May 6, 2004

SUBJECT: National Environmental Policy Act (NEPA) Review for Property
Transfer,

Demolition and Construction of New Cereal Crops Laboratory Madison,

Wisconsin

TO: Hugene Fields, Project Manager, Facilities Engineering Branch

FROM: Adrianna Hewings, Director, Midwest Area

As requested, Jerry Roberts, Area Engineer (AE), Caryl Romine, Area
Safety and Health Manager (ASHM), Ralph Jesse, Area Environmental
Protection Specialist (AEPS) and I have reviewed the subject related
environmental and design documents. Utilizing NEPA and ARS guidelines,
the proposed land transfer, demolition and construction projects were
examined for environmental issues based on known conditions and
information available to us as of this date. Reasonable effort was made
to review and verify all information whenever possible.

Our findings and recommendations are based upon:

• the Aries Consulting Group, Inc. Phase I Environmental Site Assessment
prepared for

CUH2A, Inc. dated March 2003;

• the Aries Consulting Group, Inc. Phase II Environmental Site
Assessment prepared for

CUH2A, Inc. dated June 2003;

• the CUH2A, Inc. 95% Design Submittal dated April 2, 2004; and

• discussions with ARS Location personnel (David Peterson and Jean
Weinbrenner).

FINDING 1:

Chlorinated Solvents have been detected in subsurface soils and
groundwater at concentrations above the Wisconsin Department of Natural
Resources (WDNR) contaminant limits on the subject property. Twenty-one
Leaking Underground Storage Tanks (LUSTs) have been recorded within a 1
mile radius. During the 1998 removal of Underground Storage Tanks (UST)
at the University of Wisconsin Power Plant (505 Walnut Street),
chlorinated solvents and fuel oil were released to soil. Aries
Consulting Group, Inc. (Aires) performed an analytical assessment and
reported the presence of chlorinated solvents, specifically
dichloroethylene, trichloroethylene and tetrachloroethylene plus
Gasoline and Diesel Range Organics (GRO / DRO) contaminants such as
benzene, toluene ethylbenzene and xylenes in either soil and/or
groundwater samples with only tetrachloroethylene exceeding the 5 µg/L
WDNR contaminant level. Levels exceeding cleanup objectives were noted
in both up-gradient and down-gradient wells. Aries reported that an
interview with a WDNR representative revealed the presence of the
chlorinated solvents and GRO / DRO contaminants are a regional problem
of an unknown source. The WDNR does not

National Environmental Policy Act (NEPA) Review -- Madison, Wisconsin
Page 2

believe the contaminants are the result of a release from the
neighboring University of Wisconsin Power Plant (even through
contaminants from that spill have escaped property boundaries) or a
release on the subject property. The EPA has removed the site from the
CERCLIS cleanup list and designated the property No Further Remedial
Action Planned (NFRAP). No further action recommended.

FINDING 2:

Following the transfer of property, 2 buildings will require demolition.
Aries performed an assessment of buildings 502 and 504 for asbestos,
lead and polychlorinated biphenyls (PCBs). Materials evaluated included
paint, thermal insulation, lab countertops, floor tiles and mastic,
drywall and joint compounds, ceiling tiles, and plaster ceilings and
walls. Asbestos containing building materials were discovered in both
buildings. In accordance with the National Emission Standards for
Hazardous Air Pollutants (NESHAP) friable asbestos must be removed prior
to demolition. The Design And Construction Project Manual thoroughly
addresses the processes required to abate the asbestos prior to building
demolition. No further action recommended. Lead Based Paint (LBP) was
discovered in building 502. Aries reported the lead levels are less than
the contractor release criteria established by the Department of Housing
and Urban Development (HUD). Even though the HUD guidelines do not
directly apply to this project, they are scientifically valid and safe.
No further action recommended. Polychlorinated biphenyls (PCBs) were not
identified through testing. The potential for PCB equipment to be
present exist since both 502 and 504 were built prior to 1979 when
electrical equipment such as transformers, capacitors, switches, voltage
regulators and fluorescent light ballasts were cooled with heavy oils
containing PCBs. Aries performed an on-site inspection of pole-mounted
and pad-mounted transformers and related electrical equipment and
reported them to be in good condition and no leaks were noted. The
Design and Construction Project Manual addresses the processes required
to remove PCB containing equipment prior to building demolition. No
further action recommended. No further environmental assessment is
requested for the subject project.

CONCLUSION:

Based upon the above findings, the MWA NEPA Review Team recommends an
acceptance of the environmental assessment reports and recommends the
transfer of the subject property from the USDA-Forest Service to the
USDA-ARS with a Conditional Finding of No Significant Impact (FONSI)
statement. We recommend the transfer papers delineate the presence of
exiting subsurface soil and groundwater contaminants and identify
previous owner's responsibility for future cleanup liability.

If you have comments or require additional information please contact
either Caryl Romine at 309-681-6608 (cromine@mwa.ars.usda.gov) or Ralph
Jesse at 309-681-6644 (ralph.jesse@mwa.ars.usda.gov).

cc:

T. Rupe, PS

D. Strub, AAO

D. Peterson, LC

J. Weinbrenner, LAO

J. Roberts, AE

C. Romine, ASHM

R. Jesse, AEPS