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C Mr. Robert McClellon Page 2 of 5 the site with regard to applicable California Code of Regulation, Title 27 for site security, cover, and drainage and erosion control. The investigation consisted of excavating numerous trenches on several adjoining parcels of land, characterizing the soil and debris encountered in the excavations, monitoring the air for potential contaminants, and collecting and analyzing numerous soil samples. No hazardous levels of metals, volatile organic constituents (VOCs), semivolatile organice constituents (SVOCs), heavy metals, or any other tested constituent of concern were detected in samples collected from the subject parcels. Based upon its investigation, the CIWMB concluded that the subject parcels maintained inadequate cover and drainage and erosion control and failed to meet site security standards outlined in Title 27. The CIWMB recommended that 1) above -ground surface wastes be disposed of at a permitted landfill, 2) buried wastes be consolidated, covered, and graded to meet State Minimum Standards of Cover, 3) the site be properly secured by fence and gate to prevent access by unauthorized vehicles and persons, and 4) additional testing be conducted as necessary during remediation and appropriate action taken based upon laboratory results. In a letter dated September 18, 2003, the California Regional Water Quality Control Board, Central Valley Region (RWQCB) noted that the results of the investigation demonstrated that the wastes at the site do not have hazardous waste characteristics. Tentative plans for Site mitigation include excavating debris from certain areas of each parcel for off-site disposal, consolidating the remaining debris at selected portions of each parcel, constructing an engineered cap over the consolidated debris, and providing adequate drainage/erosion control and site security. On July 28, 2004, Ground Zero supervised the advancement of five soil borings at the subject site, two of which were located on Parcel 14 (SB4 and SB5). Soil samples collected at depths of approximately 10 and 20 feet bgs from each boring were submitted to State -certified Argon Laboratories (ELAP #2359) for analysis. Discrete groundwater samples were collected through a temporary well screen installed in each boring. A new well screen was installed in each boring to avoid potential cross contamination issues. Soil samples selected for analyses were analyzed by Argon for total petroleum hydrocarbons as oil (TPHo) using EPA method 8015 modified, CAM 17 metals, and soluble lead. TPHo and soluble lead was not detected in any of the samples analyzed. Many CAM 17 metals were detected, but all were at levels well below the preliminary remedial goals and hazardous waste designation levels. Analytical results are summarized in Table 1. Groundwater samples were analyzed by Argon for TPHo, volitile organic compounds (VOCs) by EPA 8260, and soluble lead. All of the analytes sampled were below the laboratory detection limits. Groundwater analytical results are summarized in Table 2. The analytical results suggest that although the wastes have remained buried at the site for up to fifty years native soil and groundwater beneath the site have not been demonstrably degraded. As a result, the wastes currently buried at the site should not be considered designated waste as suggested in the Regional Board's letter dated September 18, 2003. G:\GROUNDZE\Palomino\wp_parce114.doc