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Mr.Aragon November 21, 2008 Page 6 of 9 management practices (BMPs) were implemented in areas surrounding the excavations and temporary stockpile staging areas to minimize/mitigate potential stormwater run-on/run-off. Prior to excavation operations, stormwater catch basins/drains near the excavation area were secured with temporary BMPs such as berms/sandbags which provided filtration of stormwater such that the solid particulate matter will be removed from water entering the catch basins. In addition, during excavation operations, engineering controls were implemented that prevent stormwater run-on/run-off from impacting Site operations. These controls complied with engineering BMPs and included a combination of the following: sand bags, hay bales/rolls, plastic sheeting and berming. These BMPs were monitored on a daily basis to make sure that there were no potential breaches in the system that could allow stormwater to enter or exit the excavation area. No precipitation occurred during excavation operations at the Site. 2.3.4 Waste Characterization Sampling Two characterization samples [COMP-6773/833/824-1 and COMP (SPCC-CHAR-1)] were collected to determine the waste characterization of materials removed from the SPCC excavation. The samples were analyzed for polycyclic aromatic hydrocarbons (PAHs) using EPA Method 8310, for total petroleum hydrocarbons (TPH) as gasoline (TPH-g), as diesel (TPH-d) and as motor oil (TPH-mo) using EPA Method 8015M, for Title 22 Metals using EPA Method 6010/7000 series, and for VOCs using EPA Method 8260. Analytical laboratory reports for these two samples are provided in Attachment A. Results from the sampling showed low-level detections of the PAHs; however, none of the samples contained benzo(a)pyrene equivalent concentrations above 0.9 milligrams per kilogram (mg/kg), the preliminary screening concentration used at many Sites in California to identify areas that could require some form of risk management. Results for the PAHs in the characterization samples are provided in Table 3. Both samples had detections of TPH-d and TPH-mo; however, there were no detections of TPH-g. Results for TPH-d and TPH-mo in Sample COMP-6773/833/824-1 were 59 and 750 mg/kg, respectively. TPH-d and TPH-mo concentrations in Sample COMP (SPCC-CHAR-1) were 20 and 290 mg/kg, respectively. Results for TPH in the characterization samples are provided in Table 4. Title 22 metals concentrations in the samples collected showed detections for the following metals: arsenic, barium, beryllium, cadmium, chromium, cobalt, copper, lead, nickel, vanadium and zinc. All concentrations were below levels that would require a California Waste Extraction Test (WET) and/or a Toxicity Characteristic Leaching Potential (TCLP) Test. In addition, the constituents and the concentrations detected in the samples were similar to background samples collected during the Remedial Investigation conducted at the Site. Results for Title 22 Metals in the characterization samples are provided in Table 5. Finally, there were no VOCs detected in the two characterization samples collected during the SPCC excavation operations. A summary of the laboratory reporting limits and results for VOCs in the characterization samples is provided in Table 6. Analytical laboratory reports for the two characterization samples are provided in Attachment A. Based on the analytical results provided above, this material was characterized as non-hazardous. 2.3.5 Transport and Disposal of Impacted Material All impacted materials removed from the excavation area were transported to, and disposed at the Waste Management Altamont Facility located at 10840 Altamont Pass Road in Livermore,