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KLEINFELDER File No. 20-3978-01.W10 July 26, 1997 3.2 Phase I Environmental Site Assessment Kleinfelder conducted a Phase I Environmental Site Assessment(ESA) of the property known as the Former Spreckels Sugar Plant in Manteca, California (Kleinfelder Job No. 20-3978-01.1`01, dated October 18, 1996). The recommendations expressed in that report are as follows: 1) Agricultural chemicals have been used at the site as part of normal crop production. No obvious evidence of the misuse of such chemicals was noted during our site reconnaissance or discovered during our historical research. The impact of the on-site and/or regional use of agricultural chemicals to soil and groundwater at the site is unknown. In general, proper application of agricultural chemicals such as pesticides, herbicides or fertilizers to crops does not pose a major concern for industrial or commercial development. However, a portion of the site is planned for residential development. It is recommended that surface and shallow depth soil samples be collected in proposed residential areas and analyzed for pesticides and herbicides. 2) A beet seed warehouse is located on site. Soils in the vicinity of the beet seed warehouse should be sampled and analyzed for the presence of pesticides. 3) Groundwater monitoring wells have been installed on site to evaluate the potential groundwater contamination issues due to the lime, wastewater and mud ponds. The groundwater samples have been analyzed for inorganic constituents. Sampling results to date have indicated that arsenic, barium and nitrates have been detected in concentrations above California Maximum Contaminant Levels. However, the monitoring wells on-site have not been sampled for organic chemicals such as solvents and petroleum constituents. Internal Spreckels documentation indicates that toluene,benzene,pentachlorophenol, acetone,phenol, trichloroethane, trichloroethene and di-n-butylphlthalate were present in wastewater samples collected in 1985. Additionally, large quantities of hazardous materials (caustics, acids, solvents etc.) have been used at the factory and stored in stationary containers or in "totes". Historical spillage of hazardous substances within the factory would most likely have been discharged to the wastewater ponds via internal drains. A closure pian will be required by the Regional Water Quality Control Board for the ponds on site. It is recommended that a plan be drafted to include sampling and analysis of the existing monitoring wells for organic chemicals including those chemicals detected in the 1985 wastewater sampling. 20-3978-01.W10 12017L155 Page 8 of 50 Copyright 1997,Kleinfelder,Inc.