certified return receipt requested subject: individual...

May 12, 2014

CERTIFIED – RETURN RECEIPT REQUESTED

Mr. Charlie Coleman Mr. Joel Chavez

EPA Region VIII DEQ

Montana Office Remediation Division

10 West 15th Street, Suite 3200 P.O. Box 200901

Helena, MT 59626-0096 Helena, Montana 59620-0901

Subject: Individual Site Investigation Reports (ISIRs) for facility polygons WGAL-003.29

and LTCK-017.01

Dear Gentlemen:

Please find enclosed two copies each of the Individual Site Investigation Reports (ISIRs) for

facility polygons WGAL-003.29 located within the West Galen Expansion Area and LTCK-

017.01 located within RDU 2 – Lost Creek. The attached ISIRs summarize data collected under

the Agency-approved Facility Sampling and Analysis Memorandum and identify appropriate

remedial requirements and performance standards for these facilities in accordance with the

ARWW&S OU ROD and Final Vegetation Management Plan (VMP). The attached ISIRs have

also been revised as identified in preliminary Agency comments and as discussed in the February

26, 2014 technical meeting between Atlantic Richfield and Agency representatives.

Please call me at (406) 723-1813 if you have any questions.

Sincerely,

Shannon Dunlap

Operations Project Manager

cc: Julie DalSoglio/EPA – (w/o enc.)

Joe Vranka/EPA – (w/o enc)

Andy Lensink/EPA – (1 CD)

Katherine Haque-Hausrath/DEQ – (1 CD)

Gunnar Emilsson/CDM

Ken Brockman/BOR

Connie Ternes-Daniels/ADLC – (1 CD)

Ron Halsey/Atlantic Richfield – (email w/o enc.)

Marc Ferries/Atlantic Richfield – (email w/o enc.)

Roy Thun/Atlantic Richfield – (email – w/o enc.)

Charlie Coleman/Joel Chavez

Kevin Bethke/TREC

John Davis/Poore, Roth and Robinson – (email – w/o enc.)

Duane Logan/Pioneer

File: 72.04.110.1 - RDU16 (w/certs) (w/o enc.)

72.04.130.16 (w/o enc.)

Library: 1 hard copy / 1 electronic copy

Chron. (w/o enc.)

Anaconda Smelter NPL Site

Old Works/East Anaconda Development Area Operable Unit; and

Anaconda Regional Water, Waste and Soils Operable Unit

Facilities Sampling

PRLU (WGAL-003.29)

Individual Site Investigation Report (ISIR)

Prepared for:

Atlantic Richfield Company

317 Anaconda Road

Butte, Montana 59701

May 2014

WGAL-003.29 ISIR

Anaconda Smelter NPL Site Page i

Z:\Current_Projects\2103_AR_MT_ARWW\2103-Site_Wide_Support\Sitewide Design Issues\Facilities\2014\ISWP_Resubmittals\27-WGAL-003_29_ISIR\Facilities ISIR WGAL-003_29.doc

TABLE OF CONTENTS

1.0 INTRODUCTION AND PROJECT DESCRIPTION ......................................................... 1

1.1 Purpose and Objectives ............................................................................................ 1

1.2 Project Organization ................................................................................................. 1

1.3 Site Description ........................................................................................................ 1

2.0 PROJECT ACTIVITIES ...................................................................................................... 2

2.1 Description of Project Activities .............................................................................. 2

2.2 Sample Location Documentation ............................................................................. 2

2.2.1 Sample Labeling ............................................................................................ 2

2.2.2 Field Documentation ..................................................................................... 2

2.3 Analytical methodology ........................................................................................... 2

2.4 SAP Deviations ........................................................................................................ 3

3.0 REMEDIAL ACTION OBJECTIVES AND REQUIREMENTS ....................................... 3

4.0 SITE CHARACTERIZATION ............................................................................................ 3

4.1 Previous Investigations ............................................................................................. 3

4.2 2010 Facility Sampling ............................................................................................ 3

4.3 Analysis .................................................................................................................... 4

4.4 Recommendations .................................................................................................... 4

5.0 REFERENCES .................................................................................................................... 6

WGAL-003.29 ISIR

Anaconda Smelter NPL Site Page ii


LIST OF TABLES

Table 1 - 2010 Facility Sampling Data Summary Table

Table 2 - Soil Analytical Requirements

Table 3 - Sample Pit Location

LIST OF FIGURES

Figure 1: Vicinity Map – Facilities Sampling and Analysis

Figure 2: Facility Sampling PRLU Polygon WGAL-003.29

LIST OF APPENDICES

APPENDIX A: LABORATORY DATA

Appendix A.1 Ashe Analytics Data

Appendix A.2 MSE, Inc. Data

APPENDIX B: SAMPLE CHAIN-OF-CUSTODIES

Appendix B.1 Ashe Analytics Data

Appendix B.2 MSE, Inc. Data

APPENDIX C: FIELD LOGS

WGAL-003.29 ISIR

Anaconda Smelter NPL Site Page 1


1.0 INTRODUCTION AND PROJECT DESCRIPTION

1.1 Purpose and Objectives

The Facilities designation for various polygons within the ARWW&S OU was initially used as

an overarching category for regions where the Land Reclamation Evaluation System (LRES)

protocol and/or remedial logic may not have been appropriate or may require modifications

because of past or present activities within the specific area. Sampling was performed within

individual Facility areas, as permitted by landowner access, to better characterize smelter related

impacts and determine remedial requirements, as appropriate. The goal was to obtain sufficient

soils data to determine the extent and magnitude of soil arsenic concentrations in comparison to

the appropriate human health arsenic action levels. In some instances, sampling was proposed to

determine if Superfund obligations are present or whether designation of the area as No Further

Action is appropriate.

This facility was sampled under the Agency-approved Facilities Sampling and Analysis

memorandum and is located in West Galen Expansion Area 1 of the Anaconda Regional Water,

Waste and Soils (ARWW&S) Operable Unit (OU) at the Anaconda Smelter NPL site. This ISIR

summarizes the Remedial Action Objectives (RAO’s), reviews data and observations from

current and previous investigations, evaluates the need for remedial action, and identifies

appropriate performance standards for Preliminary Land Remediation Unit (PRLU) polygon

WGAL-003.29 in accordance with the Record of Decision (ROD) (EPA, 1998) and Final

Vegetation Management Plan (VMP) (Atlantic Richfield, 2013) for the ARWW&S OU.

1.2 Project Organization

Atlantic Richfield’s designated representative; TREC, Inc. in conjunction with EPA oversight

personnel was responsible for determining the location of the soil sample pits, performing the

excavation of the sample pits and collecting the soil samples. Prior to sampling activities,

appropriate landowners were contacted to facilitate access to the site. TREC reviewed the data

with respect to the remedial action requirements and developed this ISIR.

1.3 Site Description

WGAL-003.29 is a 5 acre privately owned former gravel pit located at the southwest intersection

of Galen Road and Upper Racetrack Road (See the Facilities Vicinity Map provided as Figure 1).

Gravel excavated from the pit was most likely used for the construction of Galen Road. Based

on current land use, the recreational/open space/agricultural action level of 1,000 mg/kg for

surface soil arsenic is appropriate for areas within this facility. No previous sampling locations

existed within the facility. Therefore, two locations were sampled under the Facility Sampling

and Analysis Memorandum to further characterize potential smelter related impacts at the site

and assist in evaluation of remedial requirements.

WGAL-003.29 ISIR



2.0 PROJECT ACTIVITIES

2.1 Description of Project Activities

Sampling locations under the Facilities Sampling and Analysis Memorandum were identified to

better characterize smelter related impacts and determine remedial requirements, as appropriate.

All sample pits were excavated by hand. The sample crew typically consisted of a 2 person crew

accompanied by an Agency representative. All field data and analytical samples were collected

as directed by the Facilities Sampling and Analysis Memorandum and documented in the Field

Log book. Upon the end of each sampling day, the sample crew would complete the Chain-of-

Custodies for the samples. The samples were then delivered to the laboratories within a few

days following sample collection. After samples were collected, each test pit was backfilled by

hand but not reseeded. Care was taken during all phases of the sampling effort to minimize

damage to the existing vegetation.

2.2 Sample Location Documentation

2.2.1 Sample Labeling

Sample locations were labeled by location and depth interval according to the list provided in the

Facilities Sampling and Analysis Memorandum. Depth intervals were labeled as follows:

0 to 2 inches (A interval; surface sample);

2 to 6 inches (B interval);

0 to 6 inches (C interval); and

6 to 12 inches (D interval).

Location labels generally followed the format of FAC for Facilities sampling followed by a two

digit year identifier indicating the year sampled followed by a sequential number. An example

of a sample label is as follows (FAC-10-101A). Figure 2 shows the final locations of the sample

points overlaid on a basemap.

2.2.2 Field Documentation

A field log book was maintained during this sampling investigation. Copies of the field logs are

included as Appendix C. The original field log books for the facilities sampling event are

located in the offices of TREC, Inc. in Bozeman, Montana.

2.3 Analytical methodology

Table 2 presents the analytical methods used for sample analysis. Quantitative laboratory

measurements include arsenic, cadmium, copper, lead, zinc and pH for all samples. Table 2 of

the Facilities Sampling and Analysis Memorandum (Atlantic Richfield, 2010) provides

additional detail on the analytical method used for analysis of these parameters. All analyses are

WGAL-003.29 ISIR



consistent with the Clark Fork River Superfund Site Investigation Lab Analytical Protocols (CFR

SSI LAP) and Quality Assurance Project Plan (QAPP) (PTI, 1992b) unless otherwise noted.

2.4 SAP Deviations

No SAP deviations were noted.

3.0 REMEDIAL ACTION OBJECTIVES AND REQUIREMENTS

Remedial requirements for impacted soils that are applicable to areas within the ARWW&S OU

are identified in the ROD and FDRs/RAWPs. Design criteria relevant to “facility” areas

identified in this plan include:

Reduce arsenic concentrations at the surface to below human health arsenic action levels

– 1,000 mg/kg for open space/agriculture/recreation, 500 mg/kg for commercial/

industrial areas, 250 mg/kg for residential areas and 2,500 mg/kg for steep slope areas in

Smelter Hill RDUs 3 and 14 where access restrictions are in place through Atlantic

Richfield ownership or restrictive covenants.

High arsenic area – In areas of good vegetation (i.e. Dutchman) or of beneficial use (i.e.

historic areas) that are owned by Atlantic Richfield or a government entity and exceed the

arsenic action level, implementation of ICs may be appropriate through management of

the area as a high arsenic area.

Additionally, evaluations of vegetation performance standards and monitoring and maintenance

(M&M) requirements are made based on land use pursuant to requirements identified in the Final

VMP for the ARWW&S OU (Atlantic Richfield, 2013), or the Modifying Criteria of the LRES

where standards under the VMP are inappropriate.

4.0 SITE CHARACTERIZATION

4.1 Previous Investigations

No previous investigations were conducted for this site.

4.2 2010 Facility Sampling

Soils data for arsenic and other metals including, cadmium, copper, lead, and zinc were collected

to evaluate potential human health impacts as well as the potential impacts to vegetation

establishment. Sample data collected during the Facility sampling of polygon WGAL-003.29 are

presented in Table 1 below. Sampling locations are shown on Figure 2.

WGAL-003.29 ISIR



Table 1 - 2010 Facility Sampling Data Summary Table

Sample ID Depth

(inches)

As Cd Cu Pb Zn Soil pH

(standard

units) (mg/kg)

FAC-010-095A 0-2 158 4 562 119 428

FAC-010-095B 2-6 137 4 403 92 365

FAC-010-095C 0-6 7.6

FAC-010-095D 6-12 63 4 48 18 72

FAC-010-094A 0-2 176 4 421 134 302

FAC-010-094B 2-6 72 4 119 21 106

FAC-010-094C 0-6 7.4

FAC-010-094D 6-12 19 4 26 8 18

4.3 Analysis

As previously mentioned, Facility WGAL-003.29 represents a privately owned former gravel pit

located at the southwest intersection of Galen Road and Upper Racetrack Road. All of the

samples collected from the formal gravel pit exhibited arsenic concentrations below the

applicable recreational/open space/agricultural action level of 1,000 mg/kg as well as the

residential land use action level of 250 mg/kg. The Total Metal Indices (TMI = As+Cu+Zn) for

all sampled soils were also below the moderate plant stress level of 1,700 mg/kg identified in the

VMP and soil pH values were greater than 6.5 standard units. Therefore, no smelter related

impacts were identified at the facility requiring remediation.

4.4 Recommendations

No smelter related impacts were identified and therefore no active remedial requirements have

been determined necessary as a result of collecting and analyzing soils data for the facility

represented by polygon WGAL-003.29. Because soil arsenic concentrations are below the

residential land use action level of 250 mg/kg, this facility can be classified as Category 1

(Unrestricted Use) under the Final VMP.

Existing vegetation cover for this facility varies and has been found to be sparse in some areas.

In its current condition, the facility would likely not pass the Operational and Functional (O&F)

vegetation performance criteria identified in the VMP for typical Category 1 properties.

However, as discussed in the February 26, 2014 meeting between Atlantic Richfield and EPA

representatives, application of LRES modifying criteria is appropriate given physical site

conditions and can be used to designate this facility as NFA. Due to the absence of contaminated

soils, the coarse nature of the existing soil surface which effectively prevents fugitive dust

generation, and most of the parcel having internal drainage, the area will not have requirements

for vegetation establishment or long-term monitoring and maintenance (M&M) under Superfund.

WGAL-003.29 ISIR



Therefore, it is recommended that the facility represented by polygon WGAL-003.29 be

designated as a No Further Action (NFA) Category 1 (Unrestricted Use) area with no additional

Superfund obligations and unrestricted land use from a Superfund perspective. Future

development within this facility, however, will still be subject to all remaining and relevant

provisions of the ADLC Developmental Permit System (DPS) and other applicable federal, state,

and local laws as enforced by the ADLC.

Remedial activities identified in the West Galen Expansion Area FDR/RAWP for areas

immediately adjacent to this facility consist of tillage to a depth of 6 inches (T6). This T6

remedy will be applied to margins of the WGAL-003.29 facility boundary during adjacent RA

activities as delineated during performance of the required pre-construction walkthrough with

Agency personnel. Weed management will also be performed within the margins of this facility

in conjunction with adjacent remediated areas, as appropriate.

WGAL-003.29 ISIR



5.0 REFERENCES

EPA, 1998. Anaconda Smelter NPL Site, Anaconda Regional Water, Waste and Soils

(ARWW&S) Operable Unit (OU) Record of Decision (ROD). September 1998.

EPA, 2000. Final Remedial Design Work Plan, Anaconda Regional Water, Waste and Soils

Operable Unit, Anaconda Smelter NPL Site, Anaconda, MT. Prepared for EPA by CDM

Federal Programs Corporation. June 26, 2000.

Atlantic Richfield, 2013. Anaconda Smelter NPL Site, Anaconda Regional Water, Waste &

Soils OU, Final Vegetation Management Plan. May 2013.

Atlantic Richfield, 2010. Facilities Sampling and Analysis Memorandum, Anaconda Regional

Water, Waste and Soils Operable Units, Old Works/East Anaconda Development Area

Operable Unit, Anaconda, MT. May 2010.

Atlantic Richfield, 2005. West Galen Expansion Area Final Design Report/Remedial Action

Work Plan, Anaconda Regional Water, Waste and Soils Operable Unit, Anaconda Smelter

NPL Site, Anaconda, MT. June 2005.

WGAL-003.29 ISIR



Table 2 - Soil Analytical Requirements

Analyte Analytical

Method

Container

Requirements Preservative

Holding

Times

Reporting

Limits

(mg/kg)

Arsenic USEPA 6010B

Ziploc plastic

bags None

6 months 1.0 mg/kg

Cadmium USEPA 6010B 6 months 0.3 mg/kg

Copper USEPA 6010B 6 months 1.5 mg/kg

Lead USEPA 6010B 6 months 0.5 mg/kg

Zinc USEPA 6010B 6 months 2.5 mg/kg

pH

(Saturated

paste)

ASA Monograph

9, Part 2, Method

10-3.2

NA NA

WGAL-003.29 ISIR



Table 3 - Sample Pit Location

Sample ID Northing Easting

FAC-010-095A

737033.5082 1120937.5903 FAC-010-095B

FAC-010-095C

FAC-010-095D

FAC-010-094A

737319.3497 1121209.2886 FAC-010-094B

FAC-010-094C

FAC-010-094D

WGAL-003.29 ISIR



Figures

Figure 1: Vicinity Map – Facilities Sampling and Analysis

Figure 2: Facility Sampling PRLU Polygon WGAL-003.29

SHOP-011.01

WGAL-008.01

WGAL-007.01

FT-006

OWSR-010.02

SHOP-005

Gochanour 2

FT-008.05

FT-008.02

FT-011

FT-008.04

WGAL-003.28

FT-010.01

WGAL-006.06-A

FT-009.11

OWSR-014.08

FT-010.02

SHOP-008

SMHL-028

FT-012

OWSR-005

WGAL-003.10

SMHL-055.06

WGAL-003.29

SMHL-055.07

WGAL-001.02

LTCK-002.13LTCK-017.01

FT-008.07

LTCK-002.11

R.D.U.#8-Opportunity Ponds

WEST GALEN EXPANSION

R.D.U.#1-Stucky Ridge

CSOU

R.D.U.#9-Fluvial Taillings

R.D.U.#3-Smelter Hill Uplands

R.D.U.#6-South Opportunity Uplands

R.D.U.#2-Lost Creek

R.D.U.#15-Mt. Haggin

R.D.U.#13-Old Works WMA

R.D.U.#14-Smelter Hill Facilities

R.D.U.#4-Anaconda Ponds

R.D.U.#12-Slag

R.D.U.#10-Warm Springs Creek

R.D.U.#7-North Opportunity Uplands

R.D.U.#5-Blue Lagoon/Active Railroad

R.D.U.#11-Cashman Pile

8 9

89

562 1

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11

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20

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26

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36

33

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32

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12

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Stewart St.

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3RD ST. MORE

L Rd

Willow Glenn Rd.

4TH ST.

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Haus

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6TH ST.Fa

irmon

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OUTLAW Trl

Elk Haven Dr.

Dixon

St.

5TH ST.

Leslie

St.

8TH ST.

COMMERCIAL ST.

Smith St.

BEAR PAW Trl

ASPEN HILLS Rd

Erickson St.

Norris

St.

Schu

yler S

t.

MAPL

E ST.

Crosby St.

White

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Fairmont Rd.

¬«48

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Lost Creek

Mill Creek

Silver Bow Creek

Willow Creek

Antelope Creek

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Warm Springs Creek

Modesty Creek

Homestead Creek

Gregson

Creek

«

LegendFacility PolygonsRDU BoundariesSection

Hydrologic FeaturesInterstateState Highway

1 0 10.5 Miles

File: Facilities_Plan.mxd Date: 13-Mar-2014

OWSR-014.08

LTCK-002.13

LTCK-017.01LTCK-002.11

3025

1924

29

LOST CREEK RD.

LOST CREEK RD.

Lost Creek

SEE MAPINSET

AFFCO

FIGURE 1VICINITY MAP

FACILITIES SAMPLING & ANALYSISARWW&S OPERABLE UNIT

ANACONDA, MONTANA

%%%%

%%%%FAC-010-094

FAC-010-095

WGAL-003.29

WGAL-003.27

WGAL-003.25

WGAL-001.01

WGAL-003.28

WGAL-001.02

4

33

3

34

Source: Esri, DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GISUser Community

File: Facil_Samp_WGAL-003.29.mxd Date: 07-May-2014

Facilities SamplingPRLU Polygon WGAL-003.29

ARWW&S Operable UnitAnaconda Smelter NPL Site

Figure 2

ª

Legend% Facility Samples

PRLU PolygonsSection Line

70 0 7035

Feet

GALEN ROAD

Note: Sampling was conducted by TREC, Inc on 08.31.2010 under Anaconda Smelter NPL Site, OW/EADA OU and ARWW&S, Facilities Sampling and Analysis Memorandum (May 2010)

WGAL-003.295

1000 ppm WGE

As Cd Cu Pb Zn

FAC-010-095A 0-2 158 4 562 119 428FAC-010-095B 2-6 137 4 403 92 365FAC-010-095C 0-6 7.6FAC-010-095D 6-12 63 4 48 18 72FAC-010-094A 0-2 176 4 421 134 302FAC-010-094B 2-6 72 4 119 21 106FAC-010-094C 0-6 7.4FAC-010-094D 6-12 19 4 26 8 18

Land Use: Reclaimed Gravel pit Total Acres

FacilitiesISIR Design Criteria Summary

Land Owner: James Davis Polygon number

Arsenic Action Level: RDUAs > Action Level at 0-2 inches NoAs > 250ppm at 0-2 inches NoDesign Justification Discussion: Facility WGAL-003.29 represents a privately owned former gravel pit that is located at the southwest intersection of Galen Road and Upper Racetrack Road. All samples collected within the former gravel pit exhibited arsenic concentrations below the applicable recreational/open space/agricultural action level of 1,000 mg/kg as well as the residential action level of 250 mg/kg, and no other superfund impacts were identified. Therefore, this Facility is classified as a Category 1 (Unrestricted Use) area under the Final VMP and is designated as a NFA area using the LRES modifying criteria with no further requirements under Superfund.

REMEDY BASED ON EVALUATION OF BELOW DATA: No Further Action

Sample ID Depth (inches)

Soil pH (standard units)(mg/kg)

WGAL-003.29 ISIR



Appendix A

Laboratory Data

WGAL-003.29 ISIR



Appendix A.1

Ashe Analytics Data

Sheet1

Page 1

TO: TREC, INC. SEPT. 09, 2010

K BETHKE

D PIPINICH

FROM: ASHE ANALYTICS

JOHN ASHE

SUBJECT: ANALYTICAL REPORT NO. KBD00910K

PROJECT: 9202 - FACILITIES

TWENTY-EIGHT (28) SAMPLES WERE RECEIVED ON SEPT. 02, 2010 FOR

TOTAL METALS ANALYSIS (As, Cd, Cu, Pb, & Zn) BY XRF.

RESULTS ARE PRESENTED BELOW.

SAMPLE

LAB SAMPLE As As Cd Cd Cu Cu Pb Pb Zn Zn PREP

NUMBER I.D. mg/kg FLAG mg/kg FLAG mg/kg FLAG mg/kg FLAG mg/kg FLAG GROUP

K-1590 FAC-010-092A

K-1591 FAC-010-092B

K-1592 FAC-010-092D

K-1593 FAC-010-093A

K-1594 FAC-010-093B

K-1595 FAC-010-093D

K-1596 FAC-010-084A

K-1597 FAC-010-084B

K-1598 FAC-010-084D

K-1599 FAC-010-085A

K-1600 FAC-010-085B

K-1601 FAC-010-085D

K-1602 FAC-010-043.1

K-1603 FAC-010-060.1A

K-1604 FAC-010-060.1B

K-1605 FAC-010-060.1D

K-1606 FAC-010-094A 176 3.9 U 421 134 302 999860.00

K-1607 FAC-010-094B 71.6 3.9 U 119 21.3 106 999860.00

K-1608 FAC-010-094D 19.0 3.9 U 25.6 7.5 U 17.5 U 999860.00

K-1609 FAC-010-095A 158 3.9 U 562 119 428 999860.00

K-1610 FAC-010-095B 137 3.9 U 403 91.5 365 999860.00

K-1611 FAC-010-095D 62.6 3.9 U 48.0 18.3 71.9 999860.00

K-1612 FAC-010-077A

K-1613 FAC-010-077B

K-1614 FAC-010-077D

K-1615 FAC-010-077.1A

K-1616 FAC-010-077.1B

K-1617 FAC-010-077.1D

Not Part of Polygon WGAL-003.29


WGAL-003.29 ISIR



Appendix A.2

MSE, Inc. Data

Not Part of Poygon WGAL-003.29


WGAL-003.29 ISIR



Appendix B

SAMPLE CHAIN-OF-CUSTODIES

WGAL-003.29 ISIR



Appendix B.1

Ashe Analytics Chain-of-Custody

WGAL-003.29 ISIR



Appendix B.2

MSE Inc. Chain-of-Custody

WGAL-003.29 ISIR



Appendix C

Field Logs

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