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KLEINFELDER File No. 20-3978-01.W10 July 26, 1997 21)A railroad spur(s) has been located on site since construction of the factory. Various herbicides or waste oil may have been used for weed control along the railroad tracks. Hazardous substances may have been transported on site via railcars. Creosote or pentachlorophenol may have been used to treat the railroad ties in the railbed. Locomotive maintenance was conducted on site wherever necessary. PCBs, oils, and solvents may be associated with said maintenance. According to Mr. Tucker, the rail spurs will remain on site to service future development. The rail spurs should be visually inspected for evidence of contamination. If obvious signs of contamination are discovered, sampling and analysis should be conducted. If the rail spurs are to be removed, then confirmation soil sampling should be immediately conducted after removal of the railbed to verify that no contamination is present. 22)Due to the long history of the former Spreckels Sugar Plant, and the lack of available documentation regarding potential environmental issues at the site, additional environmental concerns (such as undiscovered landfills, soil staining, previously unknown USTs etc.) which were not revealed during this assessment may be discovered during development. Additionally, Kleinfelder is continuing attempts to locate and interview former Spreckels employees. If additional environmental issues are discovered during development of the site, or are revealed by interviews with former Spreckels employees, Kleinfelder should be contacted for additional consultation. 23)Several issues of potential geotechnical significance were identified during this assessment. Evaluation of geotechnical issues is beyond the scope of an ESA. The potential geotechnical issues include the impermeable pond bottoms in the southeast 33 acres of the site, the practice of spreading tare dirt and waste organic matter over the feed lots and fields, and the presence of a concrete slab (reported by Mr. Tucker) buried approximately 8 feet below the factory. These issues should be evaluated by a geotechnical engineer prior to development of the site. 24)The California Division of Oil and Gas should be consulted in writing prior to development in the area of the former oil test well. 25)Soil samples should be collected in the vicinity of the cooling towers and analyzed for the presence of hexavalent chromium. 20-3978-01.W10/2017L155 Page 14 of 50 Copyright 1997,Kleinfelder,Inc.