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� r 0 Mr. Robert McClellon December 17, 2004 Page 2 of 3 6. Bulk inert wastes, such as known construction debris, wheel rims, etc. will be visually characterized as such and will be removed to a Class III landfill. Ash wastes will be characterized through physical sampling prior to removal. Ash and associated soil will be analyzed for Cam 17 metals, pH, semi -volatile organic compounds (SVOCs) by EPA Method 8270, volatile organic compounds (VOCs) by EPA 8260, polychlorinated biphenyls (PCBs) by EPA 8080, and total petroleum hydrocarbons by EPA 8015M. A Ground Zero field technician will collect a composite sample from identified ash wastes for characterization. The ash waste will be transported to either Forward Inc. landfill in Stockton (Class II) or Chemwaste Inc. landfill in Kettleman Hills (Class I), dependent upon characterization. Any identified wastes unearthed during construction will be cordoned off and tentatively identified and characterized by a licensed Hazardous Waste contractor/transporter. We anticipate using Jim Thorpe Oil, Inc. of Lodi, California to characterize and dispose of unknown wastes. 7. Section 4.2 of the workplan states "Dust will be controlled through regular application of water using a spray nozzle or water truck, as needed." This precaution will also be employed during the handling of any ash waste. 8. Although the Calirnia Integrated Waste Management Board (CIWMB) detected no appreciable methane gas during their investigations, a methane gas meter will be utilized during excavation of areas where wastes have been identified or are encountered. Monitoring will be conducted by Ground Zero personnel properly trained in the use of the meter. Ground Zero will use a GasTech Innova SV portable gas meter calibrated to methane. 9. The workplan states, "If drums are uncovered during an excavation, the area shall be cordoned off and the CIWMB and EHD officer will be notified." Ground Zero does not expect CIWMB or EHD to act as a first responder. If unidentified wastes are encountered during earthmoving activities, CIWMB and EHD will be notified, and Jim Thorpe Oil, Inc., a licensed Hazardous Waste Hauler/Cleanup Company, will be dispatched to the site for characterization and disposal of the unknown waste. 10. The initial soil boring investigation was conducted simultaneously on APN 24-060-13 and APN 24-060-14 in order to realize a cost savings for both property owners. The Site Mitigation Workplan similarly addressed both in anticipation of conducting simultaneous cleanup. However, Peter Palomino is does not own Parcel #14 and has no decision-making authority regarding cleanup activities or related expenditures. The owner of Parcel #13 does not have the funds to pursue site mitigation activities at this time. The Site Mitigation Workplan should be considered a workplan to mitigate Parcel #13 only, which is the parcel owned by Peter Palomino. Site mitigation issues related to Parcel #14 should be addressed to Miguel Palomino, 2913 Fern Court, Riverbank, CA 95367. 11. Results of samples collected by CIWMB on Parcel #13 contained no residual metals above any hazardous waste criteria. All analyses for lead were well below the 1,000 ppm TTLC and the 5.0 ppm STLC levels that would mandate handling any soil/waste as hazardous. However, as G:\GROUNDZE\Palomino\sitmit%,,paddendum.doc