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SH KLEINFELDER generator. The facility received the following violations: "generator-pre-transport requirements, generator-general requirements, and generator-record keeping requirements," all received in 1993. The facility is listed on the CA SLIC database based upon a spill involving total petroleum hydrocarbons (TPH), filed October 4, 2002, the current status is preliminary assessment, no other information was available. The facility also appears on the AST database for the storage of aboveground storage tanks on site. The facility appears on the TRIS (Toxic Chemical Release Inventory System) based upon the storage and/or release of an estimated 9,787 pounds of ammonia by means of an air stream, an estimated 0.1 pounds of fugitive lead compounds released into the air. The facility appears on the FINDS ` database due to pertinent environmental activity. Listed activities include the AIRS/AIRS Facility Subsystem (AIRS/AFS), Biennial Reporting System (BRS), National Emissions Inventory (NEI), National Emissions Trends (NET), National Toxics Inventory (NTI), his Resource Conservation and Recovery Act Information system (RCRAINFO), and the Toxic Chemical Release Inventory System (TRIS). The facility appears on the CA VMS as an industrial facility type. According to the EDR report, the facility discharges domestic sewage and cooling water that pose a significant threat to water quality because of their high concentrations of BOD, hardness, chloride, etc. They also reportedly discharge cooling water and backwash brine waters. The water is classified as a moderate threat to water quality in case of a violation of a regional board order, Category B, no reclamation requirement required. According to the database information, the facility is also classified as ` a solid waste site-class I with primarily process waste and a major threat to water quality, Category A, no reclamation requirement required. The facility appears on the Cortese and LUST databases due to a leaking underground storage tank. The released material is reported as gasoline and the leak was discovered on May 7, 1986. The release is reported to have impacted the soil only. MTBE was tested for and detected at a maximum of 1 ppm. The case related to the leaking UST has been closed. Based on the current status and since the LUST incident reportedly impacted soil only, this specific LUST incident is not expected to impact the subject site. However, it has been Kleinfelder's experience that closure of a site by agencies does not necessarily mean that soil is not still impacted beneath the site in L, question. Rather, contaminants may not have been a concern in their state and with the property use. Therefore while this LUST incident is not expected to impact the site there is some potential, especially considering the LUST incidents immediately adjacent location to r the eastern border of the site. Based on the nature of the adjacent Owens Illinois operations and the summarized findings from the database search it is Kleinfelder's opinion that this adjacent facility has potential to impact the subject site. It should be noted however that .. based on groundwater data, that this adjacent site appears downgradient of the site, and therefore potential leaks to groundwater are less likely to impact the subject site if the groundwater flow was found to be westward instead of northeast. If contamination on site is L attributable to Owens Brockway the expense and/or liability associated with any necessary investigation or remediation would typically fall upon the responsible party (i.e. Owens Brockway). For additional information refer to Section 4.2 1_ • Tracy Operators (aka. Tracy Biomass Plant), located at 14,800 W. Schulte Road, adjacent and east of the northern portion of the subject site appears on the HAZNET database due to the storage and/or generation of other inorganic solid waste, unspecified organic liquid mixture, waste oil and mixed oil, and other organic solids. No violations are reported for the L 4035LPO 1/ST04R354 Page 10 of 30 Copyright 2004,Kleinfelder,Inc. March 12,2004