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0.0117 mg/I, toluene at 0.00268 mg/I, 1,2,4-tri methyl benzene at 0.00306 mg/I, total xylenes at 0.00690 mg/I, and total cyanide at 0.0127 mg/I; the remainder of the analytes analyzed reported non-detect concentrations. Laboratory analysis of the soil samples collected from Site B indicated the following analytes and their reported concentration ranges at or above laboratory reporting limits: barium up to 44 milligrams per kilogram (mg/kg), chromium up to 4.54 mg/kg, copper at 3.83 mg/kg, manganese up to 112 mg/kg, nickel up to 4.63 mg/kg, vanadium up to 16.5 mg/kg, zinc up to 18.2 mg/kg, chlorobenzene up to 0.196 mg/kg, toluene up to 0.101 mg/kg, sulfide up to 10.5 mg/kg, and tin up to 6.4 mg/kg; the remainder of the analytes analyzed reported non-detect concentrations. Based on the low levels reported and the intended use of the subject property as an industrial site, Kleinfelder recommended that no further evaluation of the former Disposal Site B be conducted and that the site be considered "clean-closed." On July 14, 1999, Kleinfelder abandoned well MW-7. Mr. Rodney Estrada, an inspector from the San Joaquin County PHS/EHD was present during a portion of the abandonment activities. During well abandonment of MW-7, an attempt was made to drill out well casing and well materials from surface to a total depth of 30 feet. The well was subsequently tremie-grouted with a neat cement/bentonite slurry to surface grade. Based on the limited information found regarding these wells within documentation reviewed at the RWQCB and within previous Phase I ESA reports provided to AEI during this investigation, it is unclear when and why well MW-7 was installed on the subject property. No soil sampling or groundwater sampling data was found for these wells within any of the documentation reviewed for the Spreckels Sugar site. However, water level measurement data was collected from these wells by Kleinfelder between February and October 1997. Therefore, it seems that the wells were possibly installed to collect only groundwater elevation and flow information. Based on the local regulatory oversight provided during the abandonment of well MW-7 in 1999, the former presence of this well on the subject property is not expected to represent a significant environmental concern. Based on the trace concentrations reported within the soil and groundwater samples collected from Site B, Mr. Robert McCallum of the San Joaquin County PHS/EHD verbally authorized the backfilling of Site B on July 16, 1999. The debris removed from Site B was disposed of or recycled offsite. According to a 2001 report prepared by URS Corporation and dated October 17, 2001, Site B was granted a verbal "clean-closure" by Mr. Robert McCallum of the San Joaquin County PHS/EHD. According to URS, several subsurface investigations were conducted by Kleinfelder circa 1997- 2001, in the areas of the former wastewater ponds located on the Spreckels Sugar site, which comprised a large portion of the subject property. During the subsurface investigations, soil samples were collected from the four former lime ponds, the four former mud ponds, the then active on-site wastewater ponds and the orchard area of the former Spreckels Sugar site. The numerous soil samples were analyzed for metals, total petroleum hydrocarbons as diesel (TPHd), pesticides and herbicides, polychlorinated biphenyls (PCBs), volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), triazine, carbamate pesticides and chromium. According to URS, the samples collected from the wastewater pond sludge by Kleinfelder did not reveal concentrations of metals or hazardous substances that appeared to be Project No. 297376 AEI June 22, 2011 Page 15 Consultants