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Ground Zero Analysis, Inc. <br />SITE SAFETY PLAN <br />The parcels were previously part of a Closed, Illegal, and Abandoned (CIA) landfill site <br />identified by the California Integrated Waste Management Board (CIWMB) as the Sn dimer <br />Sanitary Dump Site. An April 2003 report entitled Site Investigation, Santa Fe Road Disposal <br />Site, County of San Joaquin, Final Report, summarized a site investigation conducted by the <br />CIWMB. The objective of the CIWMB investigation was to 1) verify current ownership of all <br />parcels previouslyoperated as the Snyder Landfill, 2) to determine the horizontal and vertical <br />extent of the waste, 3) to characterize the waste via sampling and laboratory ggalyses, and 4) to <br />determine the condition of the site with regard to applicable California Code of Regulation, Title <br />27 for site security, cover, and drainage and erosion control. The investigation consisted of <br />excavating numerous trenches on several adjoining_ parcels of land, characterizing the soil and <br />debris encountered in the excavations, monitoring the air for potential contaminants, and <br />collecting and analyzing numerous soil samples. No hazardous levels of metals, volatile organic <br />constituents (VOCs), semivolatile organice constituents (SVOCs), heavy metals, or any other <br />tested constituent of concern were detected in samples collected from the subject parcels. Based <br />upon its investigation, the CIWMB concluded that the subject parcels maintained inadequate <br />cove_ r and drainage and erosion control and failed to meet site security standards outlined in Title <br />27. The CIWMB recommended that 1 above -ground surface wastes be disposed of at a <br />permitted landfill, 2) buried wastes be consolidated, covered, and graded to meet State Minimum <br />Standards of Cover, 3) the site be properly secured by fence and gate to prevent access by <br />unauthorized vehicles and persons, and 4) additional testing be conducted as necessga during <br />remediation and appropriate action taken based upon laboratory results. <br />In a letter dated September 18, 2003, the California Regional Water Quality Control Board, <br />Central Valley Region RWQCB) noted that the results of the investigation demonstrated that the <br />wastes at the site do not have hazardous waste characteristics. RWQCB staff noted, however, <br />that soluble lead concentrations in certain samples collected from Parcel 13 exceed the California <br />Public Health Goal in Drinking water of 2 ug/1, and such soil should be considered designated <br />waste. <br />Tentative plans for site remediation of the parcels include excavating debris from certain areas of <br />each parcel for off-site disposal, consolidating the remaining debris at selected portions of each <br />parcel, constructing an engineered cap over the consolidated debris, and providing adequate <br />drainage/erosion control and site security. A workplan for overall site remediation will be <br />submitted under separate cover. <br />PAGE 3 <br />