Contract analysis

1. Executive Summary This document defines the scope, methodology, and schedule for interim stabilization measures ("ISMs") to be implemented at the Kanawha Bend Chemical Plant (the "Site" or "Facility"), located at 2200 Chemical Valley Road, Institute, Kanawha County, West Virginia 25112. The ISMs are required under the consent decree lodged on February 19, 2025, in the matter captioned United States of America and

2. Site Description and Background 2.1 Site Location and Physical Setting The Kanawha Bend Chemical Plant is located at 2200 Chemical Valley Road, Institute, Kanawha County, West Virginia 25112. The Site encompasses approximately 78 acres and is situated within the Kanawha River valley, one of the most heavily industrialized corridors in the Appalachian region. The Site is bounded to the north and east by other indus

3. Regulatory Framework and Consent Decree Requirements 3.1 Applicable Statutes and Regulations The ISMs at the Kanawha Bend Chemical Plant are governed by and must comply with a comprehensive framework of federal and state environmental statutes and regulations. The principal regulatory authorities applicable to the ISMs include: Resource Conservation and Recovery Act (RCRA). RCRA Sections 3004 and 3005, codified at

4. Interim Stabilization Measures — Scope of Work 4.1 Overview of ISM Components The ISMs for the Kanawha Bend Chemical Plant consist of four principal work elements, each targeting a specific category of contamination or environmental risk at the Site. These four elements are designed to function together as an integrated interim stabilization program that addresses the most pressing environmental and human health c

1. ISM Element 1: Sulfuric Acid Residual Soil Stabilization and Neutralization

2. ISM Element 2: Heavy Metal Contaminated Soil Containment and Stabilization (Former Waste Lagoon)

3. ISM Element 3: DNAPL Containment and Migration Control in Fractured Bedrock Aquifer

4. ISM Element 4: Surface Water Protection and Stormwater Management Improvements All ISM activities will be performed by Pinnacle Creek Environmental, LLC, under the direction of Dr. Astrid Bergmann, P.E., Senior Principal and Engagement Lead. Dr. Bergmann will serve as the Project Director and will be responsible for overall technical direction, quality assurance, and regulatory coordination. ISM implementation wil