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LFR Levine-Fricke repeated as necessary to ensure the removal of Class I non-RCRA hazardous waste from the Unit and to characterize soil quality beneath the excavated material. Once Class I materials have been removed from Unit 1, excavation activities will commence in Unit 2 and then Unit 3 following the same procedures. Disposal of pyrolytic oil-affected soil(if present) will be determined following communication with Class II landfills. Samples of pyrolytic oil-affected soil will be analyzed for VOCs by EPA Method 8260, SVOCs by EPA Method 8270, and CAM- 17 metals by EPA Method 6010. Pyrolytic oil and soil affected by pyrolytic oil will be considered a Class II designated waste unless results indicate it to be a Class I non- RCRA waste. Class II designated waste, which may include soils containing chemical components (VOCs or SVOCs)of pyrolytic oil and/or soils that are significantly discolored, may be removed from the Site and transported to an State-permitted Class II disposal facility, as appropriate, following removal of all Class I waste within a unit. Confirmation sampling for removal of Class II materials will follow excavation activities and will be performed as described in Section 7.4. The excavation and confirmation sampling sequence shall be repeated until waste determined appropriate for Class II disposal is removed. During excavation activities, dust and equipment emission controls will be used to protect workers in accordance with the Health and Safety Plan(HSP). The HSO will conduct personal and perimeter air monitoring during construction activities to ensure compliance with the HSP. A handheld photoionization detector(PID) and a handheld dust meter may be used. Based on the initial geodetic survey of the 34 burn piles, there is approximately 564,000 square feet of burn pile area. Assuming the removal of approximately the top 2 feet of material, there will be an initial removal of approximately 1.13 million cubic feet(41,800 cubic yards [CY]) of soil. A single truck can transport approximately 20 CY of soil; therefore, there will be an initial need for approximately 2,100 trucks to haul the soil off site. It is anticipated that up to 60 trucks will depart the site each day. Excavation depths may be modified in the field based on the field observations and verification sampling results. Equipment and Personnel. Excavation will be accomplished using some or all of the following heavy equipment. The main loading operation will use one or two Caterpillar (Cat) 345BL excavators, depending on the schedule and truck availability. To feed the two excavators, SCI will use one or two Cat 824 rubber-tire dozers. For the trimming operation, SCI will use a Cat 325 excavator with grapple attachment. A water truck will attend each excavation area during construction activities. The roads will be maintained with a Cat D-4H dozer with a grading ("bee gee") attachment. Additionally, an off-road forklift will also be needed at the Site. The following personnel will be on site on a regular basis for overall coordination, management, and implementation of excavation activities: Final_RAP_Tracy_9.18.03(final).doc Page 23