The owners of the property enrolled the site into the Land Recycling Program but when the application was reviewed it was unclear if the site qualified. Two monitoring well were placed on site but in locations that were cross gradient to the suspected groundwater flow. Arsenic was the only contaminant found in the soil samples that exceeded a Statewide Standard at 3.8mg/kg in MW1 and 2.56mg/kg in MW2. Arsenic, barium, cadmium, chromium, and lead were found in the groundwater samples at levels just exceeding the standards. Below is the text of the response letter sent to the property owner. July 17, 2002 Liberty Group Iowa Holdings, Inc. c/o Katten Muchin Zavis Rosenman Attn: Jim Mitchell 525 West Monroe Street Chicago, Illinois 60661 Re: Iowa land Recycling Program Enrollment Application Ottumwa Courier 213 East Second Street Ottumwa, Iowa 52501 Dear Mr. Mitchell The Iowa Department of Natural Resources, Contaminated Sites Section, (Department) has completed the review of the above referenced document and at this time it is uncertain if the site qualifies for enrollment into the Iowa Land Recycling Program (LRP). In order to qualify for the LRP a site must show that sampling has exceeded Statewide Standards or that the site is suspected of being contaminated due to a documented spill, soil staining, stressed vegetation, etc. The placement of MW1 and MW2 and the results from the sampling does not clearly indicate that your site is the source. The Department has determined that in order to clarify the site as a candidate for the LRP two additional groundwater wells would be required, one up-gradient and one down-gradient of the suspected source area. If the aquifer has little seasonal variation or the groundwater flow direction was misguesstimated MW1 and MW2 may be outside any plume caused by leakage from the sumps. Metals in the soils would tend not to migrate in the horizontal direction; therefore, a soil sample should be collected in a suspected source area. If MW1 and MW2 have been removed then a third well would need to be placed in order to get a better idea on which way groundwater is flowing. The up-gradient boring (groundwater and soils) would be located in a manor as to be clear of any contamination that may have been deposited at the site but in the groundwater path of the site. This well would be used to determine the baseline groundwater and soils condition at the site. The second well would need to be located in the down-gradient direction of the suspected source either in the basement or by the southwest face of the building along East Second Street. The basement location would be the best for soil sampling. If MW1 and MW2 have been removed then a third well would need to be placed in an area helpful in determining the size of the plume but also to form a triangle with the other two wells for triangulating groundwater flow. Direct push equipment can be used for core sampling and well placement. Again, at this time, not enough information is known to complete the enrollment process for the LRP. If you have any questions or need further information please feel free to call or e-mail at (515) 281-4171 or dan.cook@dnr.state.ia.us. Sincerely, Daniel Cook Environmental Specialist Senior Contaminated Sites c: Morris Preston, Preston Engineering, Inc., 4436 N. Brady Street, Davenport, Iowa 52806 IDNR Field Office 6