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KLEINFELDER File No. 20-3978-01.W10 July 26, 1997 4) Other issues should be addressed prior to pond closure. The possible presence of buried 55-gallon drums and other debris in the lime pond levees should be evaluated. The extent of asbestos disposed of with lime in the lime ponds should also be assessed. Due to the friable (powdery) nature of the dried lime, if asbestos is present in concentrations greater than 1%, the material in the lime ponds may be considered a hazardous waste. 5) Additionally, accumulated pond bottom sludge in the existing wastewater ponds, mud ponds, and in the southeast 33 acres of the site (former wastewater ponds) may contain elevated concentrations of metals or other hazardous substances. Soil samples should be collected and analyzed from the existing and historical pond bottoms. There are also reports that the sludge from the pond bottoms was periodically removed and spread on site. It may be prudent to collect and analyze soil samples from several random representative locations on the property to evaluate the impact of this practice to the soils of the site. The former pulp drying ponds should be assessed. 6) A plugged and abandoned oil and gas test well is located on site. Drilling mud pits associated with the drilling of the abandoned oil well may be buried within a 200-foot radius of the abandoned well. These pits would be at an approximate depth of three to five feet, and cover an approximate area of 10 X 30 feet. According to a California Waste Management Board publication entitled "Oil Field Wastes", "Drilling mud is a dense slurry circulated through the well bore to lubricate and cool the drill bit, circulate cuttings and other debris to the surface to extraction, and to counter the build-up of hydrostatic pressures encountered in geologic formations. Drilling muds may be water or oil based. Water based muds are generally considered non- hazardous and are the most common. Oil based muds are generally considered hazardous". It is not known if drilling mud pits are buried near the abandoned oil well on site, or what type of drilling mud was used to drill the oil well on the site. No obvious visual indications of buried drilling mud pits were noted during our on- site reconnaissance. A geophysical investigation should be conducted to evaluate the presence/absence of buried drilling mud pits. If drilling mud pits are discovered on site, soil sampling and analysis should be conducted. 20-3978-01.W10 12017L155 Page 9 of 50 Copyright 1997,Kleinfelder,Inc.