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HomeMy WebLinkAboutDERR-2024-012267 Summary Report of January 2024 PlumeStop® Injections in Groundwater VCP-C049 Cottonwood Heights, Utah Salt Lake County, Utah Prepared for: Linde Gas & Equipment Inc. (formerly Praxair Distribution, Inc.) 6880 South 2300 East Cottonwood Heights, Utah Prepared by: Stantec Consulting Services Inc. 2890 East Cottonwood Parkway, Suite 300 Salt Lake City, UT 84121 Project No.: 203708160 May 16, 2024 Remedial Task associated with Implementation of October 2023 Proposed Remedial Action Plan for TCE in Groundwater Sign-off Sheet and Signatures of Environmental Professionals Project No.: 203708160/05-delivs/delivs/2024/SumRept PlumeStop Injects 1 This document was prepared by Stantec Consulting Services, Inc. (“Stantec”) for Linde Gas & Equipment Inc. (the “Client”). The conclusions in this Report are Stantec’s professional opinion, as of the time of the Report, and concerning the scope described in the Report. The opinions in the document are based on conditions and information existing at the time the scope of work was conducted and do not take into account any subsequent changes. The Report relates solely to the specific project for which Stantec was retained and the stated purpose for which the Report was prepared. The Report is not to be used or relied on for any variation or extension of the project, or for any other project or purpose, and any unauthorized use or reliance is at the recipient’s own risk. Stantec has assumed all information received from the Client and third parties in the preparation of the Report to be correct. While Stantec has exercised a customary level of judgment or due diligence in the use of such information, Stantec assumes no responsibility for the consequences of any error or omission contained therein. This Report is intended solely for use by the Client in accordance with Stantec’s contract with the Client. While the Report may be provided by the Client to applicable authorities having jurisdiction and to other third parties in connection with the project, Stantec disclaims any legal duty based upon warranty, reliance or any other theory to any third party, and will not be liable to such third party for any damages or losses of any kind that may result. Prepared by: John G. Russell, III, CPG Utah PG #5216074-2250 Sr. Hydrogeologist, Environmental Risk Manager Reviewed by: Cody Fauth Geology SUMMARY REPORT OF JANUARY 2024 PLUMESTOP® INJECTIONS IN GROUNDWATER Project No.: 203708160/05-delivs/delivs/2024/SumRept PlumeStop Injects ii Table of Contents 1.0 EXECUTIVE SUMMARY .................................................................................................1.1 1.1 INTRODUCTION ........................................................................................................... 1.1 1.2 BACKGROUND............................................................................................................ 1.1 2.0 JANUARY 2024 GROUNDWATER TREATMENT PROGRAM ..........................................2.1 2.1 PLUMESTOP CARBON PRODUCT ............................................................................... 2.1 2.2 PLUMESTOP INJECTION PROGRAM ........................................................................... 2.1 2.2.1 Preparation in Advance of Injection Program ....................................... 2.1 2.2.2 January 2024 Microbial Injection Locations and Process ...................... 2.2 2.2.3 Monitoring for Satisfactory Distribution of Injected PlumeStop ............. 2.5 3.0 REMEDIAL PROGRESS MONITORING PROGRAM .......................................................3.1 3.1 POST-REMEDIAL, GROUNDWATER QUALITY MONITORING PROGRAM ................... 3.1 3.1.1 Monitoring Schedule ................................................................................ 3.1 3.2 ONGOING SEMI-ANNUAL, INDOOR AIR AND SUB-SLAB DEPRESSURIZATION SYSTEM (SSDS) MONITORING PROGRAM .................................................................. 3.2 LIST OF FIGURES IN TEXT: Figures A and B REGENESIS Summary Report Figures FOLLOWING TEXT: Figure 1 Monitoring Well Location Map Figure 2 Groundwater Monitoring Wells and Abandoned Groundwater Sampling Borings SUMMARY REPORT OF JANUARY 2024 PLUMESTOP® INJECTIONS IN GROUNDWATER Project No.: 203708160/05-delivs/delivs/2024/SumRept PlumeStop Injects iii Abbreviations ft Feet LGE Linde Gas & Equipment Inc. MCL Maximum Contaminant Level MDL Method Detection Limit µg/m3 Micrograms per cubic meter µg/kg Micrograms per kilogram (aka, parts per billion-ppb; soil) µg/L Micrograms per liter (aka, parts per billion-ppb; groundwater) mg/kg milligrams per kilogram (aka, parts per million-ppm) PRB Permeable Reactive Barrier PCE Tetrachloroethylene (aka, perchloroethylene or perc) PVC Polyvinyl Chloride PDI Praxair Distribution, Inc. PRAP Proposed Remedial Action Plan QA/QC Quality Assurance/Quality Control RL Reporting Limit RSL Risk-Based Screening Level SSDS Subsurface Soil Gas Depressurization System TCE Trichloroethylene UDEQ (UDAQ/UDERR) Utah Department of Environmental Quality (Division of Air Quality/Division of Environmental Response and Remediation) US EPA United States Environmental Protection Agency VISL Vapor Intrusion Screening Level VOC Volatile Organic Compound VCP Voluntary Cleanup Program SUMMARY REPORT OF JANUARY 2024 PLUMESTOP® INJECTIONS IN GROUNDWATER EXECUTIVE SUMMARY May 16, 2024 Project No.: 203708160/05-delivs/delivs/2024/SumRept PlumeStop Injects 1.1 1.0 EXECUTIVE SUMMARY 1.1 INTRODUCTION On behalf of Linde Gas & Equipment Inc. (LGE, formerly Praxair Distribution, Inc. [PDI]), Stantec Consulting Services Inc. (Stantec) has prepared this report to document groundwater treatment activities conducted during January 2024 at and near the LGE facility located at 6880 South 2300 East in Salt Lake City, Utah. Reference Figures 1 and 2 for regional and site-specific location maps. The remedial program was administered in accordance with the protocol proposed within LGE’s October 2023 Proposed Remedial Action Plan (PRAP), which was approved by the Utah Department of Environmental Quality, Voluntary Cleanup Program (UDEQ, VCP) in early January 2024. REGENESIS® Remediation Services’ (REGENESIS) injected proprietary permeable reactive barriers (PRBs) including PlumeStop® Liquid Activated CarbonTM (collectively, “PlumeStop”) into trichloroethylene- (TCE) impacted groundwater located beneath localized portions of the LGE property and downgradient (northwest/west) of the LGE property. The injected carbon product is intended to capture TCE within the aquifer for supplemental natural reduction in TCE concentrations in groundwater located downgradient of the carbon injection-points. In turn, it is anticipated that the reduction in TCE concentrations in groundwater will result in a reduction of gaseous-phase TCE in the unsaturated vadose zone, thereby reducing or eliminating the potential for intrusion of gaseous-phase TCE into subsurface soil gas and overlying buildings. This report provides a summary of the field activities and resources associated with the January 2024 injection program and future-planned environment monitoring to investigate the progress and effectiveness of the injections in pursuit of VCP site closure. As detailed in the PRAP, the next report that will be submitted to the UDEQ will summarize the first quarter of routine monthly groundwater quality monitoring, sampling, and analytical laboratory result reports following the January 2024 injections. Thereafter, three sequential quarterly (July, October, and January) summary reports will be submitted to the UDEQ, reporting the results of quarterly monitoring/sampling of groundwater for a timeframe of one year subsequent to the January 2024 injections. 1.2 BACKGROUND Of the 15 groundwater monitoring wells that are part of the VCP site, TCE has been detected in groundwater at concentrations above either the Method Detection Limit (MDL) or Reporting Limit (RL) in wells MW-2, MW-3, MW-6, HP-2, HP-3, HP-5, and HP-9 (reference Figure 2). The last sampling date during which a TCE concentration in any of the monitoring wells was at or exceeded the UDEQ Cleanup Level of 5 micrograms per liter (aka, parts per billion-ppb) was at well MW-2 in October 2014 (5.0 ppb in both the MW-2 normal and duplicate samples, respectively). TCE concentrations in groundwater have declined in all monitoring wells since SUMMARY REPORT OF JANUARY 2024 PLUMESTOP® INJECTIONS IN GROUNDWATER EXECUTIVE SUMMARY May 16, 2024 Project No.: 203708160/05-delivs/delivs/2024/SumRept PlumeStop Injects 1.2 monitoring began in 2005, with the highest concentrations detected during the most recent sampling event of April 2023 being 1.5 ppb at well HP-9 and 1.1 ppb at HP-5. The US EPA Vapor Intrusion Screening Level (VISL) “target groundwater concentration” for TCE in groundwater with risk for possible vapor intrusion into overlying buildings is 1.19 ppb. It is anticipated that reducing and/or eliminating TCE concentrations in groundwater (e.g., TCE liquid-phase mass) should result in a corollary reduction in TCE concentrations in overlying subsurface soil gas (TCE gaseous-phase mass). In turn, the reduction in TCE mass within subsurface soil gas should reduce the potential for subsequent migration of gaseous-phase TCE into overlying buildings. REGENESIS’ PlumeStop product was injected into the upper 10 feet of the aquifer in injection- points located at and downgradient of the LGE property. As groundwater flows/attenuates naturally through the PlumeStop treatment/injection areas, the injected carbon will intercept and capture TCE in groundwater, thereby reducing the total mass of TCE attenuating farther downgradient (toward the northwest/west) from the PRB injection areas. With time, the injected PlumeStop will reduce TCE concentrations in groundwater located in the vicinity and downgradient of injection-points to below the US EPA VISL groundwater target concentration deemed protective of overlying indoor air quality. This report presents a summary of the January 2024 injections of PlumeStop at the project site. SUMMARY REPORT OF JANUARY 2024 PLUMESTOP® INJECTIONS IN GROUNDWATER JANUARY 2024 GROUNDWATER TREATMENT PROGRAM May 16, 2024 Project No.: 203708160/05-delivs/delivs/2024/SumRept PlumeStop Injects 2.1 2.0 JANUARY 2024 GROUNDWATER TREATMENT PROGRAM 2.1 PLUMESTOP CARBON PRODUCT REGENESIS’ PlumeStop consists of carbon particles milled to 1 to 2 micrometers in size. The particle size and the proprietary surface chemistry allow the carbon particles to be suspended as a colloid in the subsurface. The material was formulated to not only flow as a colloidal liquid, but also allow the PlumeStop carbon to attach to soil particles within the aquifer. The physical appearance of PlumeStop is similar to that of black to dark-gray ink. PlumeStop is designed to work quickly by allowing sorption of contaminants from the dissolved liquid-phase to the carbon, resulting in rapid reductions of contaminant concentrations within groundwater. 2.2 PLUMESTOP INJECTION PROGRAM 2.2.1 Preparation in Advance of Injection Program In advance of the project, Stantec subcontracted GPRS, Inc., a nationally recognized Ground Penetrating Radar (GPR) consulting firm, to conduct a local GPR buried utility-locate throughout the proposed injection areas. Stantec also coordinated a formal Blue Stakes of Utah Utility Locators’ utility-locate. Likewise, Stantec communicated with on-site LGE staff regarding potential buried utilities at the LGE property. No buried utilities were identified within the proposed injection areas and none were encountered during the project. REGENESIS’ subcontracted drilling firm, Interphase Drilling, and all REGENESIS injection equipment, products, and field staff, mobilized to the LGE site during January 2 and 3, 2024. Stantec helped coordinate mobilization efforts between all parties and on-site LGE representatives. Before initiating field work activities on January 4th, Stantec and LGE orchestrated an on-site health and safety ‘Kick-off Meeting.’ Site access, proposed project details, and health and safety related concerns were discussed with on-site LGE, REGENESIS, Interphase Drill, and Stantec representatives, with all field activities coordinated through LGE’s on-site Operations Manager, Mr. Dusty Wadsworth. Prior to starting the project, a jobsite safety inspection was completed and documented, with introductory communications related to on-site, potential hazards, directions to the closest hospital, and emergency contacts discussed and documented. Additional activities conducted prior to and during field work included use of a LGE snow blower to help clear land surfaces of thick snow cover for drill rig access and provide a safe working environment. No health and safety-related issues were encountered during implementation and completion of field activities. SUMMARY REPORT OF JANUARY 2024 PLUMESTOP® INJECTIONS IN GROUNDWATER JANUARY 2024 GROUNDWATER TREATMENT PROGRAM May 16, 2024 Project No.: 203708160/05-delivs/delivs/2024/SumRept PlumeStop Injects 2.2 2.2.2 January 2024 Microbial Injection Locations and Process During January 4 through 19, 2024, Stantec geologist, Mr. Cody Fauth, observed REGENESIS and Interphase Drilling implement PlumeStop injections at the LGE and Residence B properties. Injection-points are identified in the below aerial image (Figure A) from REGENESES’. Each injection borehole was advanced by the direct-push boring process, whereby product was then pressure-injected, utilizing downhole, steel rods, from the ground surface into the upper 10 feet of the aquifer (approximately 9 to 19 feet beneath the Residence B property and 14 to 24 feet below the LGE property). FIGURE A. Injection-point map LGE Property SUMMARY REPORT OF JANUARY 2024 PLUMESTOP® INJECTIONS IN GROUNDWATER JANUARY 2024 GROUNDWATER TREATMENT PROGRAM May 16, 2024 Project No.: 203708160/05-delivs/delivs/2024/SumRept PlumeStop Injects 2.3 On-site, potable water sources were used for slurry-mixing REGENESIS products within a REGENESIS portable trailer located near the injection-points. As depicted below, the portable trailer was equipped with two interior 350-gallon mixing tanks, pumps, and delivery systems manifolded for direct connection to each of the injection-points. Mixed REGENESIS product was pressure-slurried into each injection-point assembly for injection into the subsurface. FIGURE B. General schematic of portable trailer In summary, the PlumeStop product was injected at the following volumes and rates, which differed between the two properties as explained in more detail below: • LGE Property: A total of 15,400 gallons of PlumeStop at an average injection rate approximating 4.44 gallons per minute (gpm) and an average injection pressure of 25 pounds per square inch (psi). • Residence B: A total of 1,357 gallons of PlumeStop at an average injection rate approximating 2.34 gpm and an average injection pressure of 39 psi. Before starting field work, REGENESIS advised that there is usually a rise in the local water table when injecting PlumeStop product into the upper 10 feet of an aquifer. The rise in elevation of the water table varies between sites and depends on site-specific, subsurface aquifer lithologic and hydrogeologic characteristics. The water table beneath the western portion of the LGE property was measured in monitoring wells at a subsurface depth of approximately 14 feet below grade, as of January 2024. Since there were no significant concerns for affecting a rise in the water table beneath western portions of the LGE property, REGENESIS utilized an average PlumeStop product injection rate approximating 4.44 gpm and an injection pressure of 25 psi, similar to other REGENESIS product injection sites. No issues were encountered with the injection program. SUMMARY REPORT OF JANUARY 2024 PLUMESTOP® INJECTIONS IN GROUNDWATER JANUARY 2024 GROUNDWATER TREATMENT PROGRAM May 16, 2024 Project No.: 203708160/05-delivs/delivs/2024/SumRept PlumeStop Injects 2.4 Historically, the depth to the water table beneath and in close proximity to Residence B was approximated between 10 to 11 feet below natural grade. The elevation of the Residence B basement floor is approximately nine feet below natural grade (i.e., one to two feet above the historical water table). In consideration of the shallow water table beneath the Residence B property, and the potential for possible water intrusion risk to the basement, Stantec and REGENESIS observed the installation of two shallow, 1.5-inch diameter groundwater monitoring piezometers located adjacent to the eastern-most side of the Residence B home, namely PZ-1 and PZ-2 (reference Figure A). Stantec monitored water levels in the wells prior to and during the product injection program, investigating for possible rise/fluctuations in the water table as extrapolated by the water levels within the wells. The drilling firm was prepared to reduce the volume and rate of injection of product, if deemed necessary to prevent potential risk of water intrusion. The two piezometers, each of which was constructed of 15 feet of 1.5-inch diameter, 0.01- slotted, Schedule 40 PVC well screen, were drilled and installed as close as practicable to (within several feet of) the side of the home. Each wellhead has an approximate 12-inch stick-up above the ground surface and is equipped with a dedicated PVC slip-on cap. Water levels in the monitoring wells were monitored by means of a hand-held, electronic water level indicator capable of measuring to an approximate 0.01-foot accuracy. The static water levels in PZ-1, PZ-2, and nearby monitoring well HP-5 approximated 10.5 feet below grade, before the injection program began. The initial injection-point in the residence backyard was drilled approximately 6 feet west of injection-point IP-45 identified on Figure A. The initial injection-point was used as a preliminary pilot-test borehole, whereby REGENESIS and Stantec monitored water levels in monitoring wells PZ-1, PZ-2, and HP-5, while the drilling firm injected the PlumeStop/water slurried product at the same injection rate and pressure as implemented while injecting at the LGE property. Immediately upon initiating injection of product within the pilot-test boring, Stantec observed rises in water levels in nearby monitoring wells PZ-1 and HP-5 to an approximate height of between 9- to 9.5-feet below grade, and halted the injection process. The near-instantaneous rise in the localized water table indicated a potential risk to the basement if the injection program continued at the same rate. Another pilot-test injection-point was drilled in the southeastern corner of the residence backyard in the vicinity of injection-point P-74 on Figure A, to investigate the impacts of injecting PlumeStop/water product at similar rates and pressures in an injection-point located as far away from the house as practicable. Injecting at an approximately 4 gpm and a pressure of 25 psi (as implemented at the LGE property) resulted in similar rises in water levels measured in monitoring wells PZ-1, PZ-2, and HP-5 to approximate depth of 9 to 9.5 feet below grade. Stantec stopped the injection program to discuss how the driller might adjust the injection process. SUMMARY REPORT OF JANUARY 2024 PLUMESTOP® INJECTIONS IN GROUNDWATER JANUARY 2024 GROUNDWATER TREATMENT PROGRAM May 16, 2024 Project No.: 203708160/05-delivs/delivs/2024/SumRept PlumeStop Injects 2.5 REGENESIS recommended that we inject a more concentrated PlumeStop product with a smaller volume of intermixed water and at a reduced injection rate at injection-point IP-45, as they had observed success with this approach at other similar sites. REGENESIS claimed that use of a more concentrated PlumeStop product would allow injection of a smaller volume of product at a reduced injection rate, which in turn might affect smaller rises in the local water in the vicinity of the injection-points. The concentrated product would still be injected within the upper 10 feet of the aquifer and would provide more concentrated treatment of local water, as groundwater migrated through the permeable reactive barrier. Likewise, injections of the concentrated PlumeStop product only required one north-south oriented line of injection-points at the residence, as opposed to the two herringbone-oriented, injection rows implemented at the LGE property. Sequentially, injection rates and pressures were adjusted at IP-45, until an injection of concentrated PlumeStop product at a rate of 2.34 gpm and injection pressure of 39 psi resulted in the water levels in monitoring wells PZ-1 and HP-5 stabilizing at a subsurface depth approximating 9.5 feet below grade. Thereafter, the amended injection program was implemented, progressing from IP-45 toward the south and the final injection-point IP-74 (see Figure A). While monitoring water levels in the PZ-1, PZ-2, and HP-5 continually throughout the duration of the injection program, Stantec did not observe water levels in monitoring wells rising to a subsurface elevation that might intersect the basement floor elevation. 2.2.3 Monitoring for Satisfactory Distribution of Injected PlumeStop Stantec and REGENESIS field staff implemented a subsurface soil and groundwater monitoring program located in close proximity to injection-points and designed to investigate local impacts to the subsurface during and following localized PlumeStop injections. The intent of the subsurface investigative activities was to verify that the injected PlumeStop product was emplaced satisfactorily within the upper 10 feet of the aquifer along the permeable reactive barriers. During injections, Stantec monitored the color of water within select groundwater monitoring wells located in close proximity to injection-points, investigating for visible discoloration (black/gray darkening, etc.) of groundwater attributable to injection of PlumeStop product, and observed discoloration of groundwater indicating the presence of PlumeStop within monitoring wells HP-1, HP-2, HP-3, HP-5, HP-8, MW-2 and MW-3. Following local injections of product in the vicinity of monitoring wells MW-2 and HP-5, REGENESIS collected samples of groundwater from the two wells and quantified PlumeStop product at 400 milligrams per liter (aka, parts per million- ppm) in well MW-2 at the LGE property and 50,000 ppm in well HP-5 at the Residence B property. Stantec and REGENESIS also observed the drilling and soil sampling of three soil test borings (CC-1, CC-2, and CC-3 on Figure A), located a few to several lateral feet from injection-points, to investigate to what degree subsurface soils comprising the upper 10 to 15 of the aquifer might be impacted by the adjacent product injections. Subsurface soil samples were collected SUMMARY REPORT OF JANUARY 2024 PLUMESTOP® INJECTIONS IN GROUNDWATER JANUARY 2024 GROUNDWATER TREATMENT PROGRAM May 16, 2024 Project No.: 203708160/05-delivs/delivs/2024/SumRept PlumeStop Injects 2.6 continuously in each of the three soil test borings for visual inspection of discoloration and presence of the PlumeStop product. At each of the three direct-push, soil test borings, soil samples were collected continuously within 5-ft. long, clear acrylic sampling sleeves for visual inspection. Stantec and REGENESIS field staff inspected each soil sample, looking for visible signs of discoloration, indicating PlumeStop product presence within at least the upper 10 feet of the aquifer at each respective location. The field data at borings CC-1, CC-2, and CC-3 indicated successful product injection and distribution in-between and radially-outward from respective injection-points. Following monitoring of the CC-1, CC-2, and CC-3 soil test borings, each boring was backfilled flush to existing grade with hydrolyzed bentonite pellets. SUMMARY REPORT OF JANUARY 2024 PLUMESTOP® INJECTIONS IN GROUNDWATER PROPOSED PUBLIC NOTICE May 16, 2024 Project No.: 203708160/05-delivs/delivs/2024/SumRept PlumeStop Injects 3.1 3.0 REMEDIAL PROGRESS MONITORING PROGRAM The following report sections provide a summary of planned actions intended to monitor the effectiveness and remedial progress, following the January 2024 PlumeStop injection activities. LGE/Stantec’s PRAP should be referenced for more specific details regarding monitoring procedures, protocol, and QA/QC measures that will be implemented as part of the proposed activities. 3.1 POST-REMEDIAL, GROUNDWATER QUALITY MONITORING PROGRAM To monitor the effectiveness and anticipated reduction in TCE concentrations in groundwater following PlumeStop injections, static groundwater levels will be measured within, and groundwater samples will be collected from, the following monitoring wells/piezometers on the schedule that is proposed below. - PZ-1, PZ-2, MW-2, MW-3, MW-6, MW-7, HP-1, HP-2, HP-3, HP-5, HP-8, and HP-9. Remedial objectives for groundwater quality include satisfying TCE and other VOCs’ UDEQ Screening Levels (MCLs and Groundwater Protection Standards), as well as achieving the US EPA VISL “target groundwater concentration” for TCE of 1.19 ppb in groundwater that poses a potential risk for vapor intrusion into overlying buildings. Future groundwater monitoring will be used as a barometer to indicate the degree of success of the PlumeStop injections into the uppermost aquifer at the project site. Future groundwater sampling schedules may be amended and/or discontinued, depending on future media sampling, analytical results, and corollary discussions between the UDEQ and LGE. 3.1.1 Monitoring Schedule Static water levels will be measured and groundwater samples be collected for general water quality parameters and VOC laboratory analysis by Method EPA 8260D/5030A on a monthly basis for three consecutive months, following the PlumeStop injections. The field activities, qualitative observations, and analytical laboratory results associated with the first three monthly monitoring/sampling events (February, March, and April 2024) will be detailed within a forthcoming First Quarter 2024 Groundwater Monitoring Summary Report. Thereafter, the monitoring program will be reduced to quarterly sampling for three consecutive quarters, the total duration of which will provide one (1) complete year (four seasons) of groundwater quality and water level monitoring following the January 2024 PlumeStop injections. Subsequent quarterly sampling events are scheduled tentatively for July and October 2024 and January 2025. LGE/Stantec will prepare a comprehensive “Annual Summary Report” for submittal to the UDEQ, after receipt of the January 2025 laboratory report. SUMMARY REPORT OF JANUARY 2024 PLUMESTOP® INJECTIONS IN GROUNDWATER PROPOSED PUBLIC NOTICE May 16, 2024 Project No.: 203708160/05-delivs/delivs/2024/SumRept PlumeStop Injects 3.2 Following the first year of post-remedial action monitoring, similar groundwater monitoring will continue on a semi-annual (twice per year) schedule, as has been practiced historically, until conditions indicate groundwater quality satisfies UDEQ regulatory requisites and/or as deemed acceptable to both LGE and the UDEQ. 3.2 ONGOING SEMI-ANNUAL, INDOOR AIR AND SUB-SLAB DEPRESSURIZATION SYSTEM (SSDS) MONITORING PROGRAM Routine indoor air (TCE) and SSDS off-gas emission (VOCs) sampling at Residences A and B (see Figure 1) will continue on an ongoing, semi-annual (every six months) basis. The next semi-annual sampling events are scheduled tentatively for April (results pending presently) and October 2024. Samples will be collected while the respective home HVAC systems are operating. As detailed in LGE’s PRAP, it is anticipated that routine indoor air quality and SSDS off-gas emission monitoring, in conjunction with groundwater analytical data, will be used to help gauge how long to continue operating each SSDS. Following receipt of each semi-annual laboratory result report, Stantec will prepare a SSDS Mitigation System Off-Gas Emission Sampling Summary Report for submittal to the UDAQ (with copies to the UDEQ) in accordance with UDAQ Rule R307-401-15. Air Strippers and Soil Venting Projects. Stantec will also submit to the UDEQ a brief summary letter-report that documents the indoor air sampling results. Both reports will include copies of laboratory result reports. As detailed in LGE’s PRAP, starting in the Spring of 2025, the semi-annual SSDS and indoor air quality monitoring program will also include sampling and analysis of existing sub-slab soil gas monitoring probes located within the basements of both residences. It is anticipated that sampling and analysis of sub-slab soil gas, in conjunction with sampling of indoor air and groundwater quality, will verify the effect of the PlumeStop injections. SUMMARY REPORT OF JANUARY 2024 PLUMESTOP® INJECTIONS IN GROUNDWATER FIGURES May 16, 2024 Project No.: 203708160/05-delivs/delivs/2024/SumRept PlumeStop Injects Figure 1 Monitoring Well Location Map Design by: TH Reviewed by: JR & RP Scale: One Inch approxs. 100 feet Date: 7/11/2023 FIGURE 1. Ground Water Monitoring Well Location Map Linde Gas & Equipment Inc. 6880 South 2300 East Street -Salt Lake City, Utah LEGEND 0 100 200 Ground Water Monitoring Well Scale (feet) MW -5 MW -4MW-1 MW -2 MW -3 MW -6 MW -7MW-8 Residence B Residence A LGE Facility MW -9 SUMMARY REPORT OF JANUARY 2024 PLUMESTOP® INJECTIONS IN GROUNDWATER FIGURES May 16, 2024 Project No.: 203708160/05-delivs/delivs/2024/SumRept PlumeStop Injects Figure 2 Groundwater Monitoring Wells and Abandoned Groundwater Sampling Borings Design by Reviewed by Figure 2 - Groundwater Monitoring Wells and Abandoned Groundwater Sampling Borings LEGEND MW-2 /HP-1 Monitoring Well HP-4 Abandoned Sampling Boring Praxair Distribution, Inc. 6880 South 2300 East Street -Salt Lake City, Utah Date RevisedJRRP 2/17/23 0 25 feet 50 Generalized Scale MW -2 MW-1 MW -3 MW-7 MW-6 HP- 4 HP-5 HP-6 HP-7 HP-8 HP-1 HP-2 HP-3 HP- 10 HP- 9