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Patricia Bonnifield Page 2 October 20, 2003 Post Clean-up Confirmation Testing Based on the documentation provided by Ladd's to Shaw Environmental, the only recognized environmental concern at Ladd's Marina is the sandblast debris. As of October 2003, the sandblast debris has been removed and a shallow soil excavation action has taken place surrounding sandblast area. Shaw conducted the following field -sampling program on October 23, 2003 to confirm the effectiveness of the clean-up actions. Three sandblast debris samples were collected and composited 3 -to -1 into sample "SBD" for analysis. The sample was tested for total metals and compared to the TTLC for each metal. In addition, acid -soluble metal concentrations were measured using the Toxicity Characteristic Leaching Procedure (TCLP). This test was performed to classify the waste as relative to Federal hazardous waste regulations. In addition to the debris, 3 surface soil samples at a depth of 0- to 3 -inches were collected and tested for total metals to document the clean-up actions that have already occurred. One sample (SS -IA) was collected to the southwest of the sandblast area between the area and the marina inlet. One sample (SS -2A) was collected to the east of the sandblast area between the area and the vegetated area. One sample (SS -3A) was collected to the northwest of the sandblast area between the area and Buckley Cove. The soil samples were tested for total metals to be compared to the TTLCs and other potentially significant criteria. The locations of the samples are shown on Sketch 2. The samples were collected with a stainless steel trowel, which was cleaned between each sampling location. The samples were placed in glass jars, packed on ice in a cooler, and transported under chain -of -custody to CLS Labs for analysis. CLS Labs is a California certified lab. The certified analytical results are attached and the results are shown on Table 2. Data Assessment The analytical results have been evaluated using the following guidelines and criteria: • The total metals results and TCLP-leachate results for the SBD sample were compared to TTLC and TCLP regulatory levels, respectively, to determine the waste classification of the debris/soil mixture generated by the excavation. • The surface soil results were compared to the average concentration and the upper 75th quantile of metals in California soils, as reported by Bradford, et al. (1996).1 The 1 Bradford, G.R., A.C. Chang, A.L. Page, D. Bakhtar, J.A. Frampton, and H. Wright. 1996. Background Concentrations of Trace and Major Elements in California Soils. Kearney Foundation of Soil Science, Division of Agriculture and Natural Resources, University of California. CAWMI)OWS\Temporary Internet Files\Content.IE5\UTCIOUZE\Ladd's Investigation Report[1].doe