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Mr. Robert McClellon September 22, 2004 Page 6 of 11 The debris in these areas will be consolidated using an International E295 scraper, a Caterpiller 977C bulldozer, and a Caterpiller 613 scraper. All equipment will be operated by trained heavy equipment operators. Based upon the analytical results of soil and groundwater samples collected at the site in July 2004, the soil at the site should not be considered a designated waste and a Title 27 prescriptive landfill cover, therefore, is not warranted. Mr. Palomino proposes to install an alternative cover design that would essentially meet the performance requirements of Title 27, Sections 21090(a) and 21140(b). The proposed cover design consists of the following: 12 -inch layer of intermediate cover foundation; 24 -inch layer of compacted support; 6 -inch layer of crushed rock and/or asphaltic concrete. The intermediate cover foundation will be placed in a single 12 -inch lift and compacted to >90% of maximum dry weight based on ASTM D698. After placement of the intermediate cover, the compacted support layer will be spread in 12 -inch loose lifts, compacted to >90% of maxiumum dry weight based on ASTM D 698, dry of optimum moisture content. The surface cover shall consist of 6 inches of self -compacting crushed rock and/or asphaltic concrete. The engineered landfill cap will be constructed under the direct supervision of Delamare & Fulz Engineering of Modesto, California. 3.4 Site Drainage and Erosion Control Pursuant to Title 27 requirements, the final drainage plan will be designed, graded, and maintained to prevent ponding and to prevent soil erosion due to high run-off velocities. The drainage and erosion control plan will be submitted under separate cover by Delamare & Fulz Engineering. 3.5 Earthmoving Along Railroad No debris has been identified within 50 feet of the railroad track that parallels the western property boundary. However, a small amount of mounded debris at the base of the railroad berm in the southwest corner of the property (near excavation pit T26) will require excavation. Delamare & Fulz Engineering has determined that the removal of this debris will not threaten the integrity of the berm. In addition to the debris located at the southwest corner of the property, several areas of the berm were used by previous owner(s) as a soil borrow area. Mr. Palomino will place native soil in these borrow areas, as well as in the southeast corner of the property after the debris is removed from that location, in order to restore the berm to its previous state. G:\GROUNDZE\Palomino\wp_sitemitfinal.doc