can be built in a runway protection zone. This Area is currently paved and will remain paved.

AREA 2: DEMOLISHED AREA

The Demolished Area is approximately 900 feet long by 750 feet wide. Within this Area were six buildings (four of which have been demolished). Portions of two buildings are left. The Area is currently paved. Under future construction plans, the remaining buildings are due to be demolished; however, it is not known whether new buildings will be constructed in the Area. It is anticipated that whatever the future building arrangements, the remainder of the Area will continue to be paved. For the purposes of this risk evaluation, Area 2 was further subdivided into three Sub-areas; 2A, 2B, and 2C, to (i) reduce the size of the exposure units evaluated, and (ii) to evaluate the risk from specific sources. A brief description of the Sub-areas follows:

• Sub-area 2A: This is the smallest of the three Sub-areas consisting of the western portionof Area 2 and covers an area of 3.03 acres. The primary chemicals that exceededscreening criteria in this Sub-area were VOCs, TPH, and metals.

• Sub-area 2B: This is the largest of the three Sub-areas consisting of the middle portion ofArea 2 including SWMU 17 and covers an area of 4.48 acres. The primary chemicalsthat exceeded screening criteria in this Sub-area were VOCs, TPH, and metals.

• Sub-area 2C: This is the intermediate sized Sub-area consisting of theeastern/southeastern portion of Area 2 and covers an area of 3.88 acres. The primarychemicals that exceeded screening criteria in this Sub-area were VOCs and TPH.

AREA 3: RETAINED AREA

The Retained Area is approximately 2,500 feet long by 1,200 feet wide. Within this Area are nine buildings, and a large parking lot. The Area is currently paved. Under future construction plans, the majority of the current buildings are due to be retained and the Area will continue to be paved. For the purposes of this risk evaluation, Area 3 was further subdivided into eight Sub-areas; 3A to 3H. A brief description of the Sub-areas follows:

• Sub-area 3A: This Sub-area is trapezoidal and located in the northwestern portion ofArea 3 and covers about 5.25 acres. It extends from Banshee Road on the north to thenorthern edge of Building 42 on the south, and from Area 2C on the west to the middle of


Building 41 on the east. This Sub-area contained the Building 41 tankfarm and the northern portion of the pipeline that extended from the Building 41 tank farm to the Fuel Pits #1, 2, 3, and 4. Tanks have been removed and fuel pits were filled with clean fill and covered with concrete. Also, included in this Sub-area are building/structures #44, #44A, #46, and #49, and along the northern perimeter are railroad spurs and an industrial sewer line. The primary chemicals that exceeded screening criteria in this Sub-area were VOCs, TPH, and metals.

• Sub-area 3B: This Sub-area is rectangular and located on the west side of the southern

portion of Building #2 and covers about 0.68 acres. This Sub-area is bounded on the north by Sub-area 3D, on the west and south by Sub-area 3C, and on the east by Building #2. This Sub-area contains the previous Aviation Gas Refueling Station and past UST #B68. The primary chemicals that exceeded screening criteria in this Sub-area were VOCs and TPH. Industrial sewer has been blocked.

• Sub-area 3C: This Sub-area is a 7-sided polygon in the southwestern portion of Area 3

and covers about 11.91 acres. This Sub-area is bounded on the north by Sub-areas 2A and 2B, on the west by Sub-area 2C and Area 1, on the south by the Airport runway, and on the east by other portions of Area 3. This Sub-area contains Buildings #3, #42, #43, and #45H, the previous Fuel Pits #1 and #2, the previous Building #43 tankfarm and past USTs #B33 – B37, and associated pipelines connecting Fuel Pits #1 and #2 to the previous Building #41 and #43 tank farms, and connecting the two tankfarms together. The primary chemicals that exceeded screening criteria in this Sub-area were VOCs, TPH, and metals.

• Sub-area 3D: This Sub-area is rectangular and consists of the north-central portion of

Area 3 and covers about 10 acres. This Sub-area is bounded on the north by Banshee Road, on the west by Sub-area 3A, on the south by Sub-area 3B and the southern half of Building #2, and on the east by Sub-area #3E. This Sub-area contains the northern half of Building #2, the eastern half of Building #41, and SWMU #22, and along the northern perimeter are railroad spurs and an industrial sewer line. The primary chemicals that exceeded screening criteria in this Sub-area were VOCs, TPH, PAHs, and metals.

• Sub-area 3E: This Sub-area is rectangular and located along the eastern portion of the

northern half of Building #2 and covers about 0.62 acres. This Sub-area is bounded on the north by Banshee Road, on the west by Sub-area 3D, on the south by other portions of Area 3, and on the west by Sub-area 3H. This Sub-area contains SWMU #24, past UST #B24, and along the northern perimeter, railroad spurs. The primary chemicals that exceeded screening criteria in this Sub-area were VOCs, TPH, and metals.

• Sub-area 3F: This Sub-area is rectangular and located at the southwest corner of

Building #1 and covers about 0.35 acres. This Sub-area is bounded on all sides by other portions of Area 3, and contains the southwest corner of Building #1 and past USTs #B20 and B21. The primary chemicals that exceeded screening criteria in this Sub-area were TPHs and metals.


• Sub-area 3G: This Sub-area is rectangular and located at the northeastern portion of Building #1 and covers about 0.45 acres. This Sub-area is bounded on the north by Building #2, on the west by the interior portion of Building #1, on the south by interior portions of Buildings #1 and #3, and on the east by other portions of Area 3. This Sub-area contains past USTs #B22 and #B23. The primary chemicals that exceeded screening criteria in this Sub-area were VOCs, TPH, and metals.

• Sub-area 3H: This Sub-area is rectangular and located in the northeastern portion of Area

3 and covers about 0.72 acres. This Sub-area is bounded on the north by Banshee Road, on the west by Sub-area 3E, on the south by other portions of Area 3, and on the east by Area 4. The primary chemicals that exceeded screening criteria in this Sub-area were VOCs, TPH, metals, PAHs.

AREA 4: POWER PLANT The Power Plant is an area approximately 400 feet long by 300 feet wide. Within this Area, there were two main buildings (Building 5 has been demolished). Portions of flat lot are paved and others have gravel. AREA 5: INDUSTRIAL WATER TREATMENT PLANT The IWTP is an area approximately 240 feet long by 250 feet wide at its longest dimensions. Within this Area, there is one building, aeration tanks, sludge settling and equalization tanks, a sludge holding tank, filter press, and a parking lot. AREA 6: GKN FACILITY The GKN facility is approximately 4,000 feet long by 1,500 feet wide. Within this Area are three main buildings, five smaller buildings, and a large parking lot. The Area is currently paved. For the purposes of this risk evaluation, Area 6 will be further subdivided into four 6A, 6B, 6C, and 6D:

• Sub-area 6A: Buildings 21, 29, and 29A, and all parking lots and open space to the south and west of these buildings;

• Sub-area 6B: Between Buildings 29 and 27, containing Buildings 22, 28, 39;

• Sub-area 6C: Buildings 25 and 27 and all parking lots and open space to the south and within about 450 feet to the east; and

• Sub-area 6D: Parking lots and open areas beginning about 450 feet east of Buildings 25 and 27 and extending to the north, south, and east property lines.

Due to the large size of Area 6 and the presence of buildings that are likely to remain in the foreseeable future, Area 6 was subdivided to ensure that the representative concentrations calculated are as representative of the actual conditions as possible.


This Area formerly owned by Boeing has been sold to GKN Aerospace, who intends to continue manufacturing activities. Currently this Area is used for metal fabrication. As per Boeing’s sale agreement with GKN, the Area has to be cleaned to allow the continuation of non-residential/industrial activities without unacceptable risk. AREA 7: ENGINEERING CAMPUS The Engineering Campus is approximately 1,500 feet long by 1,000 feet wide (at its maximum dimensions). Within this Area are four buildings and large parking lots. Other than the buildings, the entire area is paved. AREA 8: OFFICE COMPLEX NORTH The Office Complex North is an area approximately 800 feet wide by 1,000 feet long. Within this Area are two buildings (220 and 221) separated by a small parking lot. The Area is currently paved, and will likely remain paved in the future. For the purposes of this risk evaluation, Area 8 was further subdivided into three Sub-areas; 8A, 8B, and 8C, to (i) reduce the size of the exposure units evaluated, and (ii) to evaluate the risk from specific sources. A brief description of the Sub-areas follows:

• Sub-area 8A: This Sub-area covers about 4.4 acres and consists of the southern portion of Building 220 and associated parking and access areas along the south and east perimeter of the building. The primary chemicals that exceeded screening criteria in this Sub-area were VOCs and metals.

• Sub-area 8B: This Sub-area covers about 6 acres and consists of the northern portion of

Building 220 and open areas to the west and north of the building including parking, access, and operational areas and vegetated areas along the western and northern perimeter of the property. The primary chemicals that exceeded screening criteria in this Sub-area were VOCs, TPH, PAHs, and metals.

• Sub-area 8C: This Sub-area covers about 5.8 acres and consists of Building 221 and the

associated parking and access areas to the west, north, and east of the building. The primary chemicals that exceeded screening criteria in this Sub-area were VOCs and TPH.

AREA 9: GUN RANGE The Gun Range is an area approximately 600 feet long by 500 feet wide. Within this Area, there are five main buildings and a parking lot.


APPENDIX C

SURVEY COORDINATES FOR MAPPING POINTS


APPENDIX D

ENVIRONMENTAL COVENANT

(To be inserted upon completion)


APPENDIX E

OUTLINE: HEALTH AND SAFETY PLAN


APPENDIX E Outline: Health and Safety Plan

The following outlines the types of information that should be included in a Health and Safety Plan. Information may be added or omitted as applicable to the proposed scope of work.

A. Project Information and Emergency Resources: a brief description of the scope of work, pertinent project information, roles and responsibilities of onsite personnel, contact information, emergency response information, and route to the nearest hospital and/or health clinic.

B. Site Description: relative site information such as property/project limits, current use, access requirements, utilities, known materials stored onsite, and a site map

C. Project Task Breakdown: detailed description of tasks to be performed

D. Hazard Assessment: document potential site hazards (e.g., chemical, environmental, physical), provide safety data sheets (if appropriate)

E. Protective Measures: document appropriate personal protective equipment, safe work zones, site safety equipment, site- and/or project-specific training requirements (e.g., HAZWOPER, equipment operation, etc.)

F. Monitoring Plan and Equipment: identify monitoring to be done during work activities (i.e., air and/or dust monitoring), equipment to be used including proper care and calibration

G. Decontamination and Disposal Methods: identify personal and equipment decontamination procedures and proper disposal of generated wastes

H. Contingency Planning: contingency planning for potential site conditions (e.g., fire, medical emergency, hazardous spill, weather)


APPENDIX F

WORK PLAN FOR FUTURE DRILLING AND/OR WELL INSTALLATION ACTIVITIES

Work Plan for Future Drilling and/or Well Installation Activities Draft 27 July 2016

APPENDIX F Work Plan for Future Drilling and/or Well Installation Activities

27 July 2016 TABLE OF CONTENTS

Page

1. Introduction 1 2. Approach 1 3. Notification of Planned Activities 1 4. Field Activities 2 5. Waste Handling 5 6. Health and Safety 6 7. Reporting 6 References 6

Attachment A - Sample Field Forms

Attachment B - Example Well Development Procedure

Work Plan for Future Drilling and/or Well Installation Activities 27 July 2016 Page 1

1. Introduction This Work Plan for Future Drilling and/or Well Installation Activities at the St. Louis Tract I Facility (the Work Plan) has been prepared to provide guidance and requirements for GKN to follow if such activities are necessary to accommodate their planned project activities in the Notification Area identified in the Soil Management Plan for GKN Technologies and The Boeing Company-Owned Portion of The Tract I Permitted Hazardous Waste Management Facility (SMP), dated August 2016 (Boeing Defense, Space & Security – St. Louis [Boeing], 2016). Specifically, this Work Plan is focused on drilling and/or well installation activities that would not be covered under the guidance and requirements defined in the SMP. 2. Approach At the time that proposed drilling and/or well installation locations are identified, it will be GKN’s responsibility to compare the proposed locations with Figure 1 of the SMP to verify whether notification is required. If notification is not required, GKN may proceed with the drilling and/or well installation activities and their planned project following the guidance for soil management provided in the SMP. If notification is required, GKN should use the guidance and requirements identified in this Work Plan for providing notification and for implementing the planned drilling and/or well installation activities. Work should also be performed in conjunction with the soil management procedures identified in the SMP, where appropriate. It is noted that future activities should follow the most current version of any documents, regulations, or State statutes referenced in this Work Plan, or based on the current state of practice for identified activities. 3. Notification of Planned Activities Once the drilling and/or well locations planned for completion within the Notification Area are identified, the GKN will notify the MDNR. The notification should be in written format and provide sufficient information for MDNR to review why, where, and how the work will being conducted. The notification to MDNR should include, but not be limited to, the following:


A brief summary of why the work is being conducted. A figure showing drilling and/or well locations with the bounds of the Notification Area

depicted. A written or tabular summary providing specific information for the work. Depending on

the planned scope, this may include: method of drilling (e.g., sonic, geoprobe, etc.); depth and diameter of drilling; type of samples to be collected (e.g., geotechnical, soil, water, etc.); where samples will be collected within the borehole or well (i.e., depth); what the samples will be analyzed for (e.g., physical or chemical characteristics); and/or proposed well construction details.

If samples are to be analyzed for site-specific constituents of concern, verification of what the analytical results will be compared to (e.g., Facility-specific comparison values provided in the SMP or target concentrations for groundwater provided in the Focused Corrective Measures Study (CMS) [RAM Group of Gannett Fleming, Inc. (RAM Group), 2014]). This may be dependent upon what data is being collected and for what purpose.

Identification of how the field activities will be documented and reported to MDNR. A schedule of when the planned activities are expected to occur and when a report of

activities will be submitted to MDNR.

The notification must be submitted (electronically when possible) to the MDNR at least 15 working days prior to performing the work. Within 15 working days, MDNR will respond to GKN by phone or e-mail with any questions regarding the scope of work. If verbal and/or written response from MDNR is not received within 15 working days, GKN’s Project Manager will contact MDNR to resolve any issues related to the request and obtain approval within 5 working days of the verbal approval. . If drilling and/or monitoring well locations change significantly from what is provided to MDNR in the initial notification package, GKN shall provide MDNR with a revised figure that depicts the new locations and an explanation for the changed locations. 4. Field Activities UTILITY SURVEY Prior to initiating any field activities, utility clearance for planned drilling and/or well locations will be coordinated with the selected project contractor, as many of the utilities may already be marked and/or de-energized for other planned soil disturbance activities. If locations are in an area not already cleared by the project contractor, the drilling and/or monitoring well locations will be marked onsite using lathe/flags and/or fluorescent paint and a utility location survey will be performed through the use of the Missouri One-Call System. The site will also be viewed for presence of overhead utilities and physical evidence of buried lines or structures (e.g., pavement


cuts and patches, variation in or lack of vegetation, variations in grading, manholes, gas or water service valves, monuments, etc.). DRILLING AND/OR WELL INSTALLATION Drilling may be conducted using Geoprobe, hollow stem auger (HSA), rotosonic, or other method selected to meet the needs of the scope of work. Lithologic logs should be prepared for each drilled borehole based on the visual examination of auger cuttings and drill core. The following information should be recorded on a well boring log: soil description, recovery results, field screening (photoionization detector [PID] readings), location of samples collected within the boring, and depth to water. A sample Well/Test Boring Log form is provided in Attachment A. Wells will be installed following the Missouri Well Construction Rules, defined in the Missouri Code of State Regulations, Title 10, Division 23 by a well driller licensed in the State of Missouri in accordance with The Water Well Drillers’ Act, Sections 256.600 to 256.640 RSMo. The Missouri Well Construction Rules provide guidance on each aspect of well installation including but not limited to: proper locating of wells; casing requirements; construction to exclude contaminants potentially present in the formation; material selection; grouting methodology; well development; and, well completion. If conditions are known to exist at the site that would prevent meeting any well construction requirement, a variance request to the rule will be submitted to the State of Missouri prior to well installation activities. If any well construction requirements cannot be met due to site-specific conditions encountered during field efforts, the reason for the variance will be noted on the well certification form submitted to the MDNR. A Variance Request form can be found on the MDNR’s website. Construction details for each monitoring well will be recorded in a field logbook during installation and subsequently reported on a well installation log. At least 24 hours following installation, each newly installed well will be developed following guidance in the Missouri Well Construction Rules. An example method for well development is provided as a standard operating procedure (SOP) in Attachment B. The pumping method and rate, volume of water removed, observations of groundwater color and clarity, and parameter stabilization measurements obtained during development will be recorded on a well development log. Wells will be allowed to stabilize for a minimum of one week following development before representative groundwater samples are collected. Sample Well Installation Log and Well Development Log forms are provided in Attachment A. Within 60 days of completing well installation activities, the well driller will submit the State-required well certification forms, along with the associated certification fees, to the State as required by Missouri Water Well Drillers’ Act, Section 256.614. A Monitoring Well Certification Record form can be found on the MDNR’s website.


SOIL SAMPLING Sampling methodology and selection of samples for analysis, including quality control (QC) samples, will be determined by GKN based on the purpose of the data to be collected (e.g., geotechnical sampling, constituents of concern, field screening results, etc.). Soil samples for chemical analysis may be collected from acetate liners (if direct-push borings are used) or using a hand-auger and drive hammer equipped with a split-spoon sampler and stainless steel tubes or glass jars. Alternatively, samples collected for geotechnical analysis should follow the current state of practice for sample collection and handling procedures. The sampling method used, field screening data collected, and sample-specific information (e.g., time and date of sample collection, bottle count, analyses sampled for, etc.) will be entered in the field logbook, on field sampling forms, and/or on chain-of-custody forms, as appropriate. Sampling intervals and field screening values should be recorded on the Well/Test Boring Log (sample provided in Attachment A.) Sample containers will be labeled with the project name, sample name, sample matrix, data and time of sample collection, analysis to be performed, preservation information, and the initials of the person collecting the sample. Samples will be packaged in a manner to prevent breakage or contamination and placed on ice in a cooler, if appropriate, for shipment to the contracted laboratory under chain of custody protocol. GROUNDWATER GAUGING Water levels will be collected per the ‘Standard Operating Procedure (SOP) for Groundwater Gauging’ provided in Appendix C of the Quality Assurance Project Plan (QAPP), prepared for the St. Louis Tract I Facility by RAM Group of Gannett Fleming, Inc. (RAM Group), dated 7 April 2010. As a rule of thumb, static water levels should be collected from newly installed monitoring wells prior to collecting groundwater samples or at any other time deemed appropriate to assess water elevations in the subsurface. Water level measurements, measuring point locations, and time and date of collection will be entered in the field logbook and/or on field sampling forms. A sample Groundwater Sampling Record is provided in Attachment A. GROUNDWATER SAMPLING Sampling methodology and selection of samples for analysis will be determined by GKN based on the purpose of the data to be collected (e.g., field parameters, constituents of concern, location and/or depth of samples, etc.). Groundwater samples for chemical analysis, including quality control (QC) samples, should be collected using either low-flow or passive sampling methods following the sample collection, handling, and preservation methods provided in the QAPP (RAM Group, 2010). The sampling method used, field measurements collected, and sample-specific information (e.g., time and date of sample collection, bottle count, analytes sampled for, etc.) will be entered in the field logbook, on field sampling forms, and/or on chain-of-custody forms, as appropriate. A sample Groundwater Sampling Record is provided in Attachment A.


DECONTAMINATION Drill rods, augers and down-hole equipment will be steam cleaned before startup of field operations and after each boring using a high-pressure, high temperature, hot water cleaner. Non-dedicated sampling equipment (e.g., water level meter, pumps, etc.) will be decontaminated prior to and immediately after use at each sampling point or location. Additional details regarding decontamination procedures are provided in Appendix C of the QAPP (RAM Group, 2010). To the extent possible, disposable sampling equipment and supplies will be used. Decontamination of reusable sampling equipment will be conducted prior to and after samples are collected at each sampling location. Passive samplers and/or tubing will be dedicated to each monitoring well during purging and sampling activities. Samplers and tubing will remain in their original packaging until they are ready for use to prevent contamination in the field and will be disposed of after sampling of each well is completed. FINAL SURVEY Once soil borings have been drilled and/or wells have been installed, a final horizontal and vertical survey will be conducted. This survey will include ground surface and top of casing measurement points for newly installed wells, surveyed to the nearest 0.01 foot. The top of casing elevation will be marked for future reference, with the north side of the casing as the default location. Approximate locations for soil borings/samples or other features may also be marked at the surface by field staff using lathe and/or paint for final survey. A Professional Surveyor, licensed in the State of Missouri, will be contracted for this work. 5. Waste Handling Efforts will be made to minimize waste generation. Drill cuttings and well development and decontamination fluids derived during the drilling and/or well installation activities will be containerized in 55-gallon Department of Transportation (DOT)-approved steel drums, labeled, and stored temporarily onsite. Results from soil and groundwater sampling may be used to characterize the solid and liquid wastes to determine appropriate methods for disposal. Disposable materials generated during field activities (i.e., passive samplers, tubing, gloves, paper towels, tyvek, and visqueen) will be collected and contained for proper disposal as municipal solid waste. Hazardous waste shall be handled as specified in Section 4.1.(B) of the SMP.


6. Health and Safety A health and safety plan (HASP) will be prepared by GKN or its contractor selected to implement the work based on the specific worker activities planned and the current sub-surface conditions using the procedures specified in Section 2.0 of the SMP. 7. Reporting A report will be submitted to MDNR documenting the activities completed, identifying the methods used for drilling, well installation, and/or data collection, and summarizing the data collected. The project report should include figures, tables, and/or graphs, where appropriate, to summarize the work completed and the data collected. Field documentation, including well boring, installation, and/or development logs, should be included as appendices along with analytical data reports. The report will be submitted following the schedule provided by GKN in the notification package. References 1. Boeing Defense, Space & Security – St. Louis (Boeing), 2016. Soil Management Plan for

GKN Technologies and The Boeing Company-Owned Portion of The Tract I Permitted Hazardous Waste Management Facility. August.

2. RAM Group of Gannett Fleming, Inc. (RAM Group), 2014. Focused Corrective Measures Study, Boeing Tract 1, Hazelwood, Missouri. July 22.

Work Plan for Future Drilling and/or Well Installation Activities 27 July 2016

ATTACHMENT A

Sample Field Forms

of

ft. Datum

Item

Truck Tripod Cat‐Head Safety Bentonite

ATV Geoprobe Winch Doughnut Polymer

Track Air Track Roller Bit Automatic None

Skid Cutting Head Drilling Notes:

Riser Pipe

Open End Rod Screen

Thin Wall Tube Filter Sand

Undisturbed Sample Cuttings

Split Spoon Sample Grout

Geoprobe Concrete BORING NO.

Bentonite Seal

Dilatancy: R ‐ Rapid S ‐ Slow N ‐ None Plasticity: N ‐ Nonplastic L ‐ Low M ‐ Medium H ‐ High

Toughness: L ‐ Low M ‐ Medium H ‐ High Dry Strength: N ‐ None L ‐ Low M ‐ Medium H ‐ High V ‐ Very High

Rig Make & Model

Boring Location

Field Test

Type

Inside Diameter (in.)

Hammer Weight (lb.)

Hammer Fall (in.)

Elapsed

Time (hr.)

Sampler

WELL/TEST BORING LOG

CLIENT

CONTRACTOR

Elevation

DRILLER

PROJECT PROJECT FILE NO.

PROJECT MGR.

Hammer Type Drilling Mud Casing Advance

Stre

ngt

h

Gravel

Type Method Depth

Sand

% F

ine

s

Dila

tan

cy

Tou

ghn

ess

Pla

stic

ity

% C

oar

se

% C

oar

se

% F

ine

% F

ine

% M

ed

ium

LOCATION

Well DiagramDepth (ft.)

Sampler

Blows per 6

in.

Sample No.

& Recovery

(in.)

Core BarrelCasing

0

Water

Water Level Data

Depth in feet to:

Bottom of

Casing

Bottom of

Hole

Date Time

1

BORING NO.

Page

Sample

Depth (ft.)

Stratum

Change (ft.)

USCS

Symbol

DATE FINISHED

FIELD REP.

DATE STARTED

U

Visual‐Manual Identification & Description (density/consistency, color, GROUP NAME & SYMBOL, maximum particle size*, structure,

odor, moisture, optional descriptions, geologic interpretation)

O

Sample ID Well Diagram

Field Tests

Summary

G

S

T

Overburden (Linear ft.)

Rock Cored (Linear ft.)

Number of Samples

__________

NOTE: Soil identifications based on visual‐manual methods of the USCS system.

*NOTE: Maximum Particle Size is determined by direct observation within the limitations of sampler size.

Form 2001 USCS p.1

of

NOTES: FILE NO.

NOTE: Soil identifications based on visual‐manual methods of the USCS system.

*NOTE: Maximum Particle Size is determined by direct observation within the limitations of sampler size.

Tou

ghn

ess

Sample No.

& Recovery

(in.)

Well

Diagram

Stratum

Change (ft.)

USCS

Symbol

% C

oar

se

% F

ine

WELL/TEST BORING LOG

Visual‐Manual Identification & Description (density/consistency, color, GROUP NAME & SYMBOL, maximum particle size*, structure,

odor, moisture, optional descriptions, geologic interpretation)

BORING NO.

Depth (ft.)Sample

Depth (ft.)

Sampler

Blows per 6

in.

Field Test

Stre

ngt

h

Dila

tan

cy

Gravel

Pla

stic

ity

Page

Sand

% F

ines

% F

ine

% M

ediu

m

% C

oar

se

BORING NO.

Form 2001 USCS p.2

WATER LEVEL

Ground El. ft Location

El. Datum

SOIL/ROCK BOREHOLE Type of protective cover/lock

CONDITIONS BACKFILL

Height/Depth of top of guard pipe/roadway box ft

above/below ground surface

Height/Depth of top of riser pipe ft

above/below ground surface

Type of protective casing:

Length ft

Inside Diameter in

Depth of bottom of guard pipe/roadway box ft

Type of riser pipe:

Inside diameter of riser pipe in

Type of backfill around riser

Diameter of borehole in

Depth to top of well screen ft

Type of screen

Screen gauge or size of openings in

Diameter of screen in

Type of backfill around screen

Depth of bottom of well screen ft

Bottom of Silt trap ft

Depth of bottom of borehole ft

ft + ft + ft = ft

CONTRACTOR

FIELD REP.

PROJECT

LOCATION

CLIENT

PROJECT MGR.

Guard Pipe

PROJECT FILE NO.

L3

L2

L1

WELL INSTALLATION LOGWell No.

Boring No.

(Bottom of Exploration)

(Numbers refer to depth from ground surface in feet) (Not to Scale)

COMMENTS:

DATE INSTALLED

DRILLER

Riser Pay Length (L1) Length of screen (L2) Length of silt trap (L3) Pay length

Roadway Box

Concrete

Type of Seals Top of Seal (ft) Thickness (ft)

Bentonite Seal

Form 2007

of

ELEVATION

gallons

feet

feet

NTU

gallons

feet

feet

NTU

Estimated Volume of Water Lost During Drilling:

Comments:

Volume of Water Removed:

Turubitiy of Water After Development:

Depth to Water After Development:

Comments:

Comments:

Turubitiy of Water Before Development:

Comments:

Depth to Well Bottom After Development:

Comments:

Comments:

Comments:

Depth to Water Before Development:

Depth to Well Bottom Before Development:

Page 1 1

Comments:

Comments:

Method of Removal (bailing, pumping):

PROJECT

LOCATION

WELL DEVELOPMENT FORM

FIELD REP.

PROJECT FILE NO.

CLIENT

Well No.

CONTRACTOR

PROJECT MGR.

DATE

Form 3006

of

Remarks: (ie: field filtrations, persons communicated with at site, etc.)

PA

RA

MET

ERS

Time

Turbidity (NTU)

VOCs

Instrument Used to Monitor Field

Parameters

Cleaning Procedure

Metals

Well ID

Depth to Water from Reference Mark (ft.)

Time

Depth to Product (ft.)

TIM

E SA

MP

LES

TAK

EN

Time Purging Stopped

Sampling Device

Odor

Standing Water Depth (ft.)

PROJECT MGR.

FIELD REP

DATE

PROJECT FILE NO.

GROUNDWATER SAMPLING RECORD

CONTRACTOR

Color

Reference Mark

GROUNDWATER SAMPLING INFORMATION

PROJECT

LOCATION

CLIENT

Page

Field Measured Depth Of Well (ft.)

Depth Of Well (ft.) per Log

Purging Device

Volume of Sampling Device/Pump Capacity

Cleaning Procedure

Volume Of Water In Well (gallons/liters)

Inside Diameter (in.)

Volume Removed

Time Purging Started

TPH

Volume purged/Gals

Temp, °F

Conductivity (umhos/cm)

Dissolved Oxygen (mg/L)

pH

ORP (mV)

Drawdown Ft

Work Plan for Future Drilling and/or Well Installation Activities 27 July 2016

ATTACHMENT B

Example Well Development Procedure

EXAMPLE: WELL DEVELOPMENT STANDARD OPERATING PROCEDURE (SOP) This procedure is for the development of groundwater monitoring wells that have been installed in overburden or bedrock interface formations. Before a newly constructed well can be used for water‐quality sampling, measuring water levels, or aquifer testing, it must be developed. Well development refers to the procedure used to clear the well and formation around the screen of fine‐grained materials (sands, silts, and clays) produced during drilling or naturally occurring in the formation. Well development is completed to remove fine‐grained materials from the well but in such a manner as to not introduce fines from the formation into the sand pack. Well development continues until the well responds to water level changes in the formation (i.e., a good hydraulic connection is established between the well and formation) and the well produces clear, sediment‐free water to the extent practical. After 24 hours following installation of the filter pack and annular seal, each newly installed well will be developed by a combination of mechanical surging and over‐pumping using bailers, inertial pumps with surge blocks, or mechanical submersible pumps. The well development procedures presented below are the recommended standards. However, due to variations in conditions, changes in these well development standards may be necessary in order to facilitate the successful completion of developing the monitoring well.

Procedure:

1. Don appropriate safety equipment.

2. Attach appropriate pump and lower tubing into well.

3. Turn on pump. Groundwater will be removed until a minimum of one times the volume of water added during drilling or well installation activities has be removed, if feasible.

4. Surging will be performed by raising and lowering the pump in the well to open and close the check valve in the pump several times to pull fine‐grained material from the well.

5. Collect the groundwater sample in a glass jar to determine relative turbidity, and measure and record the temperature, pH, and specific electrical conductance.

6. The fourth and fifth steps will be repeated until groundwater is relatively silt‐free; no further change is noted; and the temperature, pH, and specific conductance readings have stabilized to within 10 percent for three consecutive readings at regular volume intervals (e.g., 1‐gallon intervals) or until six additional well volumes have been removed, whichever occurs first. If possible, a turbidity less than 50 nephelometric turbidity units (NTUs) will be obtained in addition to the achievement of stable analytical parameters..

7. The developing equipment will be raised two feet and then Steps 4 and 5 will be repeated.

8. Step 6 will be repeated until entire well screen has been developed.

9. If the well purges dry before meeting well development criteria, the well will be developed by bailing it dry a minimum of two times over a period of 48 hours.


APPENDIX G

FACILITY SPECIFIC COMPARISON VALUES (FSCVs)

Identify extent of impact

Estimate distance to downgradient property boundary

Step 1

Select DAF from Step 4 Table

Select concentration protective of GW from Table 1 for covered soil

Multiply selected concentration from Step 6 by DAF from Step 4

Select minimum of the soil FSCV in Steps 7 & 9.

This is the soil FSCV.

Compare soil FSCV with representative soil concentration

Figure G-1 Steps to Select Facility Specific Comparison Value (FSCV)

Step 2

Step 3

Step 4

Step 5

Step 6

Step 7

Step 8

Step 9

Step 10

Step 6 (a)

Step 6 (b)

October 2015/MJHV

NO

YES

RAM Group (054517)

Identify COCs

Distance (ft) DAF

50 1.4

100 3.5

150 7.2

200 12.3

250 18.9

300 27.0

500 74.1

1,000 295

Multiply selected concentration from Step 6(a) by DAF from Step 4.

This is the soil FSCV protective of GW.

Select concentration protective of GW from Table 1 for uncovered soil

Step 4 DAF Table

Linearly interpolate if necessary.

For Construction Worker target levels refer to Table 2 applicable only during the construction period for dermal exposure to soil.

Abbreviations:DAF: Dilution Attenuation FactorCOC: Chemical of ConcernFSCV: Facility Specific Comparison ValueGW: GroundwaterIVI: Indoor Vapor Intrusion

Is soil gas concentration

available?

Compare FSCV from Step 7 with representative soil concentration and

FSCV soil gas concentration with representative soil gas concentration

from Table 1.

Select concentration protective of IVI from Table 1.

This is the FSCV protective of IVI.

YES

NO

Step 11

Uncovered Soil Covered Soil Soil Gas Concentration

Soil Concentration

(mg/m3) (mg/kg)

Arsenic 7440-38-2 0.34 0.81 NA N/AAluminum 7429-90-5 35,339.96 83,362.16 NA N/AAntimony 7440-36-0 0.32 0.75 NA N/ABarium 7440-39-3 97.07 228.98 NA N/ABeryllium 7440-41-7 3.72 8.78 NA N/ACadmium 7440-43-9 0.44 1.04 NA N/AChromium (Total) 7440-47-3 212,010.39 500,103.72 NA N/AChromium, hexavalent 18540-29-9 0.00 0.00 NA N/ACobalt 7440-48-4 53.25 125.60 NA N/ACopper 7440-50-8 53.91 127.17 NA N/AManganese 7439-96-5 1.15 2.72 NA N/AMercury 7439-97-6 0.12 0.29 0.04 4.90E+00Nickel 7440-02-0 7.68 18.12 NA N/ASilver 7440-22-4 0.50 1.18 NA N/ASelenium 7782-49-2 0.31 0.72 NA N/AThallium 7440-28-0 0.17 0.40 NA N/AVanadium 7440-62-2 101.31 238.99 NA N/AZinc 7440-66-6 366.35 864.18 NA N/A

1,3,5-Trimethylbenzene 108-67-8 4.10 9.67 NA N/A1,2,4-Trimethylbenzene 95-63-6 0.52 1.23 1.02 1.20E+021,2-Dichlorobenzene 95-50-1 13.08 30.85 29.21 6.88E+032-Hexanone 591-78-6 0.04 0.10 4.38 1.06E+03Acetone 67-64-1 5.29 12.49 4,527.81 1.02E+06Benzene 71-43-2 0.04 0.10 0.52 1.66E+01Bromomethane 74-83-9 0.01 0.02 0.73 2.12E+00Carbon disulfide 75-15-0 1.25 2.95 102.24 2.27E+02Chlorobenzene 108-90-7 1.34 3.17 7.30 6.54E+02Chloroprene 126-99-8 0.00 0.00 0.01 1.99E-02Chloroethane 75-00-3 32.03 75.55 1,460.58 4.16E+03Chloroform 67-66-3 0.16 0.39 0.18 2.06E+00Dichloroethylene, cis-1,2- 156-59-2 0.17 0.41 NA N/ADichloroethylene, trans -1,2- 156-60-5 0.25 0.59 NA N/ADichlorodifluoromethane 75-71-8 0.90 2.12 14.61 3.97E+00Dichloroethane, 1,1- 75-34-3 0.01 0.01 2.56 1.95E+01Ethylbenzene 100-41-4 17.77 41.92 1.64 1.09E+02Isopropylbenzene 98-82-8 17.80 42.00 58.42 4.17E+03m/p-Xylene 106-42-3 4.07 9.59 14.61 9.39E+02Methyl isobutyl ketone 108-10-1 1.15 2.70 438.18 6.29E+04Methyl ethyl ketone (2-Butanone) 78-93-3 2.79 6.59 730.29 1.33E+05Methylene chloride 75-09-2 0.01 0.02 87.64 8.30E+02Naphthalene 91-20-3 1.74 4.11 0.12 4.94E+02n-Butylbenzene 104-51-8 83.71 197.47 NA N/An-Propylbenzene 103-65-1 30.39 71.69 146.06 1.33E+04o-Xylene 95-47-6 4.14 9.78 14.61 1.28E+03sec-Butylbenzene 135-98-8 150.45 354.89 NA N/At-Butylbenzene 98-06-6 39.08 92.18 NA N/A

Table G-1Facility Specific Soil and Soil Vapor Comparison Values

Boeing Tract 1, St. Louis, Missouri

(mg/kg)

Protective of

VOLATILE ORGANIC COMPOUNDS

METALS

Groundwater Indoor VaporChemicals of Concern CAS No.

October 2015/MJHV 1 of 2 RAM Group (054517)

Uncovered Soil Covered Soil Soil Gas Concentration

Soil Concentration

(mg/m3) (mg/kg)

Table G-1Facility Specific Soil and Soil Vapor Comparison Values


(mg/kg)

Protective of Groundwater Indoor Vapor

Chemicals of Concern CAS No.

Toluene 108-88-3 13.44 31.70 730.29 3.07E+04Tetrachloroethylene 127-18-4 0.03 0.07 5.84 3.89E+01Trichloroethylene 79-01-6 0.02 0.04 0.29 2.28E+00Vinyl acetate 108-05-4 0.23 0.54 29.21 6.66E+02Vinyl chloride 75-01-4 0.00 0.01 0.93 1.12E+00Xylene 1330-20-7 218.16 514.60 14.61 1.28E+03

Acenaphthene 83-32-9 339.71 801.33 NA N/AAcenaphthylene 208-96-8 66.22 156.19 NA N/AAnthracene 120-12-7 8839.14 20850.33 NA N/AAroclor 1254 11097-69-1 0.29 0.68 NA N/ABenzo[g,h,i] perylene 191-24-2 2354.21 5553.26 NA N/ABenzo[a]anthracene 56-55-3 0.04 0.10 NA N/ABenzo[a]pyrene 50-32-8 6.61 15.59 NA N/ABenzo[b]fluoranthene 205-99-2 1.15 2.70 NA N/ABenzo[k]fluoranthene 207-08-9 11.24 26.51 NA N/ACarbazole 86-74-8 5.04 11.89 NA N/AChrysene 218-01-9 0.04 0.11 NA N/ADibenzo[a,h]anthracene 53-70-3 0.47 1.12 NA N/AFluoranthene 206-44-0 936.05 2208.00 NA N/AFluorene 86-73-7 670.32 1581.21 NA N/AHexachloroethane 67-72-1 0.02 0.05 NA N/AIndeno[1,2,3-cd]pyrene 193-39-5 0.86 2.03 NA N/APhenanthrene 85-01-8 59.63 140.65 NA N/APyrene 129-00-0 2935.39 6924.18 NA N/A

1,1,2-Trichloro-1,2,2-trifluoroethene 76-13-1 772.79 1822.90 4,381.75 2.43E+031,2,3-Trimethylbenzene 526-73-8 0.36 0.84 0.73 1.24E+02Cyanide, total 57-12-5 2.38 5.62 NA N/AMethyl tert butyl ether (MTBE) 1634-04-4 0.01 0.03 15.73 4.99E+02p-Isopropyltoluene 99-87-6 101.55 239.55 NA N/ADichloroethylene, 1,1- 75-35-4 0.02 0.04 29.21 5.04E+01Notes:mg/kg: milligrams per kilogrammg/m3: milligrams per cubic meterNA: Not availableN/A: Not applicable*Soil vapor concentration will get precedence over soil concentrations, if both are available.

OTHER CHEMICALS

SEMIVOLATILE ORGANIC CHEMICALS


Soil Up to Depth of Construction

(mg/kg)

Arsenic 7440-38-2 7.03E+02Aluminum 7429-90-5 2.32E+06Antimony 7440-36-0 6.88E+03Barium 7440-39-3 1.77E+06Beryllium 7440-41-7 8.28E+04Cadmium 7440-43-9 9.37E+03Chromium (Total) 7440-47-3 NAChromium, hexavalent 18540-29-9 3.06E+04Cobalt 7440-48-4 7.53E+02Copper 7440-50-8 1.03E+05Manganese 7439-96-5 1.42E+05Mercury 7439-97-6 2.08E+02Nickel 7440-02-0 3.17E+05Silver 7440-22-4 3.23E+05Selenium 7782-49-2 1.29E+04Thallium 7440-28-0 2.58E+01Vanadium 7440-62-2 2.40E+05Zinc 7440-66-6 7.74E+05

1,3,5-Trimethylbenzene 108-67-8 2.58E+041,2,4-Trimethylbenzene 95-63-6 4.46E+031,2-Dichlorobenzene 95-50-1 9.15E+042-Hexanone 591-78-6 7.71E+03Acetone 67-64-1 2.08E+06Benzene 71-43-2 6.70E+03Bromomethane 74-83-9 1.69E+03Carbon disulfide 75-15-0 1.64E+05Chlorobenzene 108-90-7 1.97E+04Chloroprene 126-99-8 1.02E+04Chloroethane 75-00-3 6.37E+06Chloroform 67-66-3 1.46E+04Dichloroethylene, cis-1,2- 156-59-2 5.16E+03Dichloroethylene, trans -1,2- 156-60-5 5.16E+04Dichlorodifluoromethane 75-71-8 5.67E+04Dichloroethane, 1,1- 75-34-3 1.48E+05Ethylbenzene 100-41-4 8.55E+04Isopropylbenzene 98-82-8 1.28E+05m/p-Xylene 106-42-3 5.67E+04Methyl isobutyl ketone 108-10-1 1.86E+05Methyl ethyl ketone (2-Butanone) 78-93-3 1.04E+06Methylene chloride 75-09-2 1.49E+04Naphthalene 91-20-3 7.17E+03n-Butylbenzene 104-51-8 1.29E+05n-Propylbenzene 103-65-1 1.51E+05o-Xylene 95-47-6 5.67E+04sec-Butylbenzene 135-98-8 2.58E+05

METALS

VOLATILE ORGANIC COMPOUNDS

Table G-2Facility Specific Soil Comparison Values for Construction Worker




Soil Up to Depth of Construction

(mg/kg)

Table G-2Facility Specific Soil Comparison Values for Construction Worker



t-Butylbenzene 98-06-6 2.58E+05Toluene 108-88-3 1.94E+05Tetrachloroethylene 127-18-4 9.63E+03Trichloroethylene 79-01-6 6.41E+02Vinyl acetate 108-05-4 1.21E+05Vinyl chloride 75-01-4 2.45E+03Xylene 1330-20-7 5.67E+04

Acenaphthene 83-32-9 1.11E+05Acenaphthylene 208-96-8 1.17E+05Anthracene 120-12-7 5.57E+05Aroclor 1254 11097-69-1 3.63E+01Benzo[g,h,i] perylene 191-24-2 5.83E+04Benzo[a]anthracene 56-55-3 1.78E+03Benzo[a]pyrene 50-32-8 1.78E+03Benzo[b]fluoranthene 205-99-2 1.78E+03Benzo[k]fluoranthene 207-08-9 1.78E+04Carbazole 86-74-8 7.74E+04Chrysene 218-01-9 1.78E+05Dibenzo[a,h]anthracene 53-70-3 1.78E+02Fluoranthene 206-44-0 7.43E+04Fluorene 86-73-7 7.43E+04Hexachloroethane 67-72-1 1.30E+03Indeno[1,2,3-cd]pyrene 193-39-5 1.78E+03Phenanthrene 85-01-8 5.83E+04Pyrene 129-00-0 7.74E+04

1,1,2-Trichloro-1,2,2-trifluoroethene 76-13-1 1.53E+071,2,3-Trimethylbenzene 526-73-8 3.19E+03Cyanide, total 57-12-5 NAMethyl tert butyl ether (MTBE) 1634-04-4 6.33E+05p-Isopropyltoluene 99-87-6 3.23E+05Dichloroethylene, 1,1- 75-35-4 6.41E+04Notes:mg/kg: milligrams per kilogram NA: Not calculated as toxicity value not available.Concentrations > 1 x106 mg/kg indicate chemical is not of concern as even pure product will result in acceptable risk.

OTHER CHEMICALS

SEMIVOLATILE ORGANIC CHEMICALS



APPENDIX H

OUTLINE: WORK PLAN FOR CHARACTERIZATION AND/OR REMEDIATION ACTIVITIES


APPENDIX H Outline: Work Plan for Characterization and/or Remediation Activities

The following outlines the types of information that should be included in a work plan for planned soil disturbance characterization and/or remedial action. Information may be added or omitted as applicable to the proposed scope of work.

A. Scope of Work: Provide a detailed explanation of the work to be conducted, including site plans, figures, and/or construction information. Include the approximate number of samples to be collected and analyzed, including the collection and analytical procedures.

B. Schedule of Activities: Schedule should include the estimated start date, the project duration, and the proposed days and hours of operation.

C. Work Areas: Define the planned lateral and vertical extents of the proposed work.

D. Access: Identify existing and/or needed access agreements, facility-specific security procedures, access routes to proposed work areas, etc.

E. Staging Area(s): Identify the secure staging area for all equipment, employees, and deliveries.

F. Utility Information: Identify active above and below ground utility lines and requirements for contacting Missouri One-Call for a public utility locate prior to initiating field activities.

G. Road Work Requirements: Proposed road work and traffic management plans, including requirements for right-of-way permits.

H. Existing Data Review: Identify available information as pertinent to the scope of work (e.g., depth to water, constituents of concern, location-specific hazards, etc.).

I. Environmental Practices: Provide existing environmental data, subsurface conditions, health and safety, reference to the project Quality Assurance Project Plan (QAPP) (see reference in Appendix A), engineering controls, housekeeping, preventative maintenance, decontamination, erosion control, etc. as they pertain to the scope of work.

Exhibit D

List of Leases, Easements, and Other Encumbrances

[To be prepared by Boeing]

[DATE]

[Holder of Encumbrance]

[Address of Holder]

RE: Notice of Environmental Covenant

Dear [Holder of Encumbrance]:

[Owner/Transferee] is the owner of certain real property commonly known and numbered as The Boeing Company, Tract 1, 153 & 163 James S. McDonnell Boulevard and 5220, 5230, & 5240 Banshee Road, Hazelwood, MO 63042, shown on the site map attached hereto as Exhibit A, and legally described as shown in the attached Exhibit B (the “Property”). You have been identified as the holder of a lease, easement, or other encumbrance affecting the Property.

The Property is subject to a Missouri Hazardous Waste Management Facility Permit, Permit Number MOD 000 818 963, dated [Insert Date of Re-Issued Permit] (“Permit”). The Permit requires entry of an Environmental Covenant for the Property, imposing certain activity and use limitations. This letter gives you notice that the Property is or will be subject to the Environmental Covenant and the activity and use limitations imposed thereby. To obtain a copy of the Environmental Covenant, please contact:

Mark H. Allen, P.E. Environment, Health & Safety The Boeing Company Mail Code 055-T487 5800 Woolsey Canyon Road Canoga Park, CA 91304-1148 818-620-5986 office [email protected]

This notification is purely informational. Should you need anything further regarding this notice, please contact the undersigned.

Sincerely,

[Signatory Name]

Attachments: Exhibit A—Property Map

mailto:[email protected]

Exhibit B—Property Legal Description

draft copy – do not file boeing property—boeing draft€¦ · 08/09/2017 · the boeing...

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