PHASE I ESA VACANT LAND - 8200 MCCOY ROAD ORLANDO, FLORIDA SONIC JOB NO. ECHOPARK-000503-00025-001 H&H JOB NO. SAI-317 JUNE 6, 2020 - CITY OF ORLANDO

 
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PHASE I ESA VACANT LAND - 8200 MCCOY ROAD ORLANDO, FLORIDA SONIC JOB NO. ECHOPARK-000503-00025-001 H&H JOB NO. SAI-317 JUNE 6, 2020 - CITY OF ORLANDO
Phase I ESA
                      Vacant Land

                8200 McCoy Road
                  Orlando, Florida

Sonic Job No. EchoPark-000503-00025-001
                   H&H Job No. SAI-317
                            June 6, 2020
PHASE I ESA VACANT LAND - 8200 MCCOY ROAD ORLANDO, FLORIDA SONIC JOB NO. ECHOPARK-000503-00025-001 H&H JOB NO. SAI-317 JUNE 6, 2020 - CITY OF ORLANDO
Phase I Environmental Site Assessment
                                                            Vacant Land
                                                         8200 McCoy Road
                                                          Orlando, Florida
                                              Sonic Job No. EchoPark-000503-00025-001
                                                        H&H Job No. SAI-317

                                                                      Table of Contents

1.0 Executive Summary ................................................................................................................1
   1.1 Site and Nearby Area Summary ............................................................................................1
   1.2 Findings, Opinions, and Conclusions ....................................................................................2
2.0 Introduction .............................................................................................................................5
   2.1 Purpose and Scope of Services ..............................................................................................5
   2.2 Methodology..........................................................................................................................5
   2.3 Limitations and Exceptions of Assessment ...........................................................................6
   2.4 Special Terms and Conditions ...............................................................................................6
   2.5 Data Gaps and Limitations ....................................................................................................7
3.0 Site and Area Description ......................................................................................................8
   3.1 General Site Description and Use..........................................................................................8
   3.2 Site Structures and Improvements .........................................................................................8
   3.3 Site Owner, Parcel ID, Site Occupant, and Site Contact .......................................................9
   3.4 Vicinity Characteristics .........................................................................................................9
   3.5 Physical Setting .....................................................................................................................9
4.0 Records Review .....................................................................................................................11
   4.1 Standard Environmental Record Sources – Federal, State and Local .................................11
   4.2 Other Records Review .........................................................................................................14
   4.3 Interviews ............................................................................................................................17
   4.4 Historical Use Information ..................................................................................................18
5.0 Site Reconnaissance ..............................................................................................................24
   5.1 Hazardous Substances .........................................................................................................24
   5.2 Storage Tanks, Sumps, Floor Drains, Oil/Water Separators, and Hydraulic Lifts ..............24

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PHASE I ESA VACANT LAND - 8200 MCCOY ROAD ORLANDO, FLORIDA SONIC JOB NO. ECHOPARK-000503-00025-001 H&H JOB NO. SAI-317 JUNE 6, 2020 - CITY OF ORLANDO
5.3 Water and Wastewater Information .....................................................................................24
   5.4 Indications of PCBs .............................................................................................................25
   5.5 Indications of Waste Disposal .............................................................................................25
   5.6 Surface Conditions ..............................................................................................................26
   5.7 Stormwater and Flood Information .....................................................................................26
6.0 Signatures of Environmental Professionals ........................................................................28
7.0 Qualifications of Environmental Professionals Conducting the Phase I ESA ................29

                                                                          List of Figures

Figure 1                   Site Location Map
Figure 2                   Site Map

                                                                      List of Appendices

Appendix A                 User Questionnaire
Appendix B                 Site Photographs
Appendix C                 Orange County Tax Record
Appendix D                 ERIS Documents
Appendix E                 Supporting Documents
Appendix F                 Curriculum Vitae

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PHASE I ESA VACANT LAND - 8200 MCCOY ROAD ORLANDO, FLORIDA SONIC JOB NO. ECHOPARK-000503-00025-001 H&H JOB NO. SAI-317 JUNE 6, 2020 - CITY OF ORLANDO
Phase I Environmental Site Assessment
                                                            Vacant Land
                                                         8200 McCoy Road
                                                          Orlando, Florida
                                              Sonic Job No. EchoPark-000503-00025-001
                                                        H&H Job No. SAI-317

                                                                1.0 Executive Summary

Hart & Hickman, PC (H&H) performed a Phase I Environmental Site Assessment (ESA) of the
vacant land located at 8200 McCoy Road in Orlando, Orange County, Florida (Site or subject Site).
A Site location map is provided as Figure 1. The Phase I ESA was conducted in conformance with
the scope and limitations of ASTM Practice E1527-13. Any exceptions to, or deletions from, this
practice are described in this report.

1.1 Site and Nearby Area Summary

A brief summary of the current and former uses of the subject Site and nearby area is provided
below:

Subject Site
      •      The Site is comprised of an approximately 18.9-acre section of a larger approximately
             69.39-acre parcel of land (Parcel ID: 36-23-30-0000-00-004). The subject Site is improved
             with an approximately 43,000 sq ft concrete-paved parking area in the western portion of
             the Site, unpaved gravel parking areas in the northwestern and south-central portions of the
             Site, and a stormwater retention pond in the southwestern and southern portions of the Site.
             The central and eastern portions of the Site are undeveloped vegetated land.

      •      Historically, the Site was developed for residential and/or agricultural purposes including
             a small structure in the northwestern portion of the Site prior to 1947.                                                 The
             residential/agricultural structure was removed by the early 1950s and the Site remained
             vacant land with potential wetland features and drainage ditch areas until the early 1980s
             when a stormwater pond was constructed on the southwestern portion of the Site. The Site
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PHASE I ESA VACANT LAND - 8200 MCCOY ROAD ORLANDO, FLORIDA SONIC JOB NO. ECHOPARK-000503-00025-001 H&H JOB NO. SAI-317 JUNE 6, 2020 - CITY OF ORLANDO
was used for automotive parking and storage purposes related to a car rental facility and
             car auction operation beginning in the 1990s through the late 2010s. Currently, the Site is
             vacant.

Nearby Area
      •      Currently, properties surrounding the subject Site consist of Off Lease Only automotive
             dealership to the north and northwest, Narcoossee Road to the east with a BP service station
             located beyond, Martin Andersen Beachline Expressway to the south with a 7-Eleven
             service station located beyond, and Copart Auto Auction to the west.

      •      Historically, surrounding properties were primarily undeveloped with few residential and
             agricultural properties prior to the mid- to late 1940s. Residential development in the area
             continued until construction of the Martin Andersen Beachline Expressway which began
             in the mid- to late 1960s. Commercial development in the area followed and continued
             through the late 2010s. Commercial properties surrounding the Site have generally
             consisted of used car sales, storage facilities, rental car companies, and retail gasoline
             service stations.

1.2 Findings, Opinions, and Conclusions

The purpose of a Phase I ESA is to identify Recognized Environmental Conditions (RECs) in
connection with the Site. RECs are environmental conditions that include the presence or likely
presence of hazardous substances or petroleum products on the Site that indicate an existing
release, a past release, or a material threat of a release in structures on the Site, or into the ground,
groundwater, or surface water on the Site. The ASTM standard also defines a subset of RECs
termed a Historical Recognized Environmental Condition (HREC) and a Controlled Recognized
Environmental Condition (CREC). A HREC is defined as a REC which involves a past release of
hazardous substances or petroleum products that has been addressed to the satisfaction of the
applicable regulatory authority and that is not subject to activity and/or use limitations. A CREC
is defined as a REC which involves a past release of hazardous substances or petroleum products

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PHASE I ESA VACANT LAND - 8200 MCCOY ROAD ORLANDO, FLORIDA SONIC JOB NO. ECHOPARK-000503-00025-001 H&H JOB NO. SAI-317 JUNE 6, 2020 - CITY OF ORLANDO
that has been addressed to the satisfaction of the applicable regulatory authority and that is subject
to activity and/or use limitations.

Our findings regarding RECs are based upon our review of historical records and maps; review of
regulatory database records and/or regulatory agency files; interviews with persons familiar with
the Site; observations during the Site reconnaissance; and data evaluation. Based upon our
completion of Phase I ESA activities, H&H has determined the following:

We have performed a Phase I Environmental Site Assessment in conformance with the scope
and limitations of ASTM Practice E1527-13 of the vacant land located at 8200 McCoy Road
in Orlando, Florida (Site). Any exceptions to, or deletions from, this practice are described
in Section 2.0 of this report. This assessment has revealed no evidence of recognized
environmental conditions (RECs) in connection with the Site.

H&H did not identify RECs in connection with the subject Site, but identified the following
potential environmental conditions (PECs); which based on our assessment, we do not consider to
be a REC:

      •      The Site is identified as Alamo Rent A Car on the Leaking Tanks (LST), Storage
             Tank/Contaminated Facility Search (STCS), and Contaminated Sites (DWM Contam)
             databases. Historical records indicate that nine underground storage tanks (USTs) and two
             aboveground storage tanks (ASTs) were formerly installed on the adjacent property to the
             west, approximately 250 ft from the subject Site boundary. In November 1993, a Discharge
             Notification Form (DNF) related to petroleum impacts was reported.                                                       Subsequent
             assessment activities conducted between 1994 and 2007 indicated the presence of
             petroleum impacted soil and groundwater. The release incident is currently managed by
             the Florida Department of Environmental Protection (FDEP) Petroleum Restoration
             Program (PRP).

             The most recent assessment report indicates that 23 monitoring wells were sampled in
             September 2017 and March 2018. Laboratory analytical results indicate the presence of

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PHASE I ESA VACANT LAND - 8200 MCCOY ROAD ORLANDO, FLORIDA SONIC JOB NO. ECHOPARK-000503-00025-001 H&H JOB NO. SAI-317 JUNE 6, 2020 - CITY OF ORLANDO
several petroleum-related compounds above GCTLs. However, the closest monitoring
             well to the subject Site, MW-28 located approximately 225 ft from the subject Site, did not
             indicated the presence of any compounds above groundwater cleanup target levels
             (GCTLs) in 2007 but 2018. A groundwater sample collected from monitoring well MW-
             27, located approximately 240 ft to the west of the subject Site indicated the presence of
             methyl tert-butyl ether (MTBE) at a concentration of 54 micrograms per liter (µg/l) which
             is above the GTCL of 20 µg/l. Groundwater elevation data indicates groundwater flow
             direction is to the southeast. Based on the results of the assessment activities, the FDEP is
             continuing funding for further assessment and remediation.

             Based on the release incident being managed by the FDEP PRP, interpretted groundwater
             flow direction to the southeast, and distance from the Site, H&H does not consider the soil
             and groundwater impacts related to the Alamo Rent A Car LST incident to be a REC.

Business Environmental Risk (BER)
BER’s include risks that can have a material environmental or environmentally - driven impact on
the business associated with current or planned use of the Site, not necessarily limited to those
environmental issues required to be investigated in the standard ASTM scope. The following
BERs may be applicable:

      •      Review of the Federal Emergency Management Agency (FEMA) map indicates that the
             southern and eastern portions of the Site are located in zone A or the 100-year flood hazard
             zone where no base flood elevations have been determined. The northwestern and central
             portions of the Site are located in zone X or an area of minimal flood hazard.

      •      Review of the National Wetlands Inventory (NWI) map indicates that a freshwater pond is
             located in the southwestern portion of the Site, and a freshwater forested/shrub wetland is
             located in the southeastern and eastern portions of the Site.

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PHASE I ESA VACANT LAND - 8200 MCCOY ROAD ORLANDO, FLORIDA SONIC JOB NO. ECHOPARK-000503-00025-001 H&H JOB NO. SAI-317 JUNE 6, 2020 - CITY OF ORLANDO
2.0 Introduction

This report presents the results of a Phase I ESA conducted on the vacant land located at 8200
McCoy Road in Orlando, Orange County, Florida. H&H conducted this assessment for Sonic
Automotive, Inc. (Sonic) in accordance with our authorized scope of work. Any exceptions to, or
deletions from, this practice are described in this report.

2.1 Purpose and Scope of Services

The purpose of this assessment was to identify, to the extent feasible pursuant to the processes
prescribed herein, recognized environmental conditions in connection with the Site.                                                   Such
environmental conditions include the presence or likely presence of any hazardous substances or
petroleum products in, on, or at the Site, including those which could potentially migrate into a
building or structure located at the Site: (1) due to release to the environment; (2) under conditions
indicative of a release to the environment; or (3) under conditions that pose a material threat of a
future release to the environment. ‘Release’ shall have the same meaning as the definition of
‘release’ in CERCLA 42 U.S.C. § 9601(22) and ‘environment’ shall have the same meaning as the
definition of ‘environment’ in CERCLA 42 U.S.C. § 9601(8). In this assessment, ‘migrate’ and
‘migration’ refers to the movement of hazardous substances or petroleum products in any form,
including, for example, solid and liquid at the surface or subsurface, and vapor in the subsurface.

2.2 Methodology

H&H performed this Phase I ESA in general conformance with current ASTM Standard E1527-
13, Standard Practice for ESAs: Phase I Environmental Site Assessment Process. The Phase I
ESA is also compliant with the statutory criteria for all appropriate inquiries currently accepted by
the United States Environmental Protection Agency (EPA) under ASTM Standard E1527-13. The
scope of services for the Phase I ESA includes the following tasks:

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PHASE I ESA VACANT LAND - 8200 MCCOY ROAD ORLANDO, FLORIDA SONIC JOB NO. ECHOPARK-000503-00025-001 H&H JOB NO. SAI-317 JUNE 6, 2020 - CITY OF ORLANDO
•       acquisition and review of data on historical use of the Site;
             •       Site reconnaissance, review of adjacent properties, and interviews with knowledgeable
                     individuals;
             •        review of environmental databases and previous environmental reports;
             •        contacts with regulatory officials, as appropriate; and
             •        data analysis and reporting.

2.3 Limitations and Exceptions of Assessment

The following items were beyond the scope of this assessment, and H&H did not address them in
this report:

             •        cultural, historical, and archaeological surveys;
             •        radon and indoor air testing;
             •        responsibilities of the User of this Phase I ESA to meet all appropriate inquiry (AAI)
                      as defined in ASTM E1527-13;
             •        drinking water testing;
             •        rare and endangered species survey; and
             •        wetlands delineation.

The User of this Phase I ESA has certain responsibilities to meet AAI as defined in ASTM
E1527-13. H&H provided a User Questionnaire to Mr. Cody Karns of Sonic to in part address the
User’s responsibilities. H&H has provided a copy of the completed User Questionnaire in
Appendix A.

2.4 Special Terms and Conditions

The conclusions presented in this report are professional opinions, based solely upon visual
observations of the Site and vicinity and are our interpretation of the available historical
information, documents reviewed, and analytical results as described in this report. They are

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PHASE I ESA VACANT LAND - 8200 MCCOY ROAD ORLANDO, FLORIDA SONIC JOB NO. ECHOPARK-000503-00025-001 H&H JOB NO. SAI-317 JUNE 6, 2020 - CITY OF ORLANDO
intended exclusively for the purpose outlined herein and at the Site location and the project
indicated.

This report is intended for the sole use and reliance of Sonic in accordance with the Terms and
Conditions of the Professional Services Agreement (PSA) between H&H and Sonic. The report
may not be relied upon by other parties without the expressed written consent of H&H and Sonic.
The scope of services performed in execution of this investigation may not be appropriate to satisfy
the needs of other users, and any use or re-use of this document or the findings, conclusions, or
recommendations presented herein is at the sole risk of said user.

It should be recognized that this study was not intended to be a definitive investigation of
contamination at the Site. It is possible that currently unrecognized contamination may exist at
the Site. Opinions and recommendations presented herein apply to Site conditions existing at the
time of our investigation and those reasonably foreseeable. They necessarily cannot apply to Site
changes of which H&H is unaware and has not had the opportunity to evaluate.

2.5 Data Gaps and Limitations

H&H identified the following data failure during our Phase I ESA activities.

      •      During the Phase I ESA activities, H&H was unable to obtain Site-specific historical
             documents dating back to 1940 or first developed use. H&H reviewed a 1947 aerial
             photograph of the Site which indicated the Site was developed with a residential or
             agricultural structure in the northwestern corner of the Site. Although this is considered a
             data failure in accordance with ASTM Standard E1527-13, based upon the quality of
             information obtained from other sources, the potential for this data gap to significantly
             affect the conclusions in this report appears to be low.

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3.0 Site and Area Description

3.1 General Site Description and Use

A general Site description and the subject Site use are noted below.

Site Description:                                     vacant land
Site Address:                                         8200 McCoy Road, Orlando, Florida
Parcel Size:                                          approx. 18.9-acres

The Site is comprised of an approximately 18.9-acre section of a larger approximately 69.39-acre
parcel of land (Parcel ID: 36-23-30-0000-00-004).                                                     The subject Site is improved with an
approximately 43,000 sq ft concrete-paved parking area in the western portion of the Site, unpaved
gravel parking areas in the northwestern and south-central portions of the Site, and a stormwater
retention pond in the southwestern and southern portions of the Site. The central and eastern
portions of the Site are undeveloped vegetated land. Photographs of the Site are provided in
Appendix B.

3.2 Site Structures and Improvements

Structures and improvements identified on the subject Site include the following:

Buildings:                                            none

Other Improvements:                                   concrete-paved parking area
                                                      gravel parking areas
                                                      stormwater retention pond
                                                      chain-linked and electric fences

Utilities:                                            municipal water – Orlando Utilities Commission
                                                      sanitary sewage – City of Orlando
                                                      electricity – Orlando Utilities Commission
                                                      natural gas – Florida Public Utilities

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3.3 Site Owner, Parcel ID, Site Occupant, and Site Contact

Based upon our Site visit and a review of the Orange County records, the Site owner, parcel
identification, and occupant were identified as follows:

Site Owner:                                           Mco Properties and Investments LLC

Parcel ID:                                            36-23-30-0000-00-004

Site Occupant:                                        none (vacant)

Site Contact:                                         Alhadi Abdulhussein (Mco Properties and Investments LLC)

Orange County tax parcel information and map are included in Appendix C.

3.4 Vicinity Characteristics

The table below summarizes properties adjoining the subject Site:

                Location                                                                  Property Description
                                                 McCoy Road with Off Lease Only Orlando (8443 McCoy Road and
     North/Northwest
                                                 7948 Narcoossee Road) located beyond
     East                                        Narcoossee Road with BP (8101 Narcoossee Road) located beyond
                                                 Martin Andersen Beachline Expressway with 7-Eleven (8320
     South
                                                 Narcoossee Road) located beyond
     West                                        Copart Auto Auction (8100 McCoy Road)

3.5 Physical Setting

The subject Site’s physical setting is presented as follows:

Topography
7.5-Minute USGS Topographic Map:                                                 Pine Castle, Florida dated 2015
Site Elevation:                                                                  approximately 90 ft above mean sea level
Topographic Gradient:                                                            south-southeast
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The topographic gradient across the Site is relatively flat and slopes gently to the south-southeast.
A copy of the area United States Geological Survey (USGS) topographic map is provided as Figure
1.

Geology
According to the Hydrology of Central Florida Lakes- A Primer, the Florida peninsula is
comprised of carbonate rock, including limestone and dolomite, over which sediments such as
sand, silt, and clay have been deposited. The subject Site is located in central Florida in Orange
County. Soils in the area of the Site are comprised of Smyrna-Pomello-Immokalee soils. These
soils are characterized as nearly level to gently sloping, poorly drained, and moderately well
drained soils that are sandy throughout. Bedrock in the vicinity of the Site area consists of
undifferentiated sediments which are Pliocene or Pleistocene in age.

Hydrogeology
According to the Hydrology of Central Florida Lakes- A Primer, the aquifer nearest the land
surface is the surficial aquifer in southern and central Florida. A confining layer, usually composed
of clays, fine silts, and in some cases limestone beds exist under the surficial aquifer. Below this
confining layer exists the Floridan aquifer, which is the primary source of drinking water in central
Florida. The top of this aquifer is at or near land surface in west-central Florida and can be as deep
as several hundred feet below land surface in other parts of central Florida.

Specifically, groundwater at the Site is expected to mimic surface topography and flow in a south-
southeasterly direction.

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4.0 Records Review

4.1 Standard Environmental Record Sources – Federal, State and Local

H&H used Environmental Risk Information Services (ERIS), an environmental database search
service, for a cursory review of Federal and State regulatory database files regarding regulated
facilities within an ASTM-specified search radii. Federal, state, local, tribal, and ERIS proprietary
databases were searched by ERIS on May 19, 2020 and are included in the ERIS report located in
Appendix D.

Upon our review of the ERIS report, H&H identified and summarized the following information
pertaining to the subject Site, off-Site properties, and unmappable orphan properties.

Subject Site
The Site is identified as Alamo Rent A Car on the Facility Registry Service/Facility Index
(FINDS/FRS), Resource Conservation and Recovery Act (RCRA) Non-Generators (Non Gen),
Leaking Tanks (LST), Storage Tank/Contaminated Facility Search (STCS), and Contaminated
Sites (DWM Contam) databases. It should be noted that the database listings are related to the
former car rental facility located on the adjacent property to the west. Because the subject Site
and adjacent property are currently one parcel of land, the database listings include the subject
Site. According to the databases, the Site previously generate ignitable (D001), benzene (D018),
tetrachloroethene ([PCE]; D039), and trichloroethene ([TCE]; D040) beginning in the late 1990s.
No compliance violations related to hazardous waste generation or handling have been reported in
connection with the subject Site.

The databases indicate that three 10,000-gallon gasoline USTs were installed in 1983, one 1,000-
gallon waste oil UST was installed in 1983, one 10,000-gallon diesel UST was installed in 1985,
two 650-gallon new oil ASTs were installed in 1989, one 10,000-gallon diesel UST was installed
in 1994, and three 12,000-gallon gasoline USTs were installed in 1996. All USTs and ASTs are
reportedly removed from the Site. Petroleum and diesel impacts were detected in groundwater in

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October 1993 and groundwater monitoring is on-going. The Site and release incident are further
discussed in Section 4.2.

Off-Site Properties
H&H identified the following off-Site properties listed in the ERIS report that warrant further
discussion based on their proximity to the subject Site:

      •      BP Amoco Station (8101 Narcoossee Road) is located adjacent to the east (approximately
             155 ft from Site beyond Narcoossee Road), and topographically downgradient to cross-
             gradient of the subject Site. The facility is listed on the UST, LST, STCS, DWM Contam,
             and Well Surveillance databases. According to information provided in the databases, two
             12,000-gallon gasoline USTs and two 10,000-gallon diesel USTs were installed in 1999
             and are currently registered to the facility. Four release incidents have been reported in
             relation to the facility. Release incident (Task ID 81976) was reported February 2007 and
             closed June 2008, release incident (Task ID 76588) was reported March 2005 and closed
             May 2012, release incident (Task ID 87744) was reported April 2011 and closed November
             2012, and release incident (Task ID 89950) was reported October 2012 and has not been
             closed. This facility is discussed further in Section 4.2.

      •      Florida Auto Rental (7948 Narcoossee Road) was formerly located adjacent to the north
             beyond McCoy Road and topographically upgradient to cross-gradient of the subject Site.
             The facility is identified on the Spills, STCS, and RCRA - Conditionally Exempt Small
             Quantity Generator (CESQG). According to the databases, the facility formerly generated
             ignitable (D001) hazardous in at least 1998. No compliance violations have been reported
             in connection with the facility. The database also indicates that one 1,000-gallon AST was
             installed in 1998 and has been removed from the property. A gasoline surface dumping
             complaint was recorded on August 1, 2017, but additional information is not provided.
             Based on the lack of reported release incidents, distance from the Site, and lack of
             compliance violations, the potential for impacts to the subject Site appears to be low.

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•      Copart Auto Actions (8100 McCoy Road) is located adjacent to the west and
             topographically upgradient to cross-gradient of the subject Site. The facility is listed on
             the STCS, Well Surveillance, and Delisted Storage Tank (Del Storage Tank) databases.
             According to the databases, a former 650-gallon diesel AST was installed in January 2011
             and was taken out of service in May 2017. Based on the lack of reported release incidents
             related to the diesel AST, the potential for impacts to the subject Site appears to be low.

      •      7-Eleven Food Store #27590 (8320 Narcoossee Road) is located adjacent to the south
             (approximately 815 ft from the Site beyond Martin Andersen Beachline Expressway) and
             topographically downgradient of the Site. The facility is identified on the UST, LST,
             STCS, Well Surveillance, and DWM Contam databases. According to the databases, three
             10,000-gallon gasoline USTs were installed in 1987 and were removed from the facility.
             Currently, one 15,000-gallon gasoline UST, one 10,000-gallon gasoline UST, and one
             10,000-gallon diesel UST were installed in 2011 and are currently registered to the facility.
             A release incident (Task ID 20371) was reported in September 1988 and a second release
             incident (Task ID 78847) was reported in April 2006. This facility is further discussed in
             Section 4.2.

Unplottable Properties
Unmappable properties do not contain sufficient address information in the environmental
databases to plot them on a map. H&H reviewed the list of unmappable properties and have
identified that the Reserve at Beachline is located approximately 975 ft to the southeast and is
identified in the FINDS/FRS database. The database indicates a stormwater construction permit
was issued in December 2007.

Additionally, the Narcoossee Road listing indicates approximately 50 gallons of diesel fuel were
released to ground surface in July 2018 as the result of vehicle accident. Additionally, the McCoy
Road near Narcoossee release incident indicates 10-gallons of motor oil was spilled to ground
surface on November 4, 2003 due to abandoned containers. Based on review of the Site and
surrounding area it appears these spills may be in the vicinity of the Site. However, based on the
limited quantity of material spilled, the potential for impacts to the subject Site appears to be low.

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4.2 Other Records Review

Based on limited information available in the ERIS report, H&H completed a regulatory file
review using the Florida Department of Environmental Protection’s (FDEP’s) OCULUS
Electronic Document Management System for the subject Site and several facilities identified near
the subject Site, which were identified in the ERIS database report. Additionally, H&H was
provided a previously completed Phase I ESA on the Site. Documents obtained from OCULUS
and the previous Phase I ESA are summarized below, and pertinent sections of the documents are
provided in Appendix E.

Subject Site
      •      Phase I ESA¸ prepared by ep3, Inc. (ep3) dated December 10, 2015.
             The Phase I ESA was completed on the approximately 69-acre parcel the encompasses the
             subject Site and adjacent property to the west. During the Site reconnaissance in November
             2015, the property consisted of several office structures, parking areas, and garages which
             were mostly unoccupied. Several areas throughout the property and subject Site were
             being used for vehicle parking by a vehicle auction company. Ep3 noted the presence of
             dense vegetation and ground cover limited visual observations of the ground surface
             throughout the easternmost portion of the property, which includes the subject Site.
             Historically, ep3 noted the property usage as an Alamo vehicle rental complex.

             Based on the Phase I ESA activities, ep3 concluded the presence of documented petroleum
             impacts associated with the property to be considered a REC. However, ep3 noted that
             responsibility for assessment and cleanup of the contamination is covered under the state
             of Florida’s petroleum cleanup program and therefore ep3 did not consider the petroleum
             impacts to be a REC.

      •      Revised Low Score Site Initiative (LSSI) Site Assessment Report, prepared by ep3, dated
             July 30, 2018.

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According to the LSSI Site Assessment Report, Alamo Rent A Car began operating at the
             property adjacent to the west of the subject Site in 1983, and filed a DNF for the property
             in November 1993 related to petroleum impacts. Site assessment activities conducted
             between 1994 and 2007 indicated the presence of petroleum impacted soil and
             groundwater. Figures included in the LSSI Site Assessment Report indicate the area of
             impacts is located in the southern portion of the property, approximately 250 ft to the west
             of the subject Site.

             In 2018, ep3 advanced 39 soil borings for soil field screening and collected 8 discreet soil
             samples for laboratory analysis. Laboratory analysis indicated the presence of total xylenes
             and naphthalene above the leachability-based SCTLs and the presence of naphthalene and
             2-methylnaphthalene at concentrations above the GCTLs in a soil sample collected from
             boring SB-29. No other compounds were detected at concentrations above the SCTLs or
             GCTLs in the collected soil samples. Based on a review of the soil boring location map,
             SB-29 is located approximately 330 ft to the west of the subject Site.

             The LSSI Site Assessment Report also indicates that 23 monitoring wells were sampled in
             either September 2017 or March 2018. Laboratory analytical results indicate the presence
             of several petroleum-related compounds above GCTLs. Monitoring well MW-27, located
             approximately 240 ft from the subject Site and immediately adjacent to a drainage
             ditch/stormwater pond that connects to the subject Site, indicated the presence of methyl
             tert-butyl ether (MTBE) at a concentration of 54 micrograms per liter (µg/l) which is above
             the GTCL of 20 µg/l. The closest monitoring well to the subject Site, MW-28 located
             approximately 225 ft to the west of the subject Site, did not indicated the presence of
             analyzed compounds above GCTLs in 2007 and was not sampled during the most recent
             groundwater sampling events in 2018. Groundwater elevation data indicates groundwater
             flow direction is to the southeast. Based on the results of the assessment activities, the
             FDEP is continuing fund assessment and remediation.

             Based on the release incident being managed by the FDEP PRP, the groundwater plume is
             generally defined, interpreted groundwater flow direction to the southeast, and distance

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from the Site, H&H does not consider the soil and groundwater impacts related to the LST
             incident to be a REC.

BP Amaco Station (8101 Narcoossee Road)
      •      Natural Attenuation Monitoring (NAM) Report, prepared by Environmental Compliance
             Services, Inc. (ECS), dated December 22, 2011;
      •      Limited Site Assessment Report Addendum, prepared by Taylor Environmental
             Consulting, dated April 7, 2017; and
      •      Response to Limited Site Assessment Report Addendum, prepared by Orange County
             Environmental Protection Division (OCEPD), dated April 17, 2017.

Based on review of the environmental reports listed above, it appears groundwater impacts were
detected in March 2005 during assessment activities related to release incident Task ID 76588.
Groundwater elevations recorded in December 2011 indicated groundwater flow to the southeast.
However, historical groundwater flow was interpreted generally to the north. Both the north and
southeasterly flow directions are away from the subject Site. Additionally, the most recent
groundwater data collected in December 2011 did not indicate the presence of petroleum
compounds in groundwater at concentrations above GCTLs. Based on the groundwater results,
release incident Task ID 76588 was issued a No Further Action.

The Limited Site Assessment Report Addendum indicates that impacts to soil were encountered
during replacement of regular unleaded (RUL) spill containment bucket on a UST at the facility.
However, it was determined that the soil sample was collected from the saturated zone based on
elevated groundwater levels. Several attempts were made to collect a soil sample from the
unsaturated zone in the vicinity of the RUL spill containment bucket. In February 2017, a soil
sample was collected and laboratory analytical results indicated the presence of benzene, toluene,
ethylbenzene, and total xylenes (BTEX) above SCTLs. Additionally, benzene and total xylene
were detected at concentrations above GCTLs which indicates groundwater impacts may be
present. However, two groundwater samples collected from monitoring wells in closest proximity
to impacted soil did not indicate the presence of compounds in groundwater at concentrations
above the GCTLs. Based on the results, Taylor Environmental Consulting recommended a No

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Further Action with Conditions. Upon review of the Limited Site Assessment Report Addendum,
OCEPD concurred with the recommendation to purse No Further Action with Conditions for the
reported discharge. Based on the lack of impacts to groundwater, groundwater flow direction away
from the subject Site, distance from the Site, and closed status of the release incidents, the potential
for impact to the subject Site from the UST release incidents reported at the BP facility appears
low.

7-Eleven Food Store #27590 (8320 Narcoossee Road)
      •      Annual NAM Report, prepared by HSW Engineering, Inc. (HSW), dated November 26,
             2019

Based on review of the NAM Report, analytical results from a September 1988 environmental
sampling event indicated a discharge of an unknown type and quantity of petroleum. Between
October 1992 and July 2008, a series of remedial activities and assessments were conducted
including free product extraction and soil excavation. Currently, the facility is under a NAM
program which includes monitoring the concentrations of compounds in groundwater from two
monitoring well locations. Review of the analytical data tables indicates benzene, naphthalene, 1-
methylnaphthalene, and 2-methylnaphthalene are present in groundwater above GTCLs.
However, the concentrations of these compounds appear to be decreasing or stable. Additionally,
the groundwater analytical data indicates that the extent of impacts to groundwater are generally
defined to the north-northwest and do not appear to be migrating off the property. Based on and
distance from the subject Site and impacted groundwater not migrating off the property, the
potential for impacts to the subject Site appears to be low.

4.3 Interviews

Fire Department
Fire Department Contact:                                                         Orlando Fire Department

H&H contacted the Orlando Fire Department to request records regarding releases of petroleum
products or potentially hazardous substances at or near the subject Site. A representative from the

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fire department responded to H&H’s request for information and indicated that the Orlando Fire
Department has not responded to previous fire events, hazardous material spills, or hazardous
material storage at the subject Site.

Site Contact
Site Contact:                                                                    Mr. Alhadi Abdulhussein, Mco Properties and
                                                                                 Investments, LLC

H&H interviewed Mr. Alhadi Abdulhussein, the nephew of the Site owner, during the Phase I ESA
activities. Mr. Abdulhussein indicated that he has been associated with the Site since his family
purchased the Site in the early 2000s. Mr. Abdulhussein indicated that the Site has been used for
overflow parking related to the former car rental facility and car auction operations and has not
been developed for other purposes. Mr. Abdulhussein also indicated that the LST incident was
located approximately 250 ft to the west of the western Site boundary, and is being regulated by
FDEP. He was not aware of historic or current presence of ASTs, USTs, petroleum or hazardous
material release or spill incidents, or other potential environmental concerns related to the Site.

4.4 Historical Use Information

Aerial Photographs
H&H used ERIS’s Historical Aerials Report to review historical aerial photographs of the subject
Site and surrounding area. A summary of the aerial photograph review is provided in the table
below. The Historical Aerials Report is included in Appendix D.

    Year                  Scale                                         Site                                               Surrounding Property
                                            The Site is developed with a small
                                            residential/agricultural structure in
                                            the northwestern portion of the Site.
                                                                                                               Surrounding properties appear to be
                                            The northern and western portions of
                                                                                                               agricultural or undeveloped land.
                                            the Site appear to be developed as
                                                                                                               Narcoossee Road is visible adjacent to
     1947              1” = 500’            agricultural land and the southern and
                                                                                                               the east and McCoy Road is visible
                                            eastern portions of the Site are
                                                                                                               adjacent to the north. Residences are
                                            undeveloped land. A potential
                                                                                                               visible to the north.
                                            wetland feature and drainage ditch
                                            are visible along the eastern Site
                                            boundary.

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Year                  Scale                                         Site                                               Surrounding Property
                                            The residential/agricultural structure
                                                                                                               Additional residential and/or
                                            is no longer visible. An additional
                                                                                                               agricultural development is evident
     1952              1” = 500’            wetland area and drainage ditch are
                                                                                                               to the north, northwest, and southwest
                                            visible on the southwestern portion of
                                                                                                               of the Site.
                                            the Site.
                                            The wetland features appear dry. A                                 Adjacent property to the north beyond
                                            drainage ditch transects the central                               McCoy Road is developed with a
     1954              1” = 500’
                                            portion of the Site from the northeast                             residential or agricultural use
                                            corner to the southwest corner.                                    structure.
                                                                                                               The Martin Andersen Beachline
                                                                                                               Expressway is under construction
                                                                                                               adjacent to the south of the Site.
                                            Appears similar to the 1954 aerial
     1969              1” = 500’                                                                               Residential development is visible to
                                            photograph.
                                                                                                               the north along Narcoossee Road. A
                                                                                                               mobile home lot is visible to the
                                                                                                               north.
                                                                                                               The Martin Andersen Beachline
     1978              1” = 500’            Appears similar to the 1969 aerial                                 Expressway is completed to the south.
     1980              1” = 500’            photograph.                                                        The adjacent property to the north is
                                                                                                               redeveloped for commercial purposes.
                                            A large surface water retention pond                               Adjacent property to the west is
                                            is visible on the southwest corner of                              developed for commercial purposes
     1984              1” = 500’            the Site. The central and western                                  and includes numerous buildings,
                                            portions of the Site appear to be                                  parking areas, and surface water
                                            graded.                                                            features.
                                                                                                               Additional commercial development
                                                                                                               is visible to the north along
                                            Site appears similar to the 1984 aerial                            Narcoossee Road and a retail gasoline
     1990              1” = 500’
                                            photograph.                                                        service station is developed to the
                                                                                                               south, beyond Martin Andersen
                                                                                                               Beachline Expressway.
                                            The western and northern portions of
                                            the Site appear to be used for                                     Commercial development is visible to
                                            automotive parking and storage. The                                the northwest along McCoy Road.
     1999              1” = 500’            west-central portion of the Site                                   Adjacent property to the east beyond
                                            appears paved. Surface water features                              Narcoossee Road is under
                                            are visible in the east-central and                                construction.
                                            southeastern portions of the Site.
                                                                                                               The gasoline service station adjacent
                                                                                                               to the east is completed. The adjacent
                                            Automotive storage appears to have                                 property to the west appears to be
                                            ceased. An area of concrete is still                               vacant. Additional commercial
     2005              1” = 500’
                                            visible on the northwestern portion of                             development is visible to the
                                            the Site.                                                          northwest along McCoy Road.
                                                                                                               Residential development is evident to
                                                                                                               the far northeast.

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Year                  Scale                                         Site                                               Surrounding Property
                                                                                                               Adjacent property to the west is
                                            Automotive storage and parking                                     redeveloped which includes
     2006              1” = 500’
                                            activities are visible on the                                      demolition of several structures.
     2007              1” = 500’
                                            northwestern portion of the Site.                                  Multi-family residential structures are
                                                                                                               developed to the southeast.

                                            A concrete swale is visible on the                                 Additional commercial development
     2010              1” = 500’
                                            southeastern portion of the Site.                                  is evident to the north.

                                                                                                               The gasoline service station to the
     2013              1” = 500’            Appears similar to the 2010 aerial                                 southeast is redeveloped. Additional
     2015              1” = 500’            photograph.                                                        parking is visible on adjacent property
                                                                                                               to the north.
                                                                                                               Additional commercial development
                                                                                                               is visible north of the Site, including
                                            The Site appears similar to the 2015                               adjacent property to the north.
     2017              1” = 500’
                                            aerial photograph. However, very                                   Roadside construction activities are
     2019              1” = 500’
                                            few vehicles are parked on the Site.                               apparent to the south of Martin
                                                                                                               Andersen Beachline Expressway,
                                                                                                               south of the Site.

Historical Topographic Maps
H&H used ERIS’s Topographic Maps Report to review topographic maps of the subject Site and
surrounding area for select years from 1953 to 2015. A summary of the topographic map review
is provided in the table below. The ERIS Topographic Map Report is included in Appendix D.

      Year Quad                      Scale                        Subject Site                                          Surrounding Property
                                                                        Surrounding properties are generally
                                                                        undeveloped or wetlands. McCoy Road is
           1953
                                   1:24,000 The   Site is  depicted  as depicted adjacent to the north and
 (Pine Castle, FL)                          vacant, undeveloped land.   Narcoossee Road is depicted adjacent to
                                                                        the east. Residential structures are depicted
                                                                        to the north.
                                                                        Bee Line Expressway (Martin Andersen
           1970
                                   1:24,000 Site appears similar to the Beachline Expressway) is depicted to the
 (Pine Castle, FL)                          1953 topographic map        south of the Site. Additional structures are
                                                                        depicted to the north and south.
           1980
                                   1:24,000 Site appears similar to the Surrounding area appears similar to the
 (Pine Castle, FL)                          1970 topographic map        1970 topographic map
                                                                        Structures are not depicted on properties
           2015                             A surface water feature is surrounding the Site. Goldenrod Road is
                                   1:24,000 depicted along the southern depicted to the west and Lee Vista
 (Pine Castle, FL)
                                            Site boundary.              Boulevard is located adjacent to the north.
                                                                        The airport is depicted to the southwest.
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User Questionnaire
H&H submitted a User Questionnaire to Mr. Cody Karns of Sonic to complete. H&H has included
a copy of the completed User Questionnaire in Appendix A. The questionnaire indicates that Sonic
is not aware of environmental cleanup liens, activity and use limitations, or obvious indicators that
may point to the presence or likely presence of contamination at the subject Site.

City Directories
H&H used ERIS’s City Directory Report to obtain historical information concerning the subject
Site and surrounding area. City directories were available for the Site area for select years between
1998 and 2018. The City Directory Report is included in Appendix D. A summary of the city
directory review is provided below.

   Location                               Address                                                 City Directory Listing (Year)
                                                                               not listed (2018)
                                                                               All State Insurance Company (2006-2014)
                                                                               Airport Serving Locations (2006-2010)
                                                                               Alamo Rent A Car (2002-2010)
        Site              8200 McCoy Road
                                                                               Richard Dearys Hot Dogs (2006-2010)
                                                                               Richard Deary Equipment Rental (2002)
                                                                               Ryder Truck Rental (2002)
                                                                               Certified Tours Inc. (1998)
                          8443 McCoy Road                                      not listed (1998-2018)
                                                                               not listed (1998; 2014-2018)
                          8301 McCoy Road
                                                                               Empire Paint & Body Works of Orlando (2002-2010)
   Northwest
                                                                               not listed (1998; 2014-2018)
                          8305 McCoy Road                                      Premier Getaways (2006-2010)
                                                                               Sunterra Corporation (2002)
                                                                               Off Lease Only Automobile Dealers (2018)
                                                                               Continental Rent A Car (2002-2014)
                          7948 Narcoossee Road
                                                                               Florida Auto Rental (1998-2014)
       North                                                                   Ace Rent A Car (2002)
                                                                               Park to Fly Inc (2006-2018)
                          7800 Narcoossee Road                                 Airport Parking (2014-2018)
                                                                               not listed (1998-2002)
                                                                               Narcoossee Store (2018)
                                                                               Super Stop Inc. (2002-2014)
                                                                               ATM (2014)
        East              8101 Narcoossee Road                                 Budget Rent A Car (2006-2010)
                                                                               Budget Truck Rental (2006-2010)
                                                                               Millenium Marketing Corporation (2002)
                                                                               not listed (1998)
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Location                               Address                                                 City Directory Listing (Year)
                                                                               Reserve at Beachline (2006-2018)
                          8335 Narcoossee Road
                                                                               not listed (1998-2002)
                                                                               7-Eleven (2014-2018)
                          8320 Narcoossee Road                                 CitiBank ATM (2014)
   Southeast
                                                                               not listed (1998-2010)
                                                                               not listed (2014-2018)
                          8338 Narcoossee Road                                 7-Eleven (1998-2010)
                                                                               7-Eleven Food Stores (2002-2010)
                                                                               Copart Salvage Auto Auctions (2006-2018)
       West               8100 McCoy Road                                      Cars for Breast Cancer Car Donations (2014-2018)
                                                                               not listed (1998-2002)

Fire Insurance Maps
H&H requested fire insurance maps from ERIS to identify past Site usage. Fire insurance map
coverage was not available for the Site area. The ERIS Fire Insurance Map Report indicating lack
of coverage for the Site is included in Appendix D.

Physical Setting Report
A Physical Setting Report for the subject Site was provided by ERIS. The Physical Setting Report
indicates that the southern and eastern portions of the Site are located within the 100-year flood
zone. Additionally, wetland information provided in the report indicates the southwestern portion
of the Site may be a freshwater pond and the southeastern and eastern portion of the Site may be
freshwater forested/shrub wetlands. The Physical Setting Report indicates that no registered water
supply wells are located on the subject Site; however, water supply wells are located on properties
surrounding the subject Site.

Environmental Lien Search
H&H used ERIS’s Environmental Lien and Activity and Use Limitations (AUL) Search to assist
in identifying records for environmental cleanup liens and other property use restrictions for the
subject Site. No environmental liens or other property AULs were identified by ERIS. A copy of
the ERIS Environmental Lien and AUL Search is included in Appendix D.

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Historical Use Summary
Historically, the Site was developed for residential and/or agricultural purposes including a small
structure in the northwestern portion of the Site prior to 1947. The residential/agricultural structure
was removed by the early 1950s and the Site remained vacant land with potential wetland features
and drainage ditch areas until the early 1980s when a stormwater pond was constructed on the
southwestern portion of the Site. The Site was used for automotive parking and storage purposes
related to a car rental facility and car auction operation beginning in the 1990s through the late
2010s. Currently, the Site is vacant.

Historically, surrounding properties were primarily undeveloped with few residential and
agricultural properties prior to the mid- to late 1940s. Residential development in the area
continued until construction of the Martin Andersen Beachline Expressway which began in the
mid- to late 1960s. Commercial development in the area followed and continued through the late
2010s. Commercial properties surrounding the Site have generally consisted of used car sales,
storage facilities, rental car companies, and retail gasoline service stations.

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5.0 Site Reconnaissance

Mr. Nick Hotzelt of H&H conducted a visual reconnaissance of the Site on May 20, 2020. The
weather conditions during the Site visit were sunny and temperatures in the low 90s F.
Photographs of the subject Site and surrounding area are included in Appendix B. Site features
are depicted on Figure 2.

5.1 Hazardous Substances

H&H did not observe evidence of potentially hazardous materials or petroleum products during
our Site reconnaissance.

5.2 Storage Tanks, Sumps, Floor Drains, Oil/Water Separators, and Hydraulic Lifts

During our Site visit, H&H visually assessed the subject Site for the presence of storage tanks,
sumps/drains, oil/water separators (OWSs), and hydraulic lifts. A summary of our assessment of
these items is provided below:

USTs:                                                                            none observed or reported
ASTs:                                                                            none observed or reported
Sumps and Drains                                                                 none observed or reported
OWSs:                                                                            none observed or reported
Hydraulic Lifts:                                                                 none observed or reported

H&H did not observe indications of ASTs, USTs, OWSs, hydraulic lifts, or sumps during our Site
visit, and none were reported by the Site contact.

5.3 Water and Wastewater Information

Water and wastewater use and information is summarized below.

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Water
Municipal Water:                                                                 Orlando Utilities Commission
Water Supply Wells:                                                              none observed or reported

Wastewater
Sanitary Sewage:                                                                 City of Orlando
Septic Systems:                                                                  none observed or reported

Municipal drinking water and sanitary sewer service are available through Orlando Utilities
Commission and the City of Orlando, respectively. H&H did not observe indications of water
supply wells or septic systems located on the subject Site.

5.4 Indications of PCBs

Polychlorinated biphenyls (PCBs) are sometimes found in mineral oils used in electrical
equipment including transformers. PCBs are a potential environmental contaminant. H&H did
not observe potential PCB containing equipment at the Site during our reconnaissance.

5.5 Indications of Waste Disposal

During our Site reconnaissance, H&H identified the following waste disposal areas:

Waste Containers:                                                                none
Debris Piles:                                                                    used and scrap tire debris

H&H observed used and scrap tire debris in the northeastern portion of the Site (Photograph 16).
H&H did not observe evidence of disposal of potentially hazardous materials or petroleum
products in the vicinity of the used and scrap tires. H&H did not observe significant staining to
the soil in the vicinity of the tire debris indicative of a significant environmental release.

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5.6 Surface Conditions

During our reconnaissance of the subject Site, H&H identified the following surface conditions:

Interior Surface Conditions:                                                     none

Exterior Surface Conditions:                                                     concrete-paved parking lot
                                                                                 gravel parking areas
                                                                                 stormwater pond
                                                                                 potential wetland areas

H&H observed concrete and gravel parking areas in the western and south-central portion of the
Site. H&H did not obvious indications of stained concrete, gravel, or soil; stressed vegetation;
pits; depressions; or other unusually disturbed areas indicative of a potential environmental release
during our reconnaissance of the Site.

5.7 Stormwater and Flood Information

The following is a summary of stormwater and flood zone information at the subject Site:

Stormwater
Stormwater flows across the paved areas of the Site to storm drains located throughout the paved
parking area and discharge to a stormwater retention pond located on the southern portion of the
Site. Additionally, some stormwater is expected to infiltrate into the pervious ground surface.
H&H did not observe potential environmental concerns associated with stormwater during our
reconnaissance of the Site.

Flood Information
FEMA Flood Insurance Rate Map (FIRM):                                                         Flood Plain Panel # 12095C0435G, dated
                                                                                              June 20, 2018

H&H reviewed the FEMA FIRM map, which indicates that the southern and eastern portions of
the Site are located in zone A or the 100-year flood hazard zone where no base flood elevations

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have been determined. The northwestern and central portions of the Site are located in zone X or
an area of minimal flood hazard.

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6.0 Signatures of Environmental Professionals

I declare that, to the best of my professional knowledge and belief, I meet the definition of
Environmental Professional as defined in Section 312.10 of 40 CFR 312, and have the specific
qualifications based on education, training, and experience to assess a property of the nature,
history, and setting of the subject property. I have developed and performed the all appropriate
inquires in conformance with the standards and practices set forth for the environmental
professional in 40 CFR Part 312.

Environmental Professional

Nathan O’Leary, CHMM
Project Manager

Assisted By:

_____________________________________
Nick Hotzelt, PE
Project Environmental Engineer

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