In August 2009, a Phase I ESA was completed on the Property. RECs identified in the Phase I ESA included: � The historical operations at the former Monongahela Glass Co. and Fairmont Box Factory. � Unauthorized dumping on various portions of the property, including the ruined brick outbuildings. In addition, a water-filled pit was observed in one of the ruined brick outbuildings located on the Property near the south end of the Fairmont Box Factory building. � Fill materials in the cleared field at the intersection of 14th Street and Minor Avenue. For the purposes of the Limited Phase II ESA, the RECs identified in the Phase I ESA have been divided as follows: � REC-1 � The historical operations at the former Monongahela Glass Co. and Fairmont Box Factory, and unauthorized dumping. COPCs may include volatile organic compounds VOCs, PAHs, PCBs, RCRA metals arsenic, barium, cadmium, chromium, lead, mercury selenium, and silver, and total petroleum hydrocarbons TPH. � REC-2 � Observed dumping on the western parcel. Dumped items principally consist of used tires, discarded household items, scrap wood, concrete pipe, cinder blocks, and similar debris however, empty drums, totes, paint cans, and other containers which may have contained hazardous substances or petroleum products were observed among the debris. COPCs may include RCRA metals, VOCs, PAHs, and TPH. � REC-3 � Observed dumping on the northeastern portion of the property, downslope from former Fairmont Box Factory. Dumped items principally consist of used tires, discarded household items, scrap wood, concrete pipe, cinder blocks, and similar debris however, empty drums, totes, paint cans, and other containers which may have contained hazardous substances or petroleum products were observed among the debris. COPCs may include RCRA metals, VOCs, PAHs, and TPH. � REC- 4 � Fill materials in the cleared field at the intersection of 14th Street and Minor Avenue. COPCs may include RCRA metals, VOCs, and PAHs. The Phase I ESA recommended that a Limited Phase II ESA be conducted to evaluate the RECs. A SAP December 2009 provided a Limited Phase II ESA scope of services to address the RECs for the Property. Limited Phase II ESA work was completed on March 2, 2010. Eight soil borings, four hand augers, and one groundwater screening sample were completed during this investigation. The investigation activities and laboratory analysis completed as part of the Limited Phase II ESA resulted in the following conclusions: � One concentration of lead detected in the shallow soil sample collected in REC-3 exceeded the WVDEP risk based de minimis standard for industrial soils. While additional COPCs were detected in the soils, concentrations were below the applicable standards for industrial land use. Since the majority of detected COPCs likely represented localized shallow impacts, it was considered excessive to implement a complete a risk assessment consisting of, but not limited to, statistical analyses, exposure duration, exposure frequency, and geotechnical data for each individual REC. However, due to the lead exceedance in a soil sample collected from REC-3, ALM calculations were completed to determine site-specific cleanup levels for the construction/excavation and commercial/industrial scenarios. The soil lead cleanup values for the construction/excavation and commercial/industrial scenarios for REC-3 were determined to be 1,344 mg/kg and 2,903 mg/kg, respectively. The maximum soil concentration for REC-3 is 1,160 mg/kg. Therefore, the lead concentration present in the soil in REC-3 was below the calculated site-specific clean-up value, and may remain in place. � Concentrations of several VOCs detected in the groundwater screening sample collected from a temporary monitoring well installed at SB-1 exceeded the respective WVDEP risk-based de minimis standards for groundwater. � Concentrations of several COPCs were detected in REC-1, REC-2, and REC-4 that exc