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r . Mr. Robert McClellon February 9, 2006 Page 3 of 4 • which above the California-modified residential PRG of 150 mg/kg. Due to this initial result, the sample was also analyzed for soluble lead by EPA Method WET/7420 (STLC) and EPA 1311/7420 (TCLP). The results indicated STLC lead at '15 mg/L and TCLP lead at 8.4 mg/L, which exceed both California and Federal RCRA hazardous waste critera (5 mg/L). For specific metals results please see Table 1. WASTE DISPOSAL The analytical results of waste characterization sampling conducted at the site indicate that the soil/ash waste generated from the September 30, 2005 excavation activities should be considered a Federal (RCRA) hazardous waste. Approximately 110 tons of waste will require disposal. Mr. Palomino has submitted a Notice of Regulated Waste Activity with the US EPA Region 9 RCRA Notifications Unit to obtain a generator's identification number so that he can transport the waste to Kettleman Hills Class I landfill for disposal. EHD will be notified at least 48 hours prior to transporting the waste off site under hazardous waste manifest. • PROPOSED ADDITIONAL EXCAVATION ACTIVITIES Mr. Palomino would like to continue to make progress toward site cleanup and proposes the following activities to that end: 1. Relocate the stockpiled hazardous waste from its current location approximately 20 feet east and remove the inert debris (concrete, timber, etc.) in preparation for disposal (Figure 2). The waste will be moved by individuals that have current certification in hazardous waste operations (HAZWOPER) pursuant to 29 CFR 1910.120(e) using a Case 580 backhoe or Caterpiller 977C bulldozer. The material will be placed on 6-mil plastic sheeting and will be covered by plastic when not being sorted. 2. Continue excavation activites in the southwest corner of the site where a debrisibum pit has been previously identified and move the existing soil stockpile in that location approximately 100 feet to the north (Figure 2). The existing pile and excavated material will be placed on trucks and stockpiled approximatey 100 feet north of the current location. The material will be placed on and covered with 6-mil plastic sheeting. Upon completion of the excavation, characterization soil samples will be collected at the rate of one 4:1 composite sample for every 250 cubic yards of stockpiled material. The samples will be analyzed for TPHd, TPHg, VOCs, SVOCs, PCBs, and CAM 17 metals by appropriate analytical methods. Site activities will be conducted pursuant to the procedures and safety protocols outlined in the • September 22, 2004 Workplan for Site Mitigation and the December 17, 2004 Addendum. In general safety procedures will include the following: G:\GROUNDZE\Palomino\soilpileresult2—wp.doc