DRAFT EXPANDED PHASE I REEVALUATION FOR LBJ WEST CORRIDOR CSJ: 2374-01-068 FROM LUNA ROAD TO US 75 ON IH-635 AND FROM LOOP 12 TO VALWOOD PARKWAY ON IH-35E DALLAS COUNTY TEXAS DEPARTMENT OF TRANSPORTATION MARCH 2007 TABLE OF CONTENTS SECTION PAGE EXECUTIVE SUMMARY .................................................................................................................... 1 INTRODUCTION AND PURPOSE ...................................................................................................... 2 SECTION 1. REEVALUTION OF REGULATORY AGENCY DATABASE.................................. 4 SECTION 2. FINDINGS ............................................................................................................ 21 SECTION 3. CONDITIONS AND LIMITATIONS ..................................................................... 22 SIGNATURES OF QUALIFIED ENVIRONMENTAL PROFESSIONALS .................................. 24 LIST OF TABLES TABLE 1. SUMMARY OF DATABASE FINDINGS .................................................................. 14 LIST OF FIGURES FIGURE 1. SITES WITH POTENTIAL GROUNDWATER CONTAMINATION WITH DIRECTION OF GROUNDWATER FLOW BASED ON DEM (DIGITAL ELEVATION MODEL) FIGURE 2. SITES WITH POTENTIAL GROUNDWATER CONTAMINATION WITH DIRECTION OF SLOPE BASED ON DEM (DIGITAL ELEVATION MODEL) Executive Summary In December, 2006, a review of environmental regulatory databases was undertaken as part of a Limited Phase I Environmental Site Assessment (ESA [ASTM 1527-00]) for the proposed construction project on IH-635 from Luna Road to US 75 (9.25 miles) and on IH-35E from Loop 12 to Valwood Parkway (4.75 miles) (Figure 1). In February 2007, the Texas Department of Transportation (TxDOT) requested that a reevaluation be performed on the limited Phase I ESA with particular emphasis on potential impacts of contaminated groundwater on the project. The original database review determined all listed sites to be of “low risk” to the subject corridor. For ground level construction, the risk might be “low”; however, several segments of the proposed project could be depressed, tunneled, and/or elevated and, as such, are likely to encounter groundwater during construction. The purpose of this reevaluation is to provide TxDOT with further clarification on potential groundwater impacts associated with the proposed methods of construction. Upon review of the regulatory database and any additional groundwater information (including depth, gradient, and contamination), the levels of risk will be reevaluated according to this site specific information. Sites with potential or documented groundwater contamination were mapped and color coded by potential to impact groundwater in the project area (Figure 1). In addition, a map showing approximate surface topography with color coded directions of slope is provided (Figure 2). Summary of Findings A reevaluation of the Limited Phase I Environmental Site Assessment (ASTM 1527-00) for the proposed project on IH-635 from Luna Road to US 75 (9.25 miles) and on IH-35E from Loop 12 to Valwood Parkway (4.75 miles) was performed. The results of the reevaluation are presented in this report. Based on the tasks completed, the following findings are reiterated: Of the 310 sites listed in the regulatory agency database, 49 were determined to have the potential to contaminate groundwater at the subject corridor. The 49 sites were identified as sites with documented or probable contamination of groundwater. After further review, the identified 49 sites were ranked according to the level of risk posed to the subject corridor. Seven (7) sites were determined to be of moderate risk and the remaining 42 sites were determined to be of low risk. The sites determined to be of moderate risk all involved spills and are as follows: - S IH-35E 500 feet past Valley View exit (Map ID 13), Dallas, TX due to potential groundwater contamination as a result of a 30 gallon diesel spill in 1998. - IH-635 and Coit Road (Map ID 11), Dallas, TX due to potential groundwater contamination as a result of an 800 gallon gasoline spill in 1995. - IH-35E and Valley View Lane (Map ID 9), Dallas, TX due to potential groundwater contamination as a result of a 100 gallon diesel spill in 1998. - Admiral Merchant Motor Freight (Map ID 1) IH-35E just south of IH635, Dallas, TX due to potential groundwater contamination as a result of a 50 gallon diesel spill in 1998. 1 - McClendon Trucking Company (Map ID 6), E LBJ Freeway at Josey Lane Exit, Dallas, TX due to potential groundwater contamination as a result of a 200 gallon diesel oil spill in 1998. - Flint, Inc (Map ID 6), E LBJ Freeway at Josey Lane Exit, Dallas, TX due to potential groundwater contamination as a result of a 50 gallon solvent ink spill in 1998. - US Fleet Services (Map ID 2), IH-35E and Valwood Pkwy, Farmers Branch, TX due to potential groundwater contamination as a result of a 100 gallon diesel spill in 1998, a 60 gallon diesel spill in 1990, a 46,000 lb calcium lignosulfate spill in 1992, a 100 gallon diesel spill in 1994, and a 200 gallon diesel spill in 1998. The seven moderate sites were plotted as red and the remaining 42 sites were plotted as yellow in Figure 1. The groundwater flow direction/gradient for each site, if available, was provided as well. Groundwater levels throughout the corridor are widely variable and frequently fluctuate therefore, only groundwater depths at the time of construction are useful in determining the potential risk of contaminated groundwater to activities at the subject corridor. Introduction and Purpose On December 15, 2006, a review of regulatory databases was undertaken as part of a Limited Phase I Environmental Site Assessment (ASTM 1527-00) for the proposed construction project on IH-635 from Luna Road to US 75 (9.25 miles) and on IH-35E from Loop 12 to Valwood Parkway (4.75 miles) (Figure 1). TxDOT requested that a reevaluation be performed of the limited Phase I ESA with particular emphasis on potential impacts of contaminated groundwater on the project. The original database review determined all listed sites to be of “low risk” to the subject corridor. For ground level construction, the risk might be “low”; however, several segments of the proposed project could be depressed, tunneled, and/or elevated and, as such, are likely to encounter groundwater during construction. These areas are indicated in Figure 1. The purpose of this reevaluation is to provide TxDOT with further clarification on potential groundwater impacts associated with the proposed methods of construction. Upon review of the regulatory database and any additional groundwater information (including depth to groundwater, groundwater gradient, and types and concentrations of contamination), the levels of risk were reevaluated according to this site specific information. Information concerning groundwater depth within the subject corridor was found in geotechnical reports provided to TxDOT by Mas-Tek Engineering and Associates, Inc, in March 2006 (western half of subject corridor [IH-35E]) and by Lachel and Felice Associates, Inc in June 2006 (eastern half of subject corridor [IH-635]). According to the data provided in these reports, the groundwater levels throughout the corridor are widely variable and frequently fluctuate over time. In the segment of the subject corridor from Northwest Highway to Valwood Parkway on IH-35E and from Luna Road to Webb Chapel Road on IH-635, groundwater depths were found to vary from 3 to 28 feet. In the segment of the subject corridor from Webb Chapel Road to Josey Lane on IH-635, the groundwater depths vary from 15 to 20 feet. In the segment of the subject corridor from 2 Webb Chapel Road to Marsh Lane on IH-635, the groundwater depth varies from 2 to 8 feet. In the segment of the subject corridor from Marsh Lane to Hillcrest Road on IH-635, the groundwater depth varies from 15 to 20 feet. Therefore, only groundwater depths at the time of construction are useful in determination of potential risk of contaminated groundwater to activities at the subject corridor. The regulatory agency database listed 310 sites within their respective ASTM search radii. Some sites were listed in multiple databases. The database was reviewed to determine which of the sites were considered Recognized Environmental Concerns (RECs). A REC is defined in ASTM practice E1527-00 as “the presence or likely presence of any hazardous substances or petroleum products on a property under the conditions that indicated an existing release, a past release, or a material threat of a release of any hazardous substance or petroleum products into structures on the property or in the ground, groundwater, or surface water of the property.” The term includes hazardous substances or petroleum products even under conditions in compliance with laws. The term is not intended to include de minimis conditions that generally do not present a material risk of harm to public health or the environment and that generally would not be the subject of an enforcement action if brought to the attention of appropriate governmental agencies. The 310 sites were reevaluated to determine whether they are “high risk”, “moderate risk”, or “low risk” to the project areas that will require drilling or excavation and likely encounter groundwater. “High risk” sites are those sites that are contaminated and located within the proposed right-of-way (ROW). “Moderate risk” sites are those sites that are adjacent to the ROW with a lower possibility to contaminate the ROW. “Low risk” sites are those that may be contaminated, but do not appear to pose a contamination problem to highway construction. Upon reevaluation of the 310 sites, it was determined that 49 sites representing 123 database listings could pose a risk to groundwater at the proposed construction site. Sites were eliminated based on their distance from the subject corridor, gradient from the subject corridor, and nature of the database listing. It was assumed that contaminated groundwater at an upgradient from the site was not likely to migrate greater than approximately 1000 feet, moderately likely to migrate 500 feet and likely to migrate 250 feet in the event of deep subsurface drilling or excavation. The risk posed to the subject corridor from groundwater contamination is also dependent upon the type of contaminant, concentration of contaminant, and time since initial contamination. These distances are based on average soil permeabilities listed in the Dallas County Soil Survey (USDA, 1980) for the major soil types identified in the project area. It was assumed that leaks of fuel or solvent would, in most cases, not migrate more than 1000 feet (without substantial dilution and/or degradation) given the <0.06 in/sec average rate of soil permeability identified for the soils associated with sites with potential groundwater contamination. It was assumed that groundwater contamination within 100 feet of the subject corridor is likely to seep into any large borehole or excavation that penetrates beyond the water table. Based on these criteria, sites that revealed no evidence of existing or likely groundwater contamination that could affect the subject corridor were 3 determined to be of no risk. Further research that included monitoring well data, groundwater gradient information, and site specific records was performed by Geosearch on the 49 sites that were determined to be a risk to groundwater at the proposed construction site. This research consisted of accessing Texas Commission on Environmental Quality (TCEQ) records located in Austin, Texas. This research was then used to determine if the 49 sites were in fact a risk to groundwater at the subject corridor. The sites were then plotted on the project map (Figures 1 & 2). Arrows indicate the direction of groundwater flow with each site being color coded in respect to the level of risk posed to the subject corridor. Groundwater flow information was taken from a Digital Elevation Model (DEM) (Figure 2). It was assumed that the groundwater flow typically follows the topography of the land. In addition, the cones of depression from the dewatering activities will be dependent upon the surrounding soil permeability, local topography and dewatering methodology. A list of the 49 sites can be found in Table 1 following Section 1 of this document (only areas of concern to groundwater contamination are mentioned in comments). Section 1 Reevaluation of Regulatory Agency Database The regulatory agency database report provided by Geosearch was reevaluated to ascertain which of the original 310 sites pose a potential risk to groundwater at the proposed construction sites. Based on the reevaluation, 49 sites were identified as potential risks to groundwater in the project area. These 49 sites representing 123 database listings were then researched further (site specific records including monitoring well data, and gradient information) in order to evaluate the degree of risk that they could pose to the groundwater at the proposed construction sites. The site specific results of this reevaluation are as follows: Crews Plating, Inc (Map ID 226) is listed in the DOCKETS, VCP, and CERCLIS databases. According to the CERCLIS database, illegal dumping of electroplating waste into city sewers and ditches and a suspected 10,000 gallon tank of electroplating waste and sludges were reported on- site. The facility applied for VCP in 1998 due to the groundwater being contaminated with metals and VOCs, yet no record of completion has been reported. The DOCKETS database listed the site as becoming a superfund site in 1999. The site is located at a distance of greater than 1500 feet and at a higher elevation than the subject corridor, and the gradient direction is to the southwest. Due to the distance from the subject corridor and the time since groundwater contamination, the site poses a low risk to the subject corridor. CXY Energy Offshore, Inc (Map ID 58) is listed in the DOCKETS database due to a permit violation for effluent discharges of deck drainage, drill fluids, and produced water oil in 1998. Due to the time since this incident occurred and no record of groundwater contamination being found, the site poses a low risk to the subject corridor. 4 ORYX Energy Corporation (Map ID 143) is listed in the DOCKETS and IHW databases. According to the DOCKETS listing, ORYX had a Clean Water Act Violation in 1997 for an oil spill and an effluent permit violation 1998. The IHW database listed the site as an inactive generator as of 2004. Due to the time since any spill or violation occurred and no record of groundwater contamination being found, the site poses a low risk to the subject corridor. The New Datsun Corporation (Map ID 153) is listed under the DOCKETS, VCP, and IHW databases. According to the DOCKETS database, a docket was filed for the site in 1978, yet it does not list the circumstances. The New Datsun Corporation enrolled into the VCP program in 2004 due to the soil and groundwater being contaminated with VOCs, SVOCs, and Metals. The VCP was completed in 2005. The IHW database lists the site as an inactive generator as of 2004. The site poses a low environmental risk due to its being at a distance of greater than 750 feet and at a lower elevation than the subject corridor. The Dallas City Landfill (Map ID 79) is listed under the MSWLF and NFRAP databases. According to the MSWLF database, the sanitary landfill is closed and according to the NFRAP database, the site was archived in 1993. According to an investigation report provided by Geosearch, the site has been closed since at least 1980 and groundwater contamination was found onsite in 1993. Due to the time since contamination was last documented and its being at a lower elevation than the subject corridor, it poses a low risk to the subject corridor. BWay (Map ID 134) is listed under the VCP, TRI, IHW, and LPST databases. According to the IHW database, the site is listed as an inactive generator as of 2003. The TRI database lists no release of waste into the ground. VCP was applied for at the site in 2001 due to the soil and groundwater being contaminated with metals and chlorinated solvents. No completion of this VCP has been reported. The LPST database reports groundwater impact at the site in 2001, yet the site has been issued final concurrence and the case is closed. Even though the site is at a higher elevation and sloping toward the subject corridor, it is at a distance of greater than 750 feet from the subject corridor and is underlain by low- permeability clay. Therefore, there is a low probability of contaminant migration and the site poses a low risk to the subject corridor. 10620 Stemmons Freeway (Map ID 89) is listed under the PST and HMIRS databases. This facility currently has two 600 gallon diesel tanks in use. According to the HMIRS database, a 300 gallon gasoline spill occurred in 1996 that was reported to have been cleaned up. Since there is no record of groundwater contamination and the site’s gradient is away from the subject corridor, it poses a low risk to the subject corridor. Exxon Mobil Corporation (Map ID 25) is listed under the IHW, LPST, and PST databases. The IHW database lists the site as an inactive generator and the PST lists the site as having three underground gasoline tanks currently in use. According to the LPST database, a leak occurred in 1989 that impacted groundwater with no apparent threat to receptors that has since been issued final concurrence. Due to the time since the leak 5 occurred and since the site is at a lower elevation than the subject corridor, it poses a low risk to the subject property. Omega Optical Company (Map ID 14) is listed as an active generator of numerous types of hazardous waste under the IHW database. This site is also listed under the RCRAInfo database as a small quantity generator. Since the site is located approximately 150 feet from the subject corridor, the close proximity of hazardous waste generation at the site poses a risk to the subject corridor. However, since no record of groundwater contamination was found and the site is at a lower elevation that the subject corridor, the risk is low. Dallas Castle MPG, Inc (Map ID 17) is listed under the IHW, RCRAInfo, PST, and LPST databases. The IHW database lists the site as inactive and the RCRAInfo database lists the site as having no violations and generating no waste. According to the PST database, a 10,000 gallon gasoline underground storage tank was removed from the site in 1997 and there is currently a 3000 gallon above ground gasoline tank in use. According to the LPST database, a leak was reported in 1996 that has since been issued final concurrence with the case being closed. Groundwater was impacted with no apparent threat to receptors. A risk assessment report provided by Geosearch stated that three on site monitoring wells were sampled in 2002 and all concentrations were below target cleanup levels. The report also illustrated the groundwater flowing toward the northwest which is away from the subject corridor. Since contamination levels are below cleanup levels, the groundwater flow is away from the subject corridor, and due to the time since the leak and the last sampling, the site poses a low risk to the subject corridor. Bankston Lincoln Mercury (MAP ID 20) is listed under the IHW, RCRAInfo, LPST, and PST databases. According to the IHW database, the site is listed as an inactive small quantity generator as of 2002. The RCRAInfo database noted one violation in 1991 that dealt with non-financial record review, which would not pose any type of risk to the subject corridor. The LPST database listed an occurrence in 1995 that had no groundwater impact, and no apparent threats or impacts to receptors. The case was issued final concurrence and the case has been closed. The PST database has one 4000 gallon PST in use on the subject property. The database also lists four 550 gallon PST that are not in use, and were permanently filled in place in 1998. One other 2000 gallon PST was removed from the site in 1992. With the groundwater gradient sloping to the east, and with there not being any substantial ground water impacts to the subject site, this site poses a low risk to the subject corridor. Showcase Chevrolet (Map ID 21) is listed under the IHW, RCRA, LPST, and PST databases. The IHW and RCRAInfo databases list the site as an active small quantity generator of hazardous waste. The PST database states that an above ground gasoline and an underground gasoline tank were removed in 1993. The LPST database reports that a leak occurred which caused minor soil contamination and that has since been issued final concurrence. Since no record of groundwater contamination has been documented, and given the time since the leak occurred, the site poses a low risk to the subject corridor. 6 Collision Masters (Map ID 23) is listed under the IHW, RCRAInfo, and PST databases. The IHW and RCRAInfo databases list the site as an active small quantity generator of hazardous waste with no recorded violations. One 500 gallon underground used oil tank was removed from the site in 1995. Since the site is located approximately 300 feet from the subject corridor, the close proximity of hazardous waste generation at the site poses a risk to the subject corridor. However, since no record of groundwater contamination was found and the site is at a lower elevation that the subject corridor, the risk is low. Mobil Oil Corporation (Map ID 26) is listed under the IHW, RCRAInfo, and PST databases. The IHW database lists the site as an inactive generator and the RCRAInfo database states that the site is not a generator and has no violations. According to the LPST database, a leak was reported at the site in 1989 that impacted groundwater and has since been issued final concurrence. The PST database lists three underground gasoline tanks that are currently in use on site. Since the site is at a lower elevation than the subject corridor and due to the time since the leak occurred, the site poses a low risk to the subject corridor. Midway Cleaners (Map ID 42) is listed under the IHW, RCRAInfo, LPST, and PST databases. The IHW and RCRAInfo databases list the site as an inactive generator with no violations. According to the LPST database, a leak occurred onsite in 1992 that did not impact the groundwater and that has since been issued final concurrence. The PST database lists four underground gasoline tanks that are currently in use at the site. Since there is no documentation of groundwater contamination at the site, it poses a low risk to the subject corridor. Star Enterprises (MAP ID 47) is listed under the IHW, RCRAInfo, LPST and PST databases. According to the IHW database, the site is listed as an inactive generator as of 2004. The RCRAInfo database shows no violations on the subject property. The LPST database listed an occurrence in 1993 that impacted groundwater on the site. Monitoring wells were installed in 1995, and the wells were sampled in 1995 and 1996. The final sampling data indicates elevated amounts of benzene and MTBE in MW-4. Final concurrence was given to the site in 1997, and the case was closed. The PST database lists four 1000 gallon PST’s on site and in use. The PST database also lists one 1000 gallon PST was removed from the site in 1993. With the groundwater gradient sloping away from the subject corridor, along with the site being at a lower elevation than the subject corridor, and the extended period of time since of over 10 years since the elevated levels of contaminates were documented, there is a low probability of contaminant migration into the subject corridor and the site poses a low risk to the subject corridor. Mobil Oil Corporation (Map ID 48) is listed under the IHW, RCRAInfo, LPST, and PST databases. The IHW and RCRAInfo databases list the site as an inactive generator with no violations. The LPST database lists a leak reported in 1998 that impacted groundwater with no apparent threat to receptors. This case has since been issued final concurrence and been closed. The PST database lists three underground gasoline tanks that are currently in use at the site. Due to the time since the leak occurred and the gradient of the 7 site being parallel rather than towards the subject corridor, it poses a low risk to the subject corridor. Exxon Mobil Corporation (Map ID 49) is listed under the IHW, RCRAInfo, LPST, and PST databases. The IHW and RCRAInfo databases list the site as an inactive generator with no violations. According to the LPST database, a leak occurred onsite in 1996 that had no impact on groundwater. The PST database lists the site as currently having three gasoline and one diesel underground storage tanks in use. Due to no groundwater contamination being reported at the site and the gradient of the site being away from the subject corridor, it poses a low risk to the subject corridor. Texaco Station (MAP ID 52) is listed under the RCRAInfo, LPST, and PST databases. According to the RCRAInfo database, the site is listed as a conditionally exempt small quantity generator with no violations. The LPST database listed two separate occurrences in 1991 and in 1993. Neither of these occurrences had groundwater impacts on the site. Both of these occurrences had soil contamination only. Remedial action was taken in both instances with final concurrences being issued, and both cases were. The PST database lists four 10,000 gallon PST’s, and one 550 gallon PST that were on the site. All five PST’s were removed in 1993. With the groundwater gradient sloping away from the subject corridor, and the subject corridor being at a higher elevation, the site poses a low risk to the subject corridor. Exxon Mobil Corporation (Map ID 53) is listed under the RCRAInfo, LPST, IHW, and PST databases. The IHW and RCRAInfo databases list the site as an inactive generator with no violations as of 2003. According to the LPST database, a leak was reported in 1993 that impacted the groundwater and has since been issued final concurrence. The PST database lists eight tanks which have all been removed. Since the site is at a lower elevation with a gradient away from the subject corridor, the site poses a low risk to the subject corridor. Exxon RAS 6 3700 (Map ID 67) is listed under the RCRAInfo, LPST, IHW, and PST databases. The IHW and RCRAInfo databases list the site as an inactive generator with no violations. The LPST database lists a leak reported in 1992 that impacted the groundwater and has since been issued final concurrence. The PST database lists four tanks which have all been removed. Since the site is at a lower elevation with a gradient away from the subject corridor, it poses a low risk to the subject property. Forest Lane Porsche (MAP ID 62) is listed under the IHW, RCRAInfo, LPST, and PST databases. The IHW database listed the site as an inactive generator as of 2004. According to the RCRAInfo database there have been not violations on the site. The LPST database reports groundwater impact at the site in 1989, yet the site has been issued final concurrence and the case is closed. The PST database listed twenty-two 99 gallon tanks in use on the site. Also listed on the PST database were three 2000 gallon tanks that were removed from the site between 1988 and 1989. With the groundwater gradient sloping away from the subject corridor, and the subject corridor being at a higher elevation, the site poses a low risk to the subject corridor. 8 Exxon Mobil Corporation (MAP ID 65) is listed under the IHW, RCRAInfo, LPST, and PST databases. According to the IHW database, the site is listed as an inactive generator as of 2002. The RCRAInfo database shows no violations on the subject property. The LPST listed an occurrence in 1996 that impacted groundwater on the site, yet the site has been issued final concurrence and the case is closed. The PST database listed four large volume tanks on site that contain oil, gasoline, or diesel. The PST database also lists four tanks that were removed from the site in 1986. With the groundwater gradient sloping away from the subject corridor, and the subject corridor being at a higher elevation, the site poses a low risk to the subject corridor. Shell SVC Station (MAP ID 68) is listed under the RCRAInfo, LPST, and PST databases. The RCRAInfo database shows the site to be generator with no violations on the subject property. The LPST listed an occurrence in 1995 that impacted groundwater on the site. The case was issued final concurrence and the case has been closed. It was documented in a report provided by GeoSearch that no groundwater impacts were documented at the site from the 1998 occurrence. The PST database listed four storage tanks on the site that are in use at this time. Two of the tanks are 44 gallons in capacity and have unknown contents. The remaining tanks are 15,000 gallon capacity tanks with contents being gasoline. The PST database also listed five tanks that were removed in 1994. With the groundwater gradient sloping away from the subject corridor, and the subject corridor being at a higher elevation, the site poses a low risk to the subject corridor. Days Inn Hotel (MAP ID 109) is listed under the IOP and the VCP databases. According to the IOP database, the site received a certificate for completing IOP requirements in 2000. The IOP was received due to possible contaminates from an adjacent property polluting groundwater on site. Elevated levels of solvents related to dry cleaning operations were found in the groundwater on site. The VCP database lists the site as entering the VCP program in 1997, but the database does not list a completion date. The site is at a higher elevation than the subject corridor. However the gradient is not directly towards the subject corridor and the site is at a distance of greater than 500 feet. Therefore, the site poses a low risk to the subject corridor. Buddy’s Texaco (MAP ID 18) is listed under the LPST and PST databases. The LPST database listed an occurrence in 1987 where groundwater was impacted on the site. Final concurrence was issued for the site, and the case was closed. It should be noted that in a report provided by GeoSearch, that monitoring well data was still being collected in 2004, with the results of that data showing elevated levels of contaminates still present. According to the PST database, the site has two storage tanks on site. One tank contains gasoline, and the other has unknown contents stored. Between 1995 and 1999 there were storage tanks removed that were used to store petroleum products. The groundwater water gradient is toward the subject corridor, and the site is approximately 200 feet from the subject corridor. The subject corridor is at a high elevation, therefore there is a low probability of contaminant migration and the site poses a low risk to the subject corridor. 9 Chevron 105954 (MAP ID 19) is listed under the LPST and the PST databases. The LPST database listed one occurrence in which groundwater was impacted in 1992. The site received final concurrence in 1999, and the case was closed. It is noted in the final concurrence that although maximum groundwater concentrations exceed Category III levels, the plume appears to be stable and/or declining. The PST database listed four storage tanks that are currently in use, and are used to store gasoline or diesel. There is a fifth tank on site that is temporarily out of use, and is used to store used oil. With the groundwater gradient sloping way from the subject corridor, and the subject corridor being at a higher elevation, the site poses a low risk to the subject corridor. US Fleet Services (Map ID 2) is listed under the SPILLS and ERNS databases. The ERNS database lists a 100 gallon diesel spill on pavement that occurred in 1998. The SPILLS database lists a 60 gallon diesel spill that affected Cook’s Creek in 1990. It also lists a 46000 lb calcium lignosulfate spill that affected an unnamed tributary to Hutton Creek in 1992. There was also a 200 gallon diesel spill in 1994 that affected the Trinity basin and a 200 gallon concrete additive spill in 1998 that affected the drainage ditch. Given the clearly large amount of spillage at this site, its very close proximity to the subject corridor and its gradient towards the subject corridor, there is a potential for groundwater contamination at this site. Therefore, this site poses a moderate risk to construction activity at the subject corridor. Mission Transport Company (Map ID 5) is listed under the SPILLS and ERNS databases. Both databases list a 65 gallon gasoline spill which occurred in 1989. Regardless of the sites close proximity to the subject corridor, the gradient of the site is away from the subject corridor, the incident occurred more than fifteen years ago, and the site therefore poses a low risk to the subject corridor. Flint, Inc (Map ID 6) is listed under the ERNS database due to a 50 gallon solvent ink spill which occurred onsite in 1998 and which was stated to affect the pavement along the highway. Given the chances for spillage to runoff into the nearby soil and seep into the groundwater, there is a potential for groundwater contamination at this site. In addition, the site is at a higher elevation than the subject property and within fifty feet of the subject corridor, therefore it poses a moderate risk to groundwater at the subject property. McClendon Trucking Company (Map ID 6) is listed under the ERNS database due to a 200 gallon diesel onsite in 1998 which was stated to affect asphalt and soil. Given the chances for spillage to seep from the soil into the groundwater, there is a potential for groundwater contamination at this site. In addition, the site is at a higher elevation than the subject corridor and within fifty feet of the subject corridor, therefore it poses a moderate risk to groundwater at the subject property. Tempo Mechanical (Map ID 24) is listed under the IHW, LPST, and PST databases. The IHW database lists the site as an inactive generator. According to the LPST database, a leak was reported in 1990 that was classified as group one contaminated groundwater that has or is likely to migrate offsite. Final concurrence has since been issued and the case is closed. The PST database lists three tanks, all of which have been removed. Since the site 10 is at a lower elevation with a gradient away from the subject property, the contaminated groundwater most likely migrated away from the subject corridor. Therefore, the site poses a low risk to the subject corridor. Texaco (Map ID 28) is listed under the LPST and PST databases. The LPST database lists a reported leak in 1988 that impacted groundwater and has since been issued final concurrence. The PST database lists 3 gasoline underground storage tanks that are currently in use on site. The time since the leak occurred and the lack of current documentation of groundwater contamination make this site a low risk to the subject corridor. Exxon (Map ID 28) is listed under the LPST database due to a leak reported in 1992 that impacted groundwater and has since been issued final concurrence. The time since the leak occurred and the lack of current documentation of groundwater contamination make this site a low risk to the subject corridor. Midway Texaco (Map ID 43) is listed under the PST and LPST databases. According to the LPST database, a leak was reported in 1989 that impacted a domestic water supply well and has since been issued final concurrence. The PST database lists one underground storage tank of unknown content (probably gasoline or diesel) currently in use. Given the time since the leak occurred and the lack of current documentation of groundwater contamination, the site poses a low risk to the subject corridor. 635 Diamond Shamrock (Map ID 51) is listed under the LPST and PST databases. According to the LPST database, a leak was reported in 1987 that impacted the groundwater and has since been issued final concurrence. The PST database lists 2 underground gasoline tanks that are currently in use. Due to the time since the leak occurred and the gradient being away from the subject corridor, the site poses a low risk to the subject corridor. Rodger Meier Cadillac (Map ID 60) is listed under the VCP, LPST, and PST databases. The site was enrolled in the VCP program in 1990 due to groundwater contamination, remedied by excavation, and completed in 2003. The LPST database lists a leak in 1990 that impacted groundwater and that is pending concurrence upon documentation of well plugging. The PST database lists all tanks as being permanently filled in place. Since the gradient is away from the subject corridor, the site poses a low risk. Graystone Place (Map ID 66) is listed under the LPST and PST databases. According to the LPST database, a leak was reported in 1990 that affected the groundwater and has since been issued final concurrence. The PST database lists one diesel underground storage tank in use at the site. Due to the time since the leak occurred and the lack of current documentation of groundwater contamination, the site poses a low risk to the subject corridor. The NW corner of IH35E and Manana Drive (Map ID 8) is listed under the MSWLF databases. According to the MSWLF database, the landfill was proposed in 1996, but no 11 permits have been issued to date. Since there is no evidence that this site was ever an active landfill, or that there is any groundwater contamination on site, and due to the gradient being generally away from the subject corridor, the site poses a low risk. The City of Dallas Property (Map ID 15) is listed under the IHW and MSWLF databases. The IHW database lists the site as an inactive generator. The MSWLF database lists the site as being closed and in use prior to 1974. Due to the time since the landfill was in operation, the general gradient being away from the subject corridor and the lack of evidence of groundwater contamination, the site poses a low risk. Concourse Office Park (Map ID 93) is listed under the VCP database. This site enrolled in the VCP program in 1998 due to the soil being contaminated with TPH and was completed in 2000. Due to there being no record of groundwater contamination, and the gradient being away from the subject corridor, the site poses a low risk. John Roberts BMW (Map ID 98) is listed under the VCP database. The site enrolled in the VCP program in 2005 due to the soil and groundwater being contaminated with metals and chlorinated solvents. No completion has been reported to date. Due to the gradient of the site being away from the subject corridor and the distance being more than 500 feet, the site poses a low risk. Midway Plaza (Map ID 102) is listed under the VCP, IHW, RCRAInfo, and DCR databases. The IHW and RCRA databases list the site as being an inactive generator with no violations as of 2004. The DCR database lists the site as being a drycleaner drop station. The site enrolled in the VCP program in 1998 due to the soil and groundwater being contaminated with solvents. The gradient of the site is toward the subject corridor, however, the VCP was completed in 2000 and the site is at a distance of greater than 500 feet, therefore the site poses a low risk to the subject corridor. Sam’s Cleaners (Map ID 110) is listed under the VCP database. The site enrolled in the VCP program in 2002 due to the groundwater being contaminated with VOCs and chlorinated solvents. No completion has been reported to date. Since the site is at a lower elevation with a gradient away from the subject corridor, it poses a low risk. Comet Drycleaners (Map ID 152) is listed under the VCP, IHW, and DCR databases. The site enrolled in the VCP program in 1996 and 2002 due to the groundwater being contaminated with chlorinated solvents. No completion of either VCP has been reported to date. The IHW database lists the site as an inactive generator. The DCR database lists the site as being a drycleaner facility. Due to the site being at a lower elevation, with a gradient away from the subject corridor, and a distance of greater than 750 feet, it poses a low risk to the subject corridor. Admiral Merchant Motor Freight (Map ID 1) is listed under the SPILLS database due to two diesel spills of approximately fifty gallons which occurred in 1998. This incident occurred along northbound IH-35E which lies within the subject corridor. No record of cleanup was located, and spillage from this incident is very likely to have reached the soil 12 and seeped into the groundwater. Therefore, this site poses a moderate risk to activities at the subject corridor. IH-35E and Valley View Lane (Map ID 9) is listed under the SPILLS database due to a 100 gallon diesel spill which occurred in 1998. This incident occurred at the intersection of IH-35E and Valley View Lane which lies within the subject corridor. According to the SPILLS database, Farmers Branch Creek was affected by this incident. No record of cleanup was located and spillage from this incident is very likely to have also reached the soil and seeped into the groundwater. Therefore, this site poses a moderate risk to activities at the subject corridor. IH-635 and Coit Road (Map ID 11) is listed under the SPILLS database due to an 800 gallon unleaded gasoline spill which occurred on top of the overpass in 1995. No record of cleanup was found, and due to the large volume of this spill, it is likely that a substantial amount of spillage could have runoff into the soil and seeped into the groundwater. This site is located within the subject corridor; therefore this site poses a moderate risk to activities at the subject corridor. S IH-35E 500 feet past Valley View Exit (Map ID 13) is listed under the SPILLS database due to a 30 gallon diesel spill that occurred onsite in 1997. The incident occurred within the subject corridor and no cleanup was reported. It is likely that spillage could have runoff into the soil and seeped into the groundwater, therefore the site poses a moderate risk to activities at the subject corridor. 13 226 .31 mi. H 58 .06 mi L 143 .16 mi H 153 .17 mi L 79 .08 mi. 134 .15 mi. Crews Plating, Inc 2530 Merrell Drive Dallas, TX IOP NFRAP CERCLIS MSWLF DCR ERNS HMIRS PST LPST TRI RCRAInfo IHW VCP DOCKETS Location Potential Envir. Risk (L,M ,H) SPILLS Elevation Distance Map ID Table 1: Summary of Database Findings Comments CERCLIS- illegal dumping of electroplating waste into city sewer and ditches, suspected 10,000 gallon tank of electroplating waste and sledges on site. VCP- enrolled 1998, no record of completion L X X L X L X X DOCKETS- CWA violation (oil spill) 1997 The New Datsun Corporation 13130 Preston Road Dallas, TX L X X X VCP- groundwater contaminated . enrolled 2004, completed 2005 L The Dallas City Landfill 11535 Newberry Dallas, TX L H BWay 13401 Denton Drive Farmers Branch, TX CXY Energy Offshore, Inc 12790 Merit Drive Dallas, TX ORYX Energy Corporation 13155 Noel Road Dallas, TX L X DOCKETS- CWA permit violation (effluent) 1998 X X X 14 X X X MSWLF- closed landfill NFRAP- site archived 1993 VCP- enrolled 2001, groundwater contaminated, no remediation reported to date. LPST- groundwater impact 2001. final concurrence issued CERCLIS RCRAInfo DOCKETS .03 mi. L Omega Optical Company 13515 North Stemmons Freeway Farmers Branch, TX L X X 17 .04 mi. H Dallas Castle MPG, Inc 11130 Malibu Drive Dallas, TX L X X X X 20 .04 mi. L Bankston Lincoln Mercury 4747 LBJ Freeway Dallas, TX L X X X X PST- one gasoline tank in use 21 .04 mi. H Showcase Chevrolet 5327 LBJ Freeway Dallas, TX L X X X X IHW- active generator of hazardous waste LPST- 1992, minor soil contamination 23 .06 mi. L Collision Masters 14011 N. Stemmons Freeway Dallas, TX L X X X IHW- active generator of hazardous waste 26 .05 mi L Mobil Oil Corporation 13211 Stemmons Freeway Dallas, TX L X X 15 X X IOP 14 X X NFRAP X MSWLF L DCR Exxon Mobil Corporation 13115 Harry Hines Boulevard Farmers Branch, TX X X ERNS L HMIRS .05 mi. PST 25 LPST L TRI 10620 Stemmons Freeway Dallas, TX IHW = VCP Elevation Potential Envir. Risk (L,M ,H) SPILLS Distance .09 mi. Map ID 89 Location Comments HMIRS- 300 gal gasoline spill 1996 PST- 2 6000 gal diesel tanks in use PST- 3 underground gasoline tanks in use LPST- Leak reported 1989, final concurrence issued, case closed. IHW- active generator of numerous types of hazardous waste IHW- inactive as of 2004 (see map ID 17 below) PST- 3000 gallon gasoline AST in use LPST- Leak reported 1996, Final concurrence issued, case closed PST- 3 underground gasoline tanks in use LPST- 1989, groundwater impacted, final concurrence issued IOP NFRAP CERCLIS MSWLF DCR ERNS HMIRS PST LPST TRI RCRAInfo IHW VCP DOCKETS Potential Envir. Risk (L,M ,H) SPILLS Elevation Distance Map ID Location Comments PST- 4 underground gasoline tanks in use LPST- 1992, no groundwater impact, final concurrence issued PST- 3 gasoline, 1 diesel underground storage tanks in use LPST- 1993, groundwater impacted, final concurrence issued, case closed PST- 3 underground gasoline tanks in use LPST- 1998, groundwater impacted, final concurrence issued H Midway Cleaners 12924 Midway Road Dallas, TX L X X X X .06 mi. L Star Enterprises 13010 Preston Road Dallas, TX L X X X X 48 .06 mi. H Mobil Oil Corporation 12920 Preston Road Dallas, TX L X X X X 49 .06 mi. = L X X X X PST- 3 gasoline, 1 diesel tanks in use 52 .06 mi. L L X X X LPST- 1993, soil contamination only, final concurrence issued, case closed. 53 .06 mi. L L X X X X LPST: 1993, groundwater impacted, final concurrence issued 67 .07 mi L L X X X X LPST: 1992, groundwater impacted, final concurrence issued 42 .09 mi. 47 62 .07 mi. L Exxon Mobil Corporation 12969 Preston Road Dallas, TX Texaco Station 7940 LBJ Freeway Dallas, TX Exxon Mobil Corporation 11925 Josey Lane Dallas, TX Exxon RAS 6 3700 12004 Webb Chapel Road Farmers Branch, TX Forest Lane Porsche 2640 Forest Lane Dallas, TX LPST- 1989, groundwater impacted, final concurrence issued L X X X X PST- 22 underground 99- gallon tanks of unknown contents in use. 16 65 .07 mi. L Exxon Mobil Corporation 4205 LBJ Freeway Farmers Branch, TX 68 .07 mi. L Shell SVC Station 12103 Webb Chapel Road Farmers Branch, TX L 2 .01 mi. H US Fleet Services IH 35E and Valwood Pkwy Farmers Branch. TX M X X 5 .01 mi. = L X X 6 .01 mi. H 6 .01 mi. H Mission Transport Company IH635 at Coit Road Dallas, TX Flint, Inc E LBJ Freeway at Josey Lane Exit Dallas, TX McClendon Trucking Company E LBJ Freeway at Josey Lane Exit Dallas, TX L X X X X X X X IOP NFRAP CERCLIS MSWLF DCR ERNS HMIRS PST LPST TRI RCRAInfo IHW VCP DOCKETS Potential Envir. Risk (L,M ,H) SPILLS Elevation Distance Map ID Location Comments LPST- 1996, groundwater impacted, final concurrence issued PST- 3 gasoline, 1 used oil, 1 diesel underground storage tanks in use LPST: 1995, designated major or minor aquifer impacted, final concurrence issued PST: 2 of unknown content and 2 gasoline underground storage tanks in use ERNS: 100 gallon diesel spill 1998, SPILLS: 60 gallon diesel spill 1990, 46000 lb calcium lignosulfate spill 1992, 100 gallon diesel spill 1994, 200 gallon diesel spill 1998 ERNS: 65 gallon gasoline spill 1989 SPILLS: “ “ M X ERNS: 50 gallon solvent ink spill, 1998 M X ERNS: 1998. 200 gallon oil: diesel 17 IOP NFRAP CERCLIS MSWLF DCR ERNS HMIRS PST LPST TRI RCRAInfo IHW VCP DOCKETS Potential Envir. Risk (L,M ,H) SPILLS Distance 18 Elevation Map ID 109 .11 mi. Location Comments IOP: applied 1998 due to groundwater contamination VCP: enrolled 1997, completion not reported PST: 1 gasoline, 1 unknown underground storage tank LPST: 1987, groundwater impacted, final concurrence issued PST: 3 gasoline, 1 diesel tanks in use LPST: 1992, groundwater impacted, final concurrence issued LPST- 1990, groundwater impacted, likely to migrate offsite, final concurrence issued PST: 3 gasoline underground storage tanks in use LPST: 1988, groundwater impacted, final concurrence issued H Days Inn Hotel 8051 LBJ Freeway Dallas, TX L .04 mi. L Buddy’s Texaco 2360 Valwood Parkway Dallas, TX L X X 19 .04 mi. L Chevron 105954 14051 Harry Hines Boulevard Dallas, TX L X X 24 .05 mi. L Tempo Mechanical 13737 Stemmons Freeway Dallas, TX L 28 .05 mi. H Texaco 11404 IH35E Dallas, TX L X X 28 .05 mi. H Exxon 2405 Royal Lane Dallas, TX L X LPST: 1992, groundwater impacted, final concurrence issued X X PST: 1 UST of unknown content in use LPST: 1989, domestic water supply well intake impacted, final concurrence issued 43 .06 mi. Midway Texaco 4316 IH 635 Dallas, TX X X X L 18 X X L 635 Diamond Shamrock 12950 Coit Rd Dallas, TX L .07 mi. H Rodger Meier Cadillac 4707 IH635 Dallas, TX L 66 .07 mi. H Graystone Place 2727 IH635 Dallas, TX L 8 .01 mi. L 15 .01 mi. L 93 .09 mi. L 98 .10 mi. 102 .10 mi. 51 .07 mi. 60 NW Corner IH35E and Manana Drive Dallas, TX City of Dallas property 2300 West Walnut Hill Dallas, TX Concourse Office Park 6310-6390 LBJ Freeway Dallas, TX X X X X X X X L IOP NFRAP CERCLIS Comments PST: 2 gasoline underground storage tanks in use LPST: 1987, groundwater impacted, final concurrence issued VCP: enrolled 1990, groundwater contaminated, remedy: excavation completed 2003 LPST: 1990, groundwater impacted, concurrence pending documentation of well plugging PST- 1 diesel underground storage tank in use LPST- 1990, groundwater impacted, final concurrence issued L L MSWLF DCR ERNS HMIRS PST LPST TRI RCRAInfo IHW VCP DOCKETS Potential Envir. Risk (L,M ,H) SPILLS Elevation Distance Map ID Location X X Landfill site proposed 1996, no permits issued to date X Landfill in operation prior to 1974 (grandfather site) VCP- enrolled 1998, completed 2000, soil contaminated X H John Roberts BMW 2536 Forest Lane Dallas, TX L X H Midway Plaza 12801 Midway Road Dallas, TX L X X X 19 X VCP- enrolled 2005, no completion reported, soil and groundwater contaminated with metals and chlorinated solvents VCP- enrolled 1998, completed 2000, soils and groundwater contaminated with solvents L Sam’s Cleaners 2903 Forest Lane Dallas, TX L X .17 mi L Comet Drycleaners 12817 Preston Road Dallas, TX L X X 1 .01 = 9 .01 mi = 11 .02 mi. H 13 .02 mi. = Admiral Merchant Motor Freight IH35E just south of IH635 Dallas, TX IH35 and Valley View Lane Dallas, TX IH635 and Coit Road Dallas, TX S IH35 500 feet past Valley View Exit Dallas, TX X IOP NFRAP CERCLIS MSWLF DCR ERNS HMIRS PST LPST TRI RCRAInfo IHW VCP DOCKETS Potential Envir. Risk (L,M ,H) SPILLS Distance 152 Elevation Map ID 110 .11 mi. Location Comments VCP- enrolled 2002, no completion reported, groundwater contaminated with VOCs and chlorinated solvents VCP- enrolled 1996, no completion reported, groundwater contaminated with chlorinated solvents. VCP- enrolled 2002, groundwater contaminated with chlorinated solvents, no completion reported M X 50-75 gallon diesel spill 1998 50 gallon diesel spill 1998 M X 100 gallon diesel spill 1998 M X 800 gallon gasoline spill 1995 M X 30 gallon diesel spill 1997 Potential Environmental Risk – L - low, M - moderate, H – high X - Database entries identified within the relevant ASTM search radius Elevation- H-Higher than corridor, L-Lower than corridor 20 Section 2 Findings In December, 2006, a review of environmental regulatory databases was undertaken as part of a Limited Phase I Environmental Site Assessment (ASTM 1527-00) for the proposed construction project on IH-635 from Luna Road to US 75 (9.25 miles) and on IH-35E from Loop 12 to Valwood Parkway (4.75 miles) (Figure 1). TxDOT requested that a reevaluation be performed on the limited Phase I ESA with particular emphasis on potential impacts of contaminated groundwater on the project. The original database review determined all listed sites to be of “low risk” to the subject corridor. For ground level construction, the risk might be “low”; however, several segments of the proposed project could be depressed, tunneled, and/or elevated and, as such, are likely to encounter groundwater during construction. The purpose of this reevaluation is to provide TxDOT with further clarification on potential groundwater impacts associated with the proposed methods of construction. Upon review of the regulatory database and any additional groundwater information (including depth, gradient, and contamination), the levels of risk will be reevaluated according to this site specific information. Sites with potential or documented groundwater contamination were mapped and color coded by potential to impact groundwater in the project area (Figure 1). In addition, a map showing approximate surface topography with color coded directions of slope is provided (Figure 2). Summary of Findings A reevaluation of a Limited Phase I Environmental Site Assessment (ASTM 1527-00) for the proposed project on IH-635 from Luna Road to US 75 (9.25 miles) and on IH-35E from Loop 12 to Valwood Parkway (4.75 miles) was performed. The results of the reevaluation are presented in this report. Based on the tasks completed, the following findings are reiterated: Of the 310 sites listed in the regulatory agency database, 49 were determined upon reevaluation to have the potential to contaminate groundwater at the subject corridor. The 49 sites were identified as sites with documented or probable contamination of groundwater. After further review, the identified 49 sites were ranked according to the level of risk posed to the subject corridor. Seven (7) sites were determined to be of moderate risk and the remaining 42 sites were determined to be of low risk. The sites determined to be of moderate risk all involved spills and are as follows: - S IH-35E 500 feet past Valley View exit (Map ID 13), Dallas, TX due to potential groundwater contamination as a result of a 30 gallon diesel spill in 1998. - IH-635 and Coit Road (Map ID 11), Dallas, TX due to potential groundwater contamination as a result of an 800 gallon gasoline spill in 1995. - IH-35E and Valley View Lane (Map ID 9), Dallas, TX due to potential groundwater contamination as a result of a 100 gallon diesel spill in 1998. - Admiral Merchant Motor Freight (Map ID 1) IH-35E just south of IH-635, Dallas, TX due to potential groundwater contamination as a result of a 50 gallon diesel spill in 1998. 21 - McClendon Trucking Company (Map ID 6), E LBJ Freeway at Josey Lane Exit, Dallas, TX due to potential groundwater contamination as a result of a 200 gallon diesel oil spill in 1998. - Flint, Inc (Map ID 6), E LBJ Freeway at Josey Lane Exit, Dallas, TX due to potential groundwater contamination as a result of a 50 gallon solvent ink spill in 1998. - US Fleet Services (Map ID 2), IH-35E and Valwood Pkwy, Farmers Branch, TX due to potential groundwater contamination as a result of a 100 gallon diesel spill in 1998, a 60 gallon diesel spill in 1990, a 46,000 lb calcium lignosulfate spill in 1992, a 100 gallon diesel spill in 1994, and a 200 gallon diesel spill in 1998. The seven moderate sites were plotted as red and the remaining 42 sites were plotted as yellow in Figure 1. The groundwater flow direction/gradient for each site, if available, was provided as well. Groundwater levels throughout the corridor are widely variable and frequently fluctuate therefore, only groundwater depths at the time of construction are useful in determining the potential risk of contaminated groundwater to activities at the subject corridor. Section 3 Conditions and Limitations A. Special Terms and Conditions This expanded Phase I reevaluation documents the locations of potential groundwater contamination that could impact proposed construction activities along IH-635 from Luna Road to US 75 (9.25 miles) and on IH-35E from Loop 12 to Valwood Parkway (4.75 miles). This expanded Phase I reevaluation is intended to be a document in which available environmental information is compiled to assist TxDOT in making decisions concerning construction activities along the subject corridor. The expanded Phase I reevaluation was completed in general compliance with the scope and limitations of the consensus document known as ASTM E 1527-00. This report is intended as a limited assessment of groundwater contamination that could affect the subject corridor and has been prepared in accordance with generally accepted local assessment practices. No warranties, express or implied, are intended or made. The limitations of this reevaluation should be recognized as TxDOT formulates conclusions on the environmental risks associated with the subject corridor. This screening primarily relied upon a regulatory agency database report and site specific research provided by Geosearch as well as a previous Limited Phase I ESA conducted in December 2006. It was designed to summarize groundwater conditions within the area of study (including gradient and presence of contamination). LGGROUP does not warrant the work of regulatory agencies or other third parties supplying information which may have been used during the preparation of this report. 22 B. Limitations and Exceptions of Assessment To achieve the study objectives stated in this report, LGGROUP personnel were required to base their conclusions on the best information available during the period of the investigation and within the limits prescribed by TxDOT in the contract. No investigative method can completely eliminate the possibility of obtaining partially imprecise or incomplete information. Thus, LGGROUP cannot guarantee that the investigations completely define the degree or extent of any groundwater contamination by hazardous or otherwise harmful substances described in this report or, if no such contamination was found, its absolute absence. Professional judgment was exercised in gathering and analyzing the information obtained, and LGGROUP commits to the usual care, thoroughness, and competence of the environmental profession. This report is not a legal opinion. It does not necessarily comply with requirements defined in any environmental law such as the “innocent landowner defense” or “due diligence inquiry.” Only legal counsel retained by TxDOT is competent to determine the legal implications of any information or conclusions in this report. Except as expressly provided for in our agreement with TxDOT, LGGROUP is not responsible for any effect upon the legal rights, obligations, or liabilities of any party, or for any effect on the financeability, marketability, or value of the property investigated in the study, or for the occurrence or nonoccurrence of any transaction involving the property. C. Methodology Used Preparation of the expanded Phase I reevaluation followed a methodical process in which available information was analyzed and conclusions were drawn regarding the condition of the property in general accordance with ASTM Phase I ESA guidelines. A reevaluation of a previous limited Phase I ESA as well as the regulatory agency used to prepare it was conducted. The purpose of this reevaluation is to provide TxDOT with further clarification on potential groundwater impacts associated with the proposed methods of construction. 23 Signatures of Qualified Environmental Professionals Lyle Winnette, PG (Report review) __________________________ Tom Karan, PE (Report review) __________________________ Jason Sellers (Records review and report preparation) __________________________ Robert Hines (Records review and report preparation) __________________________ Rod Sandoval (Figure preparation) __________________________ 24