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Mr. Marcus Pierce, Engineering Geologist g February 2012 Central Valley Regional Water Quality Control Board Subject: Copper Sulfate Impacted Soil Removal A groundwater sample will also be collected from beneath the excavation to determine if groundwater has been impacted by the copper sulfate in soil. Using direct -push technology, a boring will be advanced to first occurrence of groundwater for collection of a grab groundwater sample using a HydropunchTM tool, or similar technology. Soils will be cored continuously to provide a detailed analysis of lithology for logging purposes and to visually observe and document occurrences of copper sulfate in soil at deeper intervals, if any. A photoionization detector (PID) will be used to screen the cored soils for VOCs approximately every five feet. Boreholes will be abandoned according to SJCEHD's regulations with neat cement and the top 3 feet backfilled with clean native materials (SJCEHD, 2005). The grab groundwater sample will be collected in sterile, laboratory -supplied containers, submitted to a California -certified laboratory under appropriate COC documentation, and analyzed for California Title 22 Metals using USEPA Method 601013/7000. Additionally, representative samples of the excavated soil (a 4 -point composite sample) will be collected by OTIE and also submitted to the California -certified analytical laboratory under proper chain -of -custody documentation. Based upon waste impoundment requirements, the sample may be analyzed for one or more of the following: • Total petroleum hydrocarbons (TPH) by USEPA Method 8015 -modified; • Volatile organic carbons (VOCs) by USEPA Method 8260B; • California Title 22 metals by EPA Method 60106/7000; and • Polychlorinated biphenyls (PCBs) by EPA Method 8082. After confirmation sample collection, the excavation will be backfilled with clean borrow material and compacted using the backhoe bucket or a sheepsfoot roller backhoe attachment. Compaction testing will not be conducted for the site, as we anticipate that the proposed compaction method will render the location usable for its previous use (i.e., vehicle parking/storage). The excavation area will then be graded flush with the adjacent contours of the site and the paved with asphalt to match the surrounding ground surface. Equipment will be demobilized from the site following completion of these activities. This approach to excavation, confirmation sampling, and backfilling during a single mobilization is preferred for the following reasons: • The impacts to soil are presumed to be limited in extent and, in general, will be visually definable; • CSMS personnel will have full use of their vehicle parking and storage facilities more expediently; and • Expensive excavation equipment will not be tied up at the site pending confirmation sample analytical results, and can be re -mobilized readily if necessary to do so. OTIE will notify the CVRWQCB of planned excavation activities at least one week prior to implementation. If confirmation sample results indicate that it is necessary to remobilize for additional excavation, the clean backfill material will be removed and stockpiled adjacent to the excavation, and additional soil will be excavated in the affected area. Confirmation samples will then be recollected to ensure all impacted soil has been removed. Oneida Total Integrated Enterprises, LLC Page 3 of 4