SITE INFORMATION AND CORRESPONDENCE

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RE-MANUFACTURING LTD. -5- 19 February 1991 SOIL AND GROUND WATER ASSESSMENT REPORT 10. Collect background soil samples for analysis of soluble Pb. Samples shall be taken from a depth correlative to the bottom of the SI, and shall be collected at a location free of impacts from waste disposal practices, incidental spills, or general manufacturing activities. The location and depths of these borings shall be submitted for approval by the Regional Board prior to sampling. "Background" samples were collected in two areas labeled BG-1 and BG-2. The results were as follows: Borin BG-1 Boring BG-2 Depth Total Pb Soluble Pb Total Pb Soluble Pb feet b s (mg/kg) (mg/L (mg/kg) m L 4 6.4 <0.5 3720 70.4 5 6.6 <0.5 476 2.5 One of the shallow borings sampled (BG-2 at 4 feet bgs) contained hazardous levels of total and soluble lead. The sample was obviously contaminated and does not represent background concentrations of lead. Mr. Moore was quoted in Kleinfelder's report as stating that the boring BG-2 was not on his property. It appears that background concentrations of lead can be established from BG-1 and the wells constructed on site. All samples analyzed for those borings were near or below the detection limit of 5 mg/kg total lead and 0.5 mg/L soluble lead. Conclusion Re-Manufacturing has made an important step toward satisfying the requirements of a HAR by installing three monitoring wells. However, additional work is required. To complete the HAR, the report must satisfy all information required in Section 25208.8 of the Health and Safety Code. The deficiencies I have listed must be addressed. However, it is the consultant's ("qualified professional ") responsibility to certify that all the requirements of Section 25208.8 have been fully addressed and are accurate. The qualified professional must also provide a written statement indicating if any constituents have migrated into the vadose zone, surface water bodies, perched water, or water bearing strata.