Final Preliminary Endangerment Assessment Parcels 1A & 1B Hamilton Air Force Base Novato, California

FINAL PRELIMINARY ENDANGERMENT ASSESSMENT PARCELS 1A & 1B HAMILTON AIR FORCE BASE NOVATO, CALIFORNIA

425 South Main Street Sebastopol, CA 95472

October 21, 2013

A Report Prepared for:

Mark Silva Director of Maintenance, Operations and Transportation Novato Unified School District 819 Olive Avenue, Novato, CA 94945

FINAL PRELIMINARY ENDANGERMENT ASSESSMENT PARCELS 1A & 1B HAMILTON AIR FORCE BASE NOVATO, CALIFORNIA

October 21, 2013

Prepared by:

Martha A. Murphy, M.S.

______Christina J. Kennedy Senior Project Geologist

425 South Main Street Sebastopol, California 95472 (707) 823-2324

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TABLE OF CONTENTS

1.0 EXECUTIVE SUMMARY ...... 1 2.0 INTRODUCTION ...... 3 2.1 Purpose ...... 3 2.2 Site Description ...... 3 2.2.1 Site Identification ...... 3 3.0 BACKGROUND ...... 5 3.1 Site Status and History ...... 5 3.1.1 Site Status ...... 5 3.1.2 Site History ...... 5 3.1.2.1 Current and Past Business Operations at the Site ...... 5 3.1.2.2 Surrounding Land Use ...... 6 3.1.3 Hazardous Substance/Waste Management Information ...... 7 3.1.3.1 On-Site Storage, Treatment, and Disposal of Hazardous Substances .....9 3.1.3.2 Regulatory Status ...... 9 3.1.3.3 Prior Assessments/Remediation ...... 9 4.0 APPARENT PROBLEM ...... 14 5.0 ENVIRONMENTAL SETTING ...... 15 5.1 2011 Exchange Triangle Parcel 1A CRUP ...... 15 5.2 2008 Exchange Triangle Parcel 1B CRUP ...... 16 6.0 SAMPLING ACTIVITIES AND RESULTS ...... 17 6.1 Summary of Activities Conducted to Complete the PEA ...... 17 7.0 UPDATED HUMAN HEALTH SCREENING EVALUATION ...... 18 7.1 Discussion of Human Health Risks Associated with Lead and OCPs...... 18 7.2 Discussion of Human Health Risks Associated with Most Recent Soil Vapor Data ...... 20 7.2.1 Gasoline Constituents in Soil ...... 20 7.2.2 VOCs in Soil Gas ...... 20 7.2.2.1 Review of Previous Soil Gas Assessment ...... 20 7.2.2.2 Discussion of Office of Environmental Health Hazard Assessment School Screen Analysis ...... 20 7.2.3 MTBE in Groundwater ...... 21 8.0 ECOLOGICAL SCREENING EVALUATION...... 22 9.0 COMMUNITY PROFILE ...... 23 10.0 CONCLUSIONS AND RECOMMENDATIONS ...... 24 10.1 Summary and Conclusions ...... 24 10.1.1 Summary ...... 24 10.1.2 Conclusions ...... 24 10.2 Recommendations for Further Action ...... 25 11.0 REFERENCES ...... 26

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APPENDICES

Appendix A - Plates Appendix B - Lead and Organochlorine Pesticide Assessment and Removal Action Summary Appendix C - Covenants to Restrict Use of Property Appendix D - Johnson Ettinger (J&E) Output Data for Soil Gas and Groundwater

PLATES (Appendix A)

Plate 1 - Site Location Map Plate 2 - Site Plan Plate 3 - MTBE in Groundwater Plume and Landfill 26 Location Map

PROVIDED ON DISC

Historical Aerial Photographs and Topographic Maps Final Human Health Risk Assessment Report, Battelle Memorial Institute and ERRG, 2011

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1.0 EXECUTIVE SUMMARY

This Preliminary Endangerment Assessment (PEA) report has been prepared by ECON of Sebastopol, California, on behalf of the Novato Unified School District (NUSD) for the purposes of documenting the comprehensive environmental review of the Hamilton Air Force Base Public Benefit Conveyance Parcels 1A and 1B in Novato, California (hence forth referred to as Site), in accordance with Education Code Sections 17210, 17210.1 and 17213.1. Section 17210 et.seq of the Education Code mandates that in order to qualify for State funding for acquisition or construction projects, School Districts must complete environmental assessments and cleanups in accordance with recognized standards.

The Site is owned by NUSD (Plate 1, Appendix A). The report contains a comprehensive summary about past uses of the Site, as well as information about previous environmental assessments and remediation at the Site and human and ecological health screenings for the Site prior to its redevelopment by NUSD. NUSD received the parcels in a Public Benefit Conveyance from the U.S. Navy after Hamilton Air Force Base was closed during a U.S. Department of Defense base realignment and closure initiative.

The Site is bordered by a residential development and State Highway 101 on the west, a railroad right of way on the East, Main Gate Road on the south, and State Access Road on the north (Plate 2). The Site was used as an army air field and an air force base from 1932 until 1974, when it was de-activated.

Chemicals of potential concern (COPCs) known to be present on the Site are: Lead, total petroleum hydrocarbons as gasoline (TPHg), benzene, toluene, ethylbenzene, and xylenes (BTEX), and methyl tert-butyl ether (MTBE) in soil; MTBE in groundwater; and the volatile organic compounds (VOCs) benzene, trichloroethene, vinyl chloride, and 1,3-butadiene in soil gas. These chemicals were released during past activities at the Site, which included operation of a gasoline service station and maintenance of automobiles and other military personnel support activities.

The Site has undergone remediation activities by the Navy in an attempt to remove the petroleum hydrocarbon and volatile COPCs, and is currently being monitored for long-term natural attenuation (degradation) of residual COPCs. A lead removal action was also recently conducted under authority of the California Department of Public Health Childhood Lead Poisoning Prevention Branch to remove lead-impacted soil from the past use of lead-based paint on buildings at the Site.

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Based on risk analyses conducted and reviewed and updated for this site, ECON concludes the following:

1. ECON performed a final statistical analysis on the entire population of lead in soil data including the original data for soil that remained in place and the confirmation data collected after the removal action. Based on the 95% UCL value of 40.1 mg/kg, the residual lead contamination at the site is considered acceptable under the most restrictive residential land use scenario.

2. Upon review of the lead and Organochlorine Pesticides (OCPs) data DTSC agreed that the appropriate criteria to evaluate the data was the RSLs established by the USEPA Region 9. All OCP data were below the RSLs for residential exposure.

3. Battelle, the Navy’s environmental consultant, calculated that the risks associated with gasoline in soil left in the ground at the Site are below 10-6, which according to the Department of Toxic Substances Control (DTSC) is acceptable under the most restrictive residential land use scenario.

4. MTBE in groundwater at the Site is considered a potential hazard due to potential vapor intrusion to indoor air. Based on ECON’s updated human health screening evaluation, section 7 of this document, the potential human health risk due to exposure to MTBE in indoor air is negligible.

5. VOCs are present in soil gas in the vicinity of former Building 965. A non-time-critical removal action was conducted in 2009 to reduce VOCs in soil gas in that area. Soil gas monitoring conducted since the removal action indicates contaminations have declined further. ECON concludes that in aggregate, the risk associated with VOCs is lower in 2012 than was calculated in Battelle’s 2011 risk assessment.

Based on our review of past environmental assessments and remediation at the Site and on current Site conditions, ECON recommends no further action by NUSD for environmental assessment or remediation at the Site. NUSD should continue to regularly review the ongoing sampling of soil gas and groundwater being conducted by the Navy at the Site and, when natural attenuation has reduced the COPCs on the Site to below reportable limits, request that land use controls be removed from the Site.

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2.0 INTRODUCTION

2.1 Purpose

ECON has prepared this Preliminary Endangerment Assessment (PEA) for the Site on behalf of NUSD. The purpose of the PEA was to complete a comprehensive environmental review of the Site in accordance with Education Code Sections 17210, 17210.1 and 17213.1. Section 17210 et.seq of the Education Code mandates that in order to qualify for State funding for acquisition or construction projects, School Districts must complete environmental assessments and cleanups in accordance with recognized standards. This report also includes a comprehensive history of the environmental assessment and remediation work that has been performed at the Site and provides human and ecological health screenings for the Site prior to its redevelopment by NUSD for administrative and/or maintenance facilities and educational facilities.

The Site was used as an army air field and then as an air force base from 1932 until 1974, when it was de-activated. Most of the Site has remained unused since 1974 except the southeast portion of the Site (Parcel 1B), which was developed by NUSD at some time after 1998. An in- depth description of the history and past business uses of the Site is provided in Section 3.1.2 below.

This PEA Report was prepared in a manner consistent with the State of California Environmental Protection Agency (CalEPA) DTSC guidance on the Preparation of Preliminary Endangerment Assessments (DTSC 1994).

2.2 Site Description

2.2.1 Site Identification

Hamilton Air Force Base (HAFB) is an inactive former military installation located in Novato, California. It is situated between State Highway 101 on the west and San Pablo Bay on the East (Plate 1). The Site is owned by NUSD and it is located at the former HAFB on C Street at State Access Road. The Site consists of two parcels, 1A and 1B, which are separated by C Street. Parcel 1A, on the west side of C Street, is bounded by State Access Road to the north, a residential development to the west and the former Naval Exchange gas station facility to the south. Parcel 1B, on the east side of C Street, is bounded by B Street and railroad tracks to the north and east and buildings of NUSD’s Early Intervention Program to the south (Plate 2).

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The legal description of Parcel 1A (APN 157-980-06), from the Environmental Data Research (EDR) Environmental Lien Report (EDR, 2012), is as follows: “All that certain piece or parcel of land containing 9.408 acres, more or less, known as Parcel 1A of the Lands of Novato Unified School District, being a portion of the Rancho San Jose, situate and lying in the City of Novato, County of Marin, State of California.” The legal description of Parcel 1B (APN 157-980-06), from the EDR Environmental Lien Report, is as follows: “All that certain piece or parcel of land containing 2.95 acres, more or less, known as Parcel 1B of the Lands of Novato Unified School District, being a portion of the Rancho San Jose, situate and lying in the City of Novato, County of Marin, State of California.”

Contact Information Mark Silva, Director of Maintenance, Operations & Transportation Novato Unified School District Site Address: C Street and State Access Road, Novato, CA Mailing address: 819 Olive Avenue, Novato, CA 94945 Phone: 415-892-1596 USEPA ID No.: CAC002692963 DTSC CalSites Site Code 204114 DTSC EnviroStor No. 21970014 Parcel info: Refer to legal description provided above

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3.0 BACKGROUND

3.1 Site Status and History

3.1.1 Site Status

Parcel 1A is currently unused and is fenced to prohibit public access. Parcel 1B is currently used by the NUSD Early Intervention Program, the two buildings of which are located at the south end of the parcel.

3.1.2 Site History

According to PRC Environmental Management, Inc. and Uribe Associates (1997a) the Site and surrounding area were originally part of the 927 acre Hamilton Army Airfield (HAAF), a U.S. Army Corps facility, which was constructed between 1932 and 1935. HAAF provided airplane maintenance and repair and was a process point for combat crews. HAAF was transferred to the Air Force in 1947 and was renamed HAFB. In 1974, the U.S. Air Force deactivated the facility and initiated the transfer of excess property under the U.S. Department of Defense Base Realignment and Closure process. The residential housing units were transferred to the Navy in 1975 as Department of Defense Housing Facility Novato (DODHF) and the remaining property was transferred to various federal agencies. NUSD received the Site in a Public Benefit Conveyance from the U.S. Navy through the U.S. Department of Education. Parcel 1B was transferred to NUSD in April 2009 and Parcel 1A was transferred to NUSD in January 2012.

3.1.2.1 Current and Past Business Operations at the Site

Information about the Site history and land use has been synthesized from numerous documents, most of which were produced as environmental investigations. The documents are supplemented by a synthesis of historic aerial photographs, historical topographic maps, interviews, public agency records, and other available resources. Historical aerial photographs taken in 1953, 1965, 1975, 1983, 1993, 1998, 2005 and 2006 and historical topographic maps from 1914, 1942, 1954, 1968 and 1980 were viewed (provided on attached disc).

The Northern half of Parcel 1A was most recently used as a Base Exchange shopping center. Building 971 on the northern half of Parcel 1A was constructed in 1975 to house a complex of

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department-store-like shops and services. Former Buildings 954 and 955 were used for maintenance and hazardous materials and waste storage. Building 960, built in 1942, was a contractor’s office and shop and an automobile maintenance and tire shop (Naval Facilities Engineering Command [NAVFAC], 2004).

The southern half of Parcel 1A was a Public Works Center. The Center was responsible for operations and maintenance of the buildings and infrastructure of the base. The buildings were constructed in the mid-1940s and were used for workshops, offices and storage. The Site is the former location of a Public Works Center gas station referred to as #957. The station was located on the east central side of Parcel 1A (Plate 2) and contained a 12,000 gallon gasoline underground storage tank (UST). The two buildings at the gas station – Buildings 957 and 958 – were used for automobile maintenance, a fueling station, and hazardous materials and waste storage areas (PRC Environmental Management, Inc. and Uribe Associates, 1997a).

Building 965, built in 1958, was a contractor’s shop and work area and an automobile maintenance shop. Building 969, built in 1942, was a Public Works Center Shop storage and automobile maintenance shop (NAVFAC, 2004)

Former Buildings 972 and 973 are located at the south end of the Site. Building 972 was used for automobile maintenance activities and hazardous materials storage and contained some offices and Building 973 was used for automobile maintenance activities and then as a youth recreation facility (PRC Environmental Management, Inc. and Uribe Associates, 1997b).

Parcel 1B was the northern portion of what was referred to as the “Air Force Triangle Zone.” It contained Building 926, a supply warehouse; Building 928, a gymnasium; and Building 930, which was used as a barracks, for Air Force Headquarters activities, as housing, for personnel support activities, and as a Credit Union. Buildings 926 and 928 were demolished at some time between 1962 and 1991 (PRC Environmental Management, Inc. and Uribe Associates, 1997b). Based on a review of air photos, Building 930 was demolished at some time between 1983 and 1993.

3.1.2.2 Surrounding Land Use

The adjacent properties to the west and the northeast of the Site are developed with residential housing. The Site is bordered on the north by State Access Road. To the northwest of the Site, across State Access Road, are remaining commissary triangle zone buildings from the previous use of the area as HAFB. Parcel 1B is adjacent to the east side of the northern portion of Parcel 1A and east of C Street. The remaining property to the east of Parcel 1A is occupied by North

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Bay Children’s Center and, south of that on the east side of C Street and adjacent to the north side of Main Road, the Novato Charter School. Immediately adjacent to the east side of Parcel 1B are railroad tracks operated by the Golden Gate Bridge, Highway and Transportation District and immediately adjacent to the east side of the tracks is B Street.

The properties adjacent to the Site on all sides were all previously part of HAFB. Base housing (single-family homes) were adjacent to the west side of the Site. Buildings in the commissary triangle zone to the northwest of the Site included an auto hobby shop and a dry cleaner. An athletic field previously existed to the northeast of the Site across State Access Road. This field has subsequently been developed with residential housing. Buildings in the Air Force triangle zone to the east of the Site included administrative offices, classrooms, quarters, and a contractor storage yard. To the south of the Site was former Naval Exchange (NEX) gas station. The NEX gas station was located at the northwest corner of Main Entrance Road and C Street, where Building 970 and associated pump islands were in operation from the mid-1970s through the early 1990s.

3.1.3 Hazardous Substance/Waste Management Information

As discussed in Section 3.1.2.1 above, activities on the Site in the past involved the use and/or storage of hazardous substances. The Hazardous Substance/Waste Management Summary below lists each building at the Site, the known past activities at each building, the hazardous substances associated with each activity, and whether or not each substance may have been stored or disposed of on the Site. Sources of hazardous materials information included SSPORTS (1998), PRC Environmental Management, Inc. and Uribe Associates, (1997b), and Engineering Field Activity West, 1997a.

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Hazardous Substance/Waste Management Summary

Building Activities and/or Potential Hazardous Stored or Disposed of # Use Substances On Site? 926 Supply warehouse Unknown Unknown 928 Gymnasium Unknown Unknown Barracks, Air Force Headquarters activities, 930 housing, personnel support activities, Credit ACM Interior building material Union 954 Maintenance and hazardous materials and waste Unknown Unknown storage 955 Maintenance and hazardous materials and waste Unknown Unknown storage 957 Auto maintenance, fueling station, TPH-purgeables, TPH- Stored on Site hazardous materials & waste storage extractables, VOCs, metals 958 Auto maintenance, fueling station, hazardous TPH-purgeables, TPH- Stored on Site materials & waste storage extractables, VOCs, metals 960 Contractor’s office and shop; automobile TPH-purgeables, TPH- Generated and stored on Site maintenance and tire shop extractables, VOCs, metals 965 Contractor’s shop and work area and TPH-purgeables, TPH- Generated and stored on Site; ACM is automobile maintenance shop extractables, VOCs, metals, ACM Interior building material Public Works Center Shop storage and TPH-purgeables, TPH- Generated and stored on Site; ACM is 969 automobile maintenance extractables, VOCs, metals, ACM, Interior building material; LBP used shop LBP on exterior 971 Navy Exchange – Grocery store, beauty salons, Perchloroethylene Unknown barber shops, dry cleaner 972 Automobile maintenance activities TPH-purgeables, TPH- Generated and stored on Site; ACM is and hazardous materials extractables, VOCs, metals, ACM, Interior building material; LBP used storage LBP on exterior 973 Automobile maintenance activities; youth TPH-purgeables, TPH- Generated and stored on Site; ACM is recreation facility extractables, VOCs, metals, ACM Interior building material

ACM: Asbestos-Containing Materials

TPH: Total Petroleum Hydrocarbons VOCs: Volatile Organic Comopunds

Abbreviations LBP: Lead-Based Paint

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3.1.3.1 On-Site Storage, Treatment, and Disposal of Hazardous Substances

The Environmental Impact Statement (EIS) prepared by Engineering Field Activity West (1997b) stated the following regarding on-site storage, treatment, and Disposal of Hazardous Substances at the Site:

“DODHF is listed as a small-quantity generator of hazardous waste. It is not listed in the March 1992 RCRA (EPA) database as a large quantity hazardous waste generator nor as a treatment, storage, and disposal facility. Hazardous waste generated at DODHF formerly was collected and stored at a hazardous waste storage facility in Building 957. According to the BCP this waste consisted of waste from shop activities. It was periodically removed for off-site disposal.”

3.1.3.2 Regulatory Status

The Site is currently listed in DTSC’s ENVIROSTOR Database as an active cleanup site under the oversight of the DTSC School Property Evaluation and Cleanup Division, referred to here as DTSC SPECD. The ENVIROSTOR ID number is 21970014 and the Site Code is 204114.

3.1.3.3 Prior Assessments/Remediation

The Site has an extensive environmental assessment and remediation history published in documents by the Department of the Navy and their subcontractors as a result of the Base Realignment and Closure Act of 1990 (PRC Environmental Management, Inc. and Uribe Associates, 1997a). Following is a brief summary of environmental investigation, remediation and monitoring events at the Site. The Summary of Environmental Work below lists the assessments for COPCs either conducted by ECON or for which ECON was able to obtain information, either from the Navy or their contractors or from public records reviews. A more thorough summary of environmental work at the Site through 2001 is provided in Battelle’s 2002 Corrective Action Plan for the Site (Battelle, 2002). A more thorough summary of environmental work conducted at the Site since 2001 is provided in Battelle’s Annual Site Status Report for 2012 (Battelle, 2013). Assessments for risks to human health are discussed in Section 7 on page 9.

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Summary of Environmental Work

Author Report Name Year COPCs PRC Environmental Phase I Final Environmental Baseline Management, Inc. and Survey, Department of Defense Housing 1997 TPH, VOCs, Metals Uribe Associates Facility, Novato, California PRC Environmental Phase I Supplemental Environmental Management, Inc. and Baseline Survey, Department of Defense 1997 TPH, VOCs, Metals Uribe Associates Housing Facility, Novato, California SSPORTS DOD Housing Facility, Novato, CA, Environmental Volume III, Asbestos Building Survey 1998 ACM Detachment Report for Nonresidential Buildings Final Environmental Impact Statement Engineering Field for the Disposal and Reuse of the 1997 LBP Activity West Department of Defense Housing Facility (DODHF), Novato, California

ACM: Asbestos-Containing Materials

TPH: Total Petroleum Hydrocarbons VOCs: Volatile Organic Compounds

Abbreviations LBP: Lead-Based Paint

PRC Environmental Management, Inc. and Uribe Associates (1997a) conducted an environmental baseline survey (EBS) of the Site for the Navy. The EBS included screening level sampling that was targeted towards the areas likeliest to have had releases of contaminants to the environment. The results of that report were used to establish what the Navy considered the baseline environmental condition of the Site. The survey consisted of sampling for purgeable and extractable Total Petroleum Hydrocarbons (TPH), Volatile Organic Compounds (VOCs), and metals, and some minor sampling for asbestos-containing materials (ACM) at various locations throughout the Site based on past uses of the specific locations (PRC Environmental Management, Inc. and Uribe Associates, 1997a). The survey did not address UST removals and investigations, lead-based paint, or PCBs. Based on the results of the sampling, the Navy recommended that no further action be taken at the Site regarding any detected contaminants other than the UST releases at buildings 957 and 970. These releases are discussed below.

PRC Environmental Management, Inc. and Uribe Associates (1997b) provided a summary and assessment of pesticide usage at the Site in their 1997 supplemental EBS. They stated in

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Appendix B of the document, “Pesticides, insecticides, termiticides, and rodenticides were applied intermittently on an as needed basis at the DODHF site either by personnel from the Navy Public Works Pest Control Department or by contractor personnel. All personnel from the Public Works Pest Control Department or contractor were trained and licensed in the proper and legal application of pesticides, which included insecticides, termiticides, and rodenticides listed above. All pesticides were applied per manufacturer's directions in accordance with the State and Federal EPA registered pesticide label directions and in accordance with the installation's annually approved Pest Management Plan. Incidental use of pesticides by homeowners is presumed. Therefore, since the pesticides and herbicides were routinely applied in a manner consistent with the standards for licensed application, they likely do not pose a threat to human health and the environment. In addition, since pesticides were applied by specific, trained personnel, there is no indication that reportable quantities of pesticides were stored at DODHF.”

The SSPORTS Naval Environmental Detachment of Vallejo, California, conducted an asbestos survey of non-residential buildings in 1997 (SSPORTS, 1998) including the buildings that were remaining on the Site at that time. The purpose of the survey was to observe the condition of damaged and/or friable ACM that was observed during two earlier ACM surveys conducted by the Navy and to identify additional damaged and/or friable ACM that was not identified during the two earlier surveys. Damaged and/or friable ACM was detected during this survey on the interiors of Buildings 930, 965, 969, 972, and 973.

Polychlorinated biphenyls (PCBs) were commonly used in electrical transformers and capacitors, as well as some light fixtures, ballasts and machinery in the past. A survey of all oil-filled electrical property on the Site was conducted in 1993 with a follow-up in 1998 (NAVFAC, 2004). No oil-filled electrical equipment with PCBs at a minimum concentration of 5 parts per million – the screening level above which the State of California considers the fluid a hazardous waste – were identified at the Site.

Engineering Field Activity West (EFAW), of San Bruno, California, conducted a 1997 assessment of non-residential buildings for potential soil lead hazards that included the Site (EFAW, 1997). The assessment was a visual survey of the exterior of non-residential buildings at HAFB for potential lead-based paint (LBP) hazards. Buildings at the Site that were assessed for soil lead hazards due to LBP were: 930, 960, 965, 969, 972 and 973. EFAW determined that these buildings either contained an impervious structure on the ground surrounding them (pavement) or the condition of the exterior paint was good and/or there were no paint chips observed around the buildings. EFAW concluded that, based on these visual results, the

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buildings at the Site “…do not have the potential to pose a threat or do not pose a significant threat with respect to lead hazard from lead-based paint.”

A Navy Exchange service station was formerly located at Building 970, adjacent to the south end of the Site in the upgradient direction of groundwater flow from Parcel 1A (Plate 2). It housed three single-walled, steel 10,000-gallon USTs that contained unleaded gasoline and one 1,000- gallon waste oil tank. The gasoline USTs were located approximately 70 feet south of Building 970. These tanks and their associated piping were in use from the mid-1970s until their removal in 1995.

Building 957 is the former location of a Public Works Center (PWC) gas station (Plate 2). A 12,000-gallon gasoline UST at Building 957 and its associated piping were excavated and removed from the Site in 1992.

A release of gasoline from all four of the USTs at Buildings 957 and 970 impacted soil and groundwater beneath the Site. The specific COPCs from the releases are benzene, toluene, ethylbenzene and xylenes (BTEX) and methyl tert-butyl ether (MTBE). An interim remedial action to remove the BTEX and MTBE from soil beneath the Site using air sparging and soil vapor extraction was started by Battelle, the Navy’s environmental consultant at the Site, in June 1998 (Battelle, 2013). Since these initial releases, concentrations of BTEX in groundwater have been significantly reduced as a result of the active treatment as well as natural attenuation mechanisms, leaving MTBE as the only COPC remaining in groundwater (Battelle, 2013). Because the MTBE groundwater plumes underlying these two areas have merged and are no longer distinguishable from one another, the individual site designations have been combined and relabeled as “Former UST Site 957/970.” Active remediation was discontinued in January of 2009 and Parcel 1A was monitored for one year for rebound of the COPCs. The system was removed in 2010, although some equipment remains at the Site.

In 1992 a 2,000-gallon fuel oil UST was removed from the vicinity of Building 972. According to NAVFAC (2004), soil and groundwater samples collected during the removal of the UST contained TPH. The San Francisco Bay Regional Water Quality Control Board (RWQCB) then opened a Leaking Underground Storage Tank (LUST) case for the Site. A site investigation was subsequently conducted to characterize the extent of TPH contamination but analysis of both soil and groundwater showed concentrations of TPH below action levels. The LUST case was closed by the RWQCB in November, 1996.

In October 2006, ECON, on behalf of NUSD, collected soil gas samples in the vicinity of Building 965, the former Public Works Maintenance Building. The sampling resulted in the

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detection of 28 volatile organic compounds and 6 chlorinated compounds. The Navy conducted a Non-Time-Critical Removal Action (NTCRA) in November 2009 to address the presence of VOCs in soil gas at the Building 965 Area within Parcel 1A (Engineering/Remediation Resources Group, Inc. [ERRG], 2009). The removal action consisted of soil excavation and pavement removal in the vicinity of the suspected former wash pad south of Building 965.

Work by the Navy subsequent to the NTCRA is summarized in the Envirostor database as follows: “In January 2010, the Navy conducted an initial round of soil vapor sampling at Parcel 1A after the completion of the removal action. The soil vapor data indicated that benzene at one location and vinyl chloride at one location exceeded the soil vapor screening levels established for the removal action. Additional soil vapor data were collected in the spring and summer of 2010 to confirm the after-action VOC concentrations. Vinyl chloride and benzene concentrations had diminished, but not below the removal action goals. The Navy prepared a comprehensive risk assessment for the site in late 2010 and a final removal action completion report was prepared to document the outcome of the removal action and present the risk assessment. The Navy has entered into a land use covenant with NUSD and DTSC for long-term restriction of groundwater, digging restrictions at the location of the former USTs, and a residential restriction in the area of the former washrack at B-965 [Building 965].”

The Navy continues to monitor both groundwater and soil gas at the Site. Soil gas is sampled annually in the vicinity of former Building 965. In 2012 it was sampled in August and in October, as one sampling event. Analytical results indicated that three COPCs – benzene, 1,3-butadiene, and vinyl chloride – were detected at concentrations greater than screening criteria (Battelle, 2013).

Groundwater is sampled annually in November. A plume of MTBE in groundwater, which has been undergoing monitoring and remediation by the Navy since 1998, extends beneath the Site. In November of 2012, the concentrations of MTBE detected in the groundwater plume beneath the Site ranged from 3.8 micrograms per liter (µg/l) to 100 µg/l, with the lowest concentrations on the western side of Parcels 1A and the eastern side of Parcel 1B and the highest concentrations in the centerline of the plume and at the northeastern end of Parcel 1A (Battelle, 2013). The plume extends from Former UST Site 957/970 northward off of the Site, where it has migrated as far as Landfill 26 (Plate 3).

The DTSC SPECD requires screening of proposed school sites where lead from lead-based paint, OCPs from termiticide application, and PCBs from electrical transformers are potential sources of soil contamination. As discussed in Section 3.1.3.3 above, PCB assessments were conducted at the Site in 1993 and 1998, and no hazardous concentrations of PCBs were detected in oil

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containing equipment. Sampling for lead from lead-based paint and for OCPs had not previously been conducted by the Navy, and the previous lead assessment at the Site was a visual lead survey, as discussed above in Section 3.1.3.3.

In preparation for the transfer of the Site to NUSD, ECON, on behalf of NUSD, began preparing a Phase I Environmental Site Assessment (ESA) Addendum in 2011. In 2012, as part of the Phase I ESA Addendum and at the request of DTSC SPECD, ECON conducted lead and OCP sampling on Parcels 1A and 1B since assessment for those substances had not previously been conducted. OCPs were not detected in soil at the Site above the U.S. EPA RSLs. These sampling activities are discussed in Section 6. Lead from lead-based paint was detected in several locations on Parcel 1A above DTSC screening limits, necessitating a limited removal action of impacted soil conducted in early 2013. The removal action was conducted under the guidance of the California Department of Public Health Childhood Lead Poisoning Prevention Branch. Final sampling of the areas from which soil was excavated for the removal action showed that remaining lead in soil, to an upper confidence level of 95% is below the DTSC screening level of 80 parts per million (ppm), as derived by the LeadSpread 8 Model (California Human Health Screening Levels for Lead, Cal/EPA Office of Environmental Health Hazard Assessment [OEHHA], 2009). A summary of the sampling and removal action activities and results is included in Appendix B.

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4.0 APPARENT PROBLEM

Past historical activities conducted at the Site have caused the release of chemicals to soil, soil vapor, and groundwater. A thorough discussion of the sources of contamination and the actions previously undertaken to remediate this contamination was provided in Section 3.1.3.3 above. The presence of residual levels of hydrocarbons, VOCs, lead, and OCPs in soil, soil vapor, and groundwater beneath the Site present measurable risks. These risks have been re-evaluated using the most current data in the human health screening evaluation for this PEA. The outcome of the revised risk assessment will determine whether further investigation or remedial action is necessary (or not) to meet current or future uses of the Site.

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5.0 ENVIRONMENTAL SETTING

The Navy has prepared a total of seven risk assessments for the Site, starting with a Tier 1 Risk- Based Corrective Action Assessment in 1998 (Battelle, 2013). According to Battelle and ERRG (2011) “Six of the seven previous Human Health Risk Assessments (HHRAs) focused on evaluating potential risks to future human receptors at Former Underground Storage Tank (UST) Site 957/970 as a result of residual fuel hydrocarbons in soil and groundwater. The 2009 HHRA was conducted to address the presence of volatile organic compounds (VOCs) in soil gas in the Building 965 Area within Parcel 1A.”

The Site has been thoroughly assessed regarding the ongoing on-site risks to human health as evaluated in these previous HHRAs, resulting in the following Covenants to Restrict Use of Property (CRUPs). The CRUP documents are included as Appendix C.

5.1 2011 Exchange Triangle Parcel 1A CRUP

The 2011 Parcel 1A CRUP was implemented based on three factors:

1. MTBE in Groundwater: The plume from the former leaking USTs extends beneath the Site and contains dissolved MTBE in concentrations exceeding the maximum contaminant level of 13 µg/l.

2. Soil contamination: Soil contamination remains on the Site at the Former UST 957 location, at depths greater than 5 ft bgs.

3. Soil gas contamination: Soil gas contamination in the Building 965 Area resulting from historical Navy Public Works activities at the suspected wash pad area south of Building 965.

Use restrictions based on these factors include:

1. Groundwater Management, essentially prohibiting activities involving interaction with the groundwater beneath the Site;

2. Soil Management, prohibiting disturbance of the soil unless it is removed and disposed of following all applicable laws and regulations;

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3. Prohibition of residential building on the Site; and,

4. Ongoing monitoring of contaminated media

The 2011 Parcel 1A CRUP is included in Appendix C.

5.2 2008 Exchange Triangle Parcel 1B CRUP

The 2008 Parcel 1B CRUP was implemented based on one factor:

1. MTBE in Groundwater: The plume from the former leaking USTs extends beneath the Site and contains dissolved MTBE in concentrations exceeding the maximum contaminant level of 13 µg/l.

Use restrictions based on this factor include:

1. Groundwater Management, essentially prohibiting activities involving interaction with the groundwater beneath the Site;

2. Ongoing monitoring of contaminated media

The 2008 Parcel 1B CRUP is included in Appendix C.

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6.0 SAMPLING ACTIVITIES AND RESULTS 6.1 Summary of Activities Conducted to Complete the PEA

As discussed in Section 3.1.3.3 above, there is an extensive history of assessment, remediation, and sampling related to the past releases of hazardous substances to the Site. The most recent assessment, remediation, and sampling at the Site is documented in ECON’s 2012/2013 Lead and OCP Assessment/Lead-in-Soil Removal Action report (Appendix B). These activities were conducted by NUSD to complete the PEA, after transference of the property from the Navy.

The Navy is currently monitoring the MTBE in groundwater plume by sampling the groundwater monitoring wells upgradient of and on the Site semi-annually to annually. They are also monitoring the VOCs in soil gas “…until levels warrant removal of the residential use restriction for the area” (Battelle, 2013). In November of 2012, the concentrations of MTBE detected in the groundwater plume beneath the Site ranged from 3.8 µg/l to 100 µg/l, with the lowest concentrations on the western side of Parcels 1A and the eastern side of Parcel 1B and the highest concentrations in the centerline of the plume and at the northeastern end of Parcel 1A. The plume extends from Former UST Site 957/970 northward off of the Site, where it has migrated as far as Landfill 26 (Plate 3).

As discussed in Section 3.1.3.3 above, soil gas is sampled annually in the vicinity of former Building 965. In 2012 it was sampled in August and in October, as one sampling event. Analytical results indicated that four COCs – benzene, 1,3-butadiene, trichloroethene and vinyl chloride – were detected at concentrations greater than screening criteria (Battelle, 2013).

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7.0 UPDATED HUMAN HEALTH SCREENING EVALUATION

In March 2011 Battelle Memorial Institute submitted a revised risk assessment for the site: “Human Health Risk Assessment for Parcel 1A, Former Department of Defense Housing Facility, Novato, California”, which is provided on the attached disc. The revised risk assessment included a comprehensive evaluation of human health risks associated with constituents of concern in soil, groundwater and soil gas. All data through 2010 was considered and a thorough site conceptual model and analysis of potential receptors and exposure pathways was presented. The following section provides updated risk information associated with data collected by ECON for completion of the PEA. This new data includes the following:

• Lead and OCP data collected in 2012 and subsequent removal actions (Appendix B); • Recent soil gas data collected in 2012; and • Recent groundwater monitoring data collected in 2012.

7.1 Discussion of Human Health Risks Associated with Lead and OCPs

Initial shallow soil sampling for lead in the areas targeted during the 2012 lead and OCP investigation resulted in locating a few areas where lead concentrations exceeded OEHHA’s revised screening level of 80 mg/kg. ECON then performed a statistical analysis on the data using ProUCL 4.1 to calculate the 95% upper confidence level (UCL) for the data population. By iteratively removing the highest concentrations from the data set ECON was able to lower the 95% UCL below the 80 mg/kg screening level. The locations of the data points that were removed from the statistical analysis were then targeted for remedial action including excavation and proper disposal of affected soil. Soil sampling completed after the removal action confirmed that remaining concentrations were below the screening level (Lead/OCP report, Appendix B)

ECON performed a final statistical analysis on the entire population of lead in soil data including the original data for soil that remained in place and the confirmation data collected after the removal action. ECON discussed the findings of the statistical analysis produced by Pro UCL 4.1 with DTSC’s toxicologist, who recommended using the “Bootstrap” 95% UCL methodology. The bootstrap method resulted in a 95% UCL of 40.1 mg/kg, which is well below DTSC’s 80 mg/kg screening level. Based on the 95% UCL value of 40.1 mg/kg, the residual lead contamination at the site is considered acceptable under the most restrictive residential land use scenario.

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Upon review of the OCP data DTSC agreed that the appropriate criteria to evaluate the data was the RSLs established by the USEPA Region 9. All OCP data were below the RSLs for residential exposure.

7.2 Discussion of Human Health Risks Associated with Most Recent Soil Vapor Data

ECON reviewed data presented in Battelle’s Annual Site Status Report for the Year 2012 (Battelle, 2013). That report presents the most recent groundwater and soil gas monitoring data available for the Site. ECON assessed the incremental changes in risk associated with more recent volatile organic constituents in soil and MTBE concentrations in groundwater.

7.2.1 Gasoline Constituents in Soil

In their 2001 HHRA, Battelle calculated the risks from soil impacted with gasoline constituents (TPHg, BTEX, and MTBE) left in place in the vicinity of Former UST 957 after the UST and associated piping were excavated and removed from the Site. Battelle stated that exposure to gasoline-impacted soil at the Site under the conditions at that time was likely to be minimal due to asphalt covering the Site and the depth of the impacted soil, which is greater than 3 to 5 ft bgs. Battelle’s calculations for residential and occupational risks from soil are summarized in Table 3-17 of the 2001 HHRA (Battelle, 2001). The highest total risks for the three categories of receptors were as follows:

Age-adjusted Residential Receptor: 6.69E-07 Child residential Receptor: 6.29E-07 Occupational Receptor: 3.51E-07

Battelle calculated that a risk below 10-6 or lower is acceptable for a site under the most restrictive residential land use scenario. In addition, subsequent sparging efforts have reduced concentrations of gasoline constituents in soil further and therefore risks have been additionally reduced.

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7.2.2 VOCs in Soil Gas

7.2.2.1 Review of Previous Soil Gas Assessment

Results of the soil gas assessment were presented in Attachment 2 of the Battelle report. ECON reviewed the data and found that the following constituents were detected in soil gas above screening levels documented in Battelle’s report (highest concentration listed):

• 1,3-butadiene - 13 microgram per cubic meter of air (µg/m3) • Benzene - 180 µg/m3 • Trichloroethene - 690 µg/m3 • Vinyl Chloride. - 410 µg/m3

To evaluate the change in risk to human health associated with these changes in concentrations ECON used the DTSC modified Johnson Ettinger (J&E) vapor intrusion model for soil gas (version 3.1). The maximum concentration for each constituent was used in the model. Model output data is presented in Appendix D. The updated incremental risk and hazard quotient for each constituent was added to Table 1 (excerpted from Battelle 2011, provided on attached disc). Yellow highlights indicate which data was updated. The total risk soil gas risk calculated by Battelle in 2011 was 4.27E-05. The total risk calculated based on the 2012 data is 1.04E-05 for a total reduction of approximately 24%.

7.2.2.2 Discussion of Office of Environmental Health Hazard Assessment School Screen Analysis

In the 2011 Battelle risk assessment Battelle input risk information for each constituent of concern into OEHHA’s School Screen spreadsheet (OEHHA, 2004). This spreadsheet is proprietary and created by each user so it was not available for ECON to update directly. The input parameters used for “School Screen” include the raw soil gas data with some consideration of the toxicity of each constituent. Although not directly comparable, the total risk associated with VOCs at Parcel 1A in 2012 is approximately 24% lower than it was at the time of the 2011 Battelle risk assessment. The following summarizes the change in risk calculated for each constituent listed in Section 7.1.1.1.

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Summary of Change in Risk

Constituent 2011 Risk 2012 Risk % Change 1,3-butadiene 9.10E-07 6.20E-07 -32 % Benzene 5.0E-06 1.6E-06 -68% Trichloroethene 1.0E-06 3.1E-06 +68% Vinyl Chloride 3.30E-05 2.2E-06 -33%

As illustrated above, in aggregate, the risk associated with VOCs is lower in 2012 than was calculated in the 2011 risk assessment. On this basis ECON concludes that the risks calculated through School Screen are likely to be proportionally lower based on the new data.

7.2.3 MTBE in Groundwater

ECON reviewed the 2013 report and found that the highest MTBE in groundwater concentration detected on Parcel 1A is 100 µg/l at monitoring well PG-MW-1. In the 2011 risk assessment the highest concentration considered by Battelle was 300 µg/l at the same well. ECON input the updated MTBE information in the J&E Model Version 3.1 for groundwater (Appendix D) and found that the hazard quotient from vapor intrusion to indoor air is 2.2E-04. The hazard quotient threshold set by the USEPA is 1.0 below which no noncancerous affects would occur to potential receptors. With a hazard quotient of 2.2E-04 ECON concludes that potential human health risk due to exposure to MTBE in indoor air is negligible.

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8.0 ECOLOGICAL SCREENING EVALUATION

An ecological screening evaluation calculates risk factors from the Site for non-domesticated terrestrial and aquatic plants and animals, but can also include domesticated species, such as livestock. A review of the California Department of Fish and Wildlife’s (Formerly California Department of Fish and Game) California Natural Diversity Database Quick Viewer (accessed April 2013) has revealed that several Federally- and State-threatened and endangered species of wildlife are listed within the boundaries of the 7.5 minute Novato topographic quadrangle within which the Site is located. In consultation with the DTSC, however, an ecological risk evaluation was not deemed necessary or conducted for the site because it is located in a developed urban setting, is occupied, or was recently occupied, predominantly by commercial building structures, and does not maintain natural resources required to support wildlife habitats. Further, ECON observed no potential for ambient air quality issues, runoff of surface water impacted with the Site COPCs, or groundwater impacted with COPCs, to impact off-site ecological receptors.

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9.0 COMMUNITY PROFILE

A community profile was not prepared by ECON for this PEA work because most of the environmental assessment, remediation and monitoring conducted at the Site has been done by the Navy. For their part, a Restoration Advisory Board (RAB) has been established and includes representatives from the U.S. Army, the U.S. Navy, the USEPA, the DTSC, and a RAB community co-chairperson. As stated in the RAB charter, the mission of the RAB is to “…promote and enhance the information exchange between the responsible government agencies and the community regarding the cleanup of the Army and Navy Base Realignment and Closure portions…” of Hamilton Army Air Field (RAB, 1995). The RAB promotes community awareness and solicits constructive community review and comment on environmental cleanup and restoration activities at the Site as well as disseminating information about the progress of the work being done. The RAB holds regular public meetings and has produced fact sheets for the public. In addition, documents related to the RAB and the Site cleanup are located at the South Novato Library, 6 Hamilton Landing, Suite 140A.

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10.0 CONCLUSIONS AND RECOMMENDATIONS

This Preliminary Endangerment Assessment (PEA) Report has been prepared on behalf of NUSD to provide information about the recent lead removal activity completed at the Site. The report has provided a comprehensive summary about past uses of the Site, as well as information about previous environmental assessments and remediation at the Site and human and ecological health screenings for the Site prior to its redevelopment by NUSD.

10.1 Summary and Conclusions

10.1.1 Summary

The Site has undergone remediation activities by the Navy in an attempt to remove the petroleum hydrocarbon and volatile COPCs, and is currently being monitored for long-term natural attenuation (degradation) of residual COPCs. A lead removal action was also recently conducted to remove lead-impacted soil from the past use of lead-based paint on buildings at the Site.

10.1.2 Conclusions

2. All OCP data was below the RSLs for residential exposure.

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3. Soil impacted with gasoline constituents (TPHg, BTEX, and MTBE) was left in place in the vicinity of Former UST 957 after the UST and associated piping were excavated and removed from the Site. Battelle calculated the risks associated with leaving this soil in place in their 2001 HHRA. The highest total risks for the three categories of receptors were as follows:

Age-adjusted Residential Receptor: 6.69E-07 Child residential Receptor: 6.29E-07 Occupational Receptor: 3.51E-07

4. MTBE in groundwater at the Site is considered a potential hazard due to vapor intrusion to indoor air. ECON concludes that with the hazard quotient threshold set by the USEPA as 1.0, a hazard quotient of 2.2E-04 for the Site means that potential human health risk due to exposure to MTBE in indoor air is negligible.

5. VOCs are present in soil gas in the vicinity of former Building 965. A non-time-critical removal action conducted in 2009 reduced VOCs in soil gas in that area, as has natural attenuation. ECON concludes that in aggregate, the risk associated with VOCs is lower in 2012 than was calculated in Battelle’s 2011 risk assessment. On this basis ECON concludes that the risks calculated through School Screen are likely to be proportionally lower based on the new data. The Hazard Index value for the hypothetical residential receptor is 0.2, which is below the U.S. EPA criterion of 1.

10.2 Recommendations for Further Action

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11.0 REFERENCES

Battelle. June 8, 2001. Final Revised Risk Assessment for Former Underground Storage Tank Site 957/970, Department of Defense Housing Facility, Novato, California.

Battelle. March 1, 2002. Corrective Action Plan for Groundwater For Former Underground Storage Tank Site 957/970, Department of Defense Housing Facility, Novato, California.

Battelle, August 22, 2006. Summary of Conceptual Site Model at Underground Storage Tank (UST) Site 957/970 and Critical Updates in the Leading Edge Area of the MTBE Plume.

Battelle Memorial Institute and Engineering/Remediation Resources Group, Inc. March, 2011. Final Revised Risk Assessment for Former Underground Storage Tank Site 957/970, Department of Defense Housing Facility, Novato, California.

Battelle. February 5, 2013. Annual Site Status Report for the Year 2012, Former UST Site 957/970, Former Department of Defense Housing Facility Novato, Novato, California.

California Department of Fish and Game, California Natural Diversity Database.

California Office of Environmental Health Hazard Assessment (CA OEHHA), February 2004. Guidance for Assessing Exposures and Health Risks at Existing and Proposed School Sites, Final Report.

CA OEHHA, 2009. California Human Health Screening Levels for Lead.

ECON and Blankinship & Associates. May 30, 2007. Conceptual Site Model for Parcels 1A and 1B, Hamilton Army Air Field, Novato, California.

Engineering Field Activity West, April, 1997a. Assessment Report of Non-Residential Buildings for Potential Soil Lead Hazards from Lead-Based Paint at the Department of Defense Housing Facility (DODHF), Novato, California.

Engineering Field Activity West, November, 1997b. Final Environmental Impact Statement for the Disposal and Reuse of the Department of Defense Housing Facility (DODHF), Novato, California.

ECON Page 27 October 21, 2013 Final Preliminary Endangerment Assessment Parcels 1A & 1B Hamilton Air Force Base, Novato, California

Engineering/Remediation Resources Group, Inc., October, 2009. “Final Removal Action Work Plan for Non-Time-Critical Removal Action for the Building 965 Area, Former Department of Defense Housing Facility, Novato, California.”

Environmental Data Resources, Inc. June 15, 2012a. The EDR-Radius Map, Inquiry No. 3345331.2s.

Environmental Data Resources, Inc. June 15, 2012b. Sanborn Map Report, Inquiry No. 3345331.3.

Environmental Data Resources, Inc. June 22, 2012c. The EDR-City Directory Abstract, Inquiry No. 3345331.6.

Environmental Data Resources, Inc. June 15, 2012d. The EDR Historical Topographic Map Report, Inquiry No. 3345331.4.

Environmental Data Resources, Inc. June 18, 2012e. The EDR Aerial Photo Decade Package, Inquiry No. 3345331.5.

Environmental Data Resources, Inc. July 2, 2012f. The EDR Environmental LienSearch Report, Inquiry No. 3345331.7S.

Naval Facilities Engineering Command (NAVFAC), August, 2004. Final Phase IVD, Finding of Suitability to Transfer, Department of Defense Housing Facility, Exchange Triangle Parcel 2 West, Novato, California.

Lawrence Livermore National Laboratory (LLNL), Livermore, California, October 16, 1995. Recommendations to Improve the Cleanup Process for California's Leaking Underground Fuel Tanks (LUFTs).

PRC Environmental Management, Inc. and Uribe Associates, April 27, 1997a. Phase I Supplemental Environmental Baseline Survey, Department of Defense Housing Facility, Novato, California.

ECON Page 28 October 21, 2013 Final Preliminary Endangerment Assessment Parcels 1A & 1B Hamilton Air Force Base, Novato, California

PRC Environmental Management, Inc. and Uribe Associates, April 15, 1997b. Final Environmental Baseline Survey Sampling and Analysis Screening Level Report, Department of Defense Housing Facility, Novato, California.

Restoration Advisory Board, Hamilton Army Airfield Joint Army and Navy Restoration Program, 1995. Restoration Advisory Board (RAB) Charter.

SSPORTS Environmental Detachment (SSPORTS), January 1998. DOD Housing Facility, Novato, CA, Volume III, Asbestos Building Survey Report for Nonresidential Buildings.

State of California, Environmental Protection Agency, Department of Toxic Substances Control (DTSC), January 1994. Preliminary Endangerment Assessment Guidance Manual.

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Appendix A

Plates

PARCEL 1A PARCEL 1B APN: 157-980-06 APN: 157-980-06

¤£101

Drawn by A. Llewellyn. March 2013. Base layer is Bing aerial photography provided by ArcGIS Online.

EXPLANATION Site Approximate Site Boundary San Jose (Pacheco) Land Grant

0 1,000 2,000 ! California Marin County Novato Scale in Feet ¨ Site Location Map Plate Novato Unified School District Hamilton Air Force Base, Parcels 1A and 1B, Novato, California 1 State Access Rd

PARCEL 1A APN: 157-980-06 PARCEL 1B APN: 157-980-06

B St

970

Main Gate Rd

C St C C St C

Drawn by A. Llewellyn. March 2013. Base layer is Bing aerial photography provided by ArcGIS Online.

EXPLANATION 0 100 200 Former Building Approximate Site Boundary Scale in Feet This Site is in the San Jose (Pacheco) land grant (Rancho); its boundary is to large for the extent and scale of this map, see Plate 1. ¨ This Site is in a Planned District zone.

Site Plan Plate Novato Unified School District Hamilton Air Force Base, Parcels 1A and 1B, Novato, California 2 ng Facility, Novato, ngCalifornia.Facility, ormer ormer 957/970,Site UST Former Department of Defense Housi

State Access Rd

PARCEL 1A 5, 2013. Annual 5,2012, F 2013. StatusSite Year Report for the PARCEL 1B

B St

Main Gate Rd Referencefor MTBE Concentration Plume: Battelle.February Drawn by A. Llewellyn. March 2013. Base layer is Bing aerial photography provided by ArcGIS Online. EXPLANATION MTBEMTBE Concentrations Concentrations (November (November 2012) 2012) 0 250 500 11 - -13 13 µg/l µg/l 1313 - -100 100 µg/l µg/l Scale in Feet ¨ >100>100 µg/l µg/l Approximate Location of Landfill 26 Approximate Site Boundary MTBE in Groundwater Plume and Landfill 26 Location Map Plate Novato Unified School District Hamilton Air Force Base, Parcels 1A and 1B, Novato, California 3

Appendix B

Lead and Organochlorine Pesticide Assessment and Removal Action Summary

LEAD AND ORGANOCHLORINE PESTICIDE ASSESSMENT AND REMOVAL ACTION SUMMARY PARCELS 1A & 1B HAMILTON AIR FORCE BASE NOVATO, CALIFORNIA

425 South Main Street Sebastopol, CA 95472

October 21, 2013

A Report Prepared for:

Mark Silva Director of Maintenance, Operations and Transportation Novato Unified School District 819 Olive Avenue, Novato, CA 94945

LEAD AND ORGANOCHLORINE PESTICIDE ASSESSMENT AND REMOVAL ACTION PLAN PARCELS 1A & 1B HAMILTON AIR FORCE BASE NOVATO, CALIFORNIA

October 21, 2013

Prepared by:

Martha A. Murphy, M.S.

______Christina J. Kennedy Senior Project Geologist

425 South Main Street Sebastopol, California 95472 (707) 823-2324

ECON Page ii October 21, 2013 Lead and Organochlorine Pesticide Assessment and Removal Action Summary Parcels 1A & 1B, Hamilton Air Force Base, Novato, CA

TABLE OF CONTENTS

1.0 INTRODUCTION ...... 1 1.1 Sampling Plan ...... 1 1.2 Soil Sampling and Laboratory Analytical Results ...... 1 1.3 Statistical Analysis of Initial and Step-Out Sampling Data ...... 3 1.4 Lead Removal Action ...... 3 1.5 Statistical Analysis of Post-Excavation Lead Data ...... 4 1.6 Summary & Conclusions ...... 4 2.0 REFERENCES ...... 6

Attachments

Attachment A - Plates Attachment B - Lead and OCP Sampling Plan Attachment C - Tables and Laboratory Analytical Reports Attachment D - Technical Memorandum with Statistical Analysis Attachment E - Waste Manifest Attachment F - Oaks Environmental Testing Analytical Report Attachment G - Statistical Analysis Post Lead Removal Action

PLATES (Attachment A)

Plate 1 – Site Location Map Plate 2 – Soil Sampling analytical Results for OCPs – Initial Assessment Plate 3 – Soil Sampling Analytical Results for Lead – Initial Assessment Plate 4 – Soil Sampling Analytical Results for Lead in Soil – Step-Out/Step Down Soil Assessment and Pre Removal Action Assessment (Excavation) Plate 5 – Soil Sampling Analytical Results for Lead in Soil – Post Removal Action Assessment (Excavation)

TABLES (Attachment C)

Table 1 – Analytical Results for Lead/OCP in Soil – Initial Assessment Table 2 – Analytical Results for Specific OCP Compounds in Soil - Initial Assessment Table 3 - Analytical Results for Quality Control Water Samples - Initial Assessment Table 4 - Analytical Results for Lead in Soil – Step-Out/Step Down Soil Assessment Table 5 - Analytical Results for Lead in Soil – Post Removal Action Assessment

ECON Page iii October 21, 2013 Lead and Organochlorine Pesticide Assessment and Removal Action Summary Parcels 1A & 1B, Hamilton Air Force Base, Novato, CA

1.0 INTRODUCTION

ECON has prepared this Lead and Organochlorine Pesticide Assessment and Removal Action Summary on behalf of Novato Unified School District (NUSD) as part of the Preliminary Endangerment Assessment (PEA) required to be conducted at the Site, Parcels 1A and 1B of the public benefit conveyance (PBC) from the United States Navy. Transfer of ownership from the Navy has been accomplished under the Base Realignment and Closure (BRAC) program. As described in the Hamilton Army Airfield Reuse Plan: Final Reuse Plan (Hamilton Reuse Planning Authority, 1996), Parcels 1A and 1B (Plate 1, Attachment A) were designated for transfer as an educational PBC to NUSD. Parcel 1B was transferred to NUSD in April 2009 and Parcel 1A was transferred to NUSD in January 2012. The PEA is being conducted prior to the redevelopment of the Site by NUSD for administrative and/or maintenance facilities and educational facilities.

In preparation for the transfer of the Site to NUSD, ECON, on behalf of NUSD, began preparing a Phase I Environmental Site Assessment (ESA) in 2011. The Phase I assessment work revealed that no previous lead or OCP sampling had been conducted at the Site other than the lead-based paint survey conducted by Engineering Field Activity West in 1997 (Engineering Field Activity West, 1997). As a result, the DTSC School Property Evaluation and Cleanup Division (DTSC SPECD) requested that NUSD conduct lead and OCP sampling on Parcels 1A and 1B.

1.1 Sampling Plan

Prior to sampling, ECON prepared a Lead and OCP Sampling Plan for the DTSC SPECD dated January 11, 2012 (Attachment B). The sample locations for both lead and OCPs were identified based on DTSC guidelines (DTSC, 1996) and subsequent correspondence and input from Mr. Neal Hutchison of the DTSC.

1.2 Soil Sampling and Laboratory Analytical Results

The number of samples collected for each building was based on the size of the existing or former building footprints and on the accessibility of exposed soil or degraded surface asphalt for sampling. Although DTSC does not require sampling beneath asphalt pavement, some samples were collected beneath asphalt pavement for due diligence purposes for potential future construction on the Parcel. These samples were collected in areas in which the asphalt was depressed or degraded (for ease of drilling through the asphalt). Initial sampling was conducted

ECON Page 1 October 21, 2013 Lead and Organochlorine Pesticide Assessment and Removal Action Summary Parcels 1A & 1B, Hamilton Air Force Base, Novato, CA

on January 11-13, 2012. Samples were collected in brass sample sleeves by hand slide hammer or with a drill rig 140 pound hammer. Discrete soil samples for both lead and OCPs were collected at a depth of 0 to 6 inches below ground surface (bgs) and samples for OCPs were additionally collected from between 2 and 3 feet bgs at each sample location. Sample locations are shown on Plates 2, 3, and 4. Tables of laboratory analytical results and the laboratory analytical reports are included in Attachment C.

Samples for OCP were composited by the laboratory as follows: up to four adjacent samples from the same depth were composited into one sample. The portion of each discrete sample that was not used in a composite was placed on hold and used for analysis if OCPs were detected above the adjusted screening level for that composite sample. Screening levels were adjusted by dividing the screening level by the number of discrete samples used for a composite. OCPs were analyzed by EPA Method 8081.

For the purpose of screening the initial data, at the direction of the DTSC, the OCP concentrations were compared with California Human Health Screening Levels (CHHSLs) for soil for residential land use. The initial sampling resulted in the detection of some constituents of OCPs in three general locations (Plate 2 and Table 1). Composite sample EB(5S, 6S, 7S, 8s), collected from the south side of former Building 928, contained p,p-DDE at a concentration of 0.012 milligrams per kilogram (mg/kg) which is below the CHHSL of 1.6 mg/kg. Discrete samples EB-19S PB/OCP and EB-20S PB/OCP, both from the north side of Building 971, contained concentrations of OCPs below to nominally exceeding the CHSSLs. Upon review of the OCP data DTSC agreed that the appropriate criteria to evaluate the data were the Regional Screening Levels (RSLs) established by the USEPA Region 9. All OCP data was below the RSLs as summarized on Table 2.

Lead analysis was conducted on the uppermost soil (closest to ground surface) from each shallow soil core. Lead samples were analyzed for total lead by EPA method 6010/6020. Total lead was detected in numerous soil samples during the initial sampling event at concentrations ranging from 8.8 to 750 mg/kg (Plate 3 and Table 1). The DTSC environmental screening level (ESL) for lead is 80 mg/kg. Based on these findings DTSC requested that step-out and step-down sampling for lead be conducted for Borings EB-25, EB-26, and EB-28, as well as two additional sampling locations along the south side of Building 972 and one additional location along the west side of Building 969, halfway between EB-25 and the north end of the building.

ECON conducted the step-out/step-down sampling on May 4, 2012. Step-out samples were triangulated around each original sample location (as listed above) at a distance of 5 feet, and

ECON Page 2 October 21, 2013 Lead and Organochlorine Pesticide Assessment and Removal Action Summary Parcels 1A & 1B, Hamilton Air Force Base, Novato, CA

samples were collected at both a shallow (0-6 inches bgs) depth and a 1 foot bgs step-down depth. Total lead was detected at concentrations exceeding the DTSC ESL for lead in four of the shallow step-out samples: EB-44-0, EB-45-0, EB-46-0, and EB-51-0. Concentrations ranged from 240 to 360 mg/kg (Plate 4 and Table 4).

Quality Assurance/Quality Control (QA/QC) samples were collected during the initial sampling. The samples collected consisted of 7 duplicate soil samples and one sample each of the water used for rinseate and a rinseate blank. QA/QC sample results are shown on Table 3.

1.3 Statistical Analysis of Initial and Step-Out Sampling Data

Based on the initial sampling for OCPs the DTSC agreed that no further action was required. Regarding the lead data ECON was requested to prepare a statistical analysis that included the total number of samples collected, the frequency of detection, and the minimum and maximum values and to calculate the 95% upper confidence limit for the data set.

ECON performed five separate statistical analyses on the lead in soil data collected at the Site using the tool ProUCL 4.1 (Attachment D – Technical Memorandum with Statistical Analysis). An initial evaluation of the data found that it did not display a normal distribution and ECON concluded that an Upper Confidence Level (UCL) for exposure point concentrations for the lead could not be calculated. Each separate statistical analysis excluded the points with the highest lead concentrations, beginning with the highest concentration of 750 mg/kg. ECON was able to eliminate all samples with concentrations at 250 mg/kg or higher (total 5 samples) and the result was a 95% Chebyshev UCL of 62.21 which is below the 80 mg/kg standard and a closer approximation of a normal distribution. ECON concluded that it would be possible to complete a limited soil removal in the area of the five highest samples and remediate any concern regarding lead in soil at the site.

1.4 Lead Removal Action

The lead removal action was conducted on February 9-11, 2012 under the guidance of the California Department of Public Health (CDPH) Childhood Lead Poisoning Prevention Branch. Lead-impacted soil was excavated and removed from the site by CDPH-certified lead abatement contractor J’s Construction of Union City, California. After removal of any asphalt covering impacted areas, lead-impacted soil was removed to a depth of 6 inches bgs in three locations. Two of the locations – Borings EB-25 and EB-38 – were excavated in a 10-foot-diameter circle around the boring locations. The third location was the former location of the skid shed and

ECON Page 3 October 21, 2013 Lead and Organochlorine Pesticide Assessment and Removal Action Summary Parcels 1A & 1B, Hamilton Air Force Base, Novato, CA

Borings EB-44, EB-45, and EB-46. Soil was excavated to at least 2 feet outside the perimeter of the former skid shed, which included Borings EB-44, EB-45, and EB-46. The excavated soil was temporarily stored onsite in a closed metal bin until it was removed and disposed of at Clean Harbors in Buttonwillow, California, on February 27, 2013. The waste manifest is included in Attachment E.

Soil was sampled in the excavation areas both immediately prior to and subsequent to excavation by CDPH-certified lead inspector assessor Maribel Robles of Oaks Environmental Testing in Oakland, California. Sample results from the pre-excavation sampling are shown on Table 4. Although concentrations of total lead in these samples were high (ranging from 420 to 2,600 mg/kg at a depth of 1 inch bgs), this soil was subsequently excavated. Post excavation soil sampling was conducted on February 14, 2013. Concentrations of lead on soil in the target locations after excavation ranged from 9.5 to 19 mg/kg at a depth of approximately 1 inch bgs (Table 5, Plate 5). These concentrations are below the DTSC ESL of 80 mg/kg. The report of sampling results from Oaks Environmental Testing Analytical Report is attached (Attachment F).

1.5 Statistical Analysis of Post-Excavation Lead Data

ECON did a statistical analysis on the data that represents all of the lead in soil remaining at the site after the lead removal action. This includes data collected throughout the site in areas that were not excavated, and the confirmation data that was collected after the removal action.

ECON performed the statistical analyses on the lead in soil data collected at the Site using the tool ProUCL 4.1 (Attachment G – Statistical Analysis Post Lead Removal Action). ECON initially prepared a frequency diagram which showed that the data displayed a lognormal distribution. With a lognormal transformation however, the data closely approximated a normal distribution thus an Upper Confidence Level (UCL) for exposure point concentrations for the lead could be calculated. ECON discussed the findings of the statistical analysis produced by Pro UCL 4.1 with Dr. Eric Scuillo of the DTSC who recommended that ECON use the “Bootstrap” 95% UCL of 40.09 which is below the 80 mg/kg RSL.

1.6 Summary & Conclusions

ECON conducted lead and OCP sampling of soil at both Parcels (1A and 1B) at the Site in 2012. Initial sampling for lead resulted in the detection of lead in soil at concentrations greater than the DTSC ESL of 80 mg/kg, requiring step-out and step down sampling in three locations on

ECON Page 4 October 21, 2013 Lead and Organochlorine Pesticide Assessment and Removal Action Summary Parcels 1A & 1B, Hamilton Air Force Base, Novato, CA

Parcel 1A. A subsequent removal action of lead-impacted soil was conducted in those three locations in February of 2013.

ECON’s assessment of OCPs in soil and assessment and removal of lead in soil at the Site has resulted in the following:

1. OCPs were detected in shallow (less than 3 ft bgs) soil in three locations at the Site. Concentrations of OCPs in these locations do not exceed the USEPA Region 9 RSLs.

2. Lead was detected in shallow soil at various locations throughout Parcel 1A, mostly concentrated in three areas adjacent to painted buildings. Removal of lead-impacted soil to a depth of 6 inches bgs in these three locations resulted in the reduction of lead in soil to acceptable levels. ECON’s statistical analysis shows that remaining lead in soil, to an upper confidence limit of 95%, averages 40.09 mg/kg, well below the DTSC ESL of 80 mg/kg; however, there are four exposure points that still contain lead above the ESL. These points are shown on Plate 3.

ECON Page 5 October 21, 2013 Lead and Organochlorine Pesticide Assessment and Removal Action Summary Parcels 1A & 1B, Hamilton Air Force Base, Novato, CA

2.0 REFERENCES

California Department of Toxic Substance Control (DTSC), June 9, 2006. Interim Guidance Evaluation Of School Sites With Potential Soil Contamination As A Result Of Lead From Lead- Based Paint, Organochlorine Pesticides From Termiticides, And Polychlorinated Biphenyls From Electrical Transformers.) Engineering Field Activity West, April, 1997. Assessment Report of Non-Residential Buildings for Potential Soil Lead Hazards from Lead-Based Paint at the Department of Defense Housing Facility (DODHF), Novato, California. April. Hamilton Reuse Planning Authority, 1995, Revised November 1996. Hamilton Army Airfield Reuse Plan, Final Reuse Plan.

ECON Page 6 October 21, 2013 Lead and Organochlorine Pesticide Assessment and Removal Action Summary Parcels 1A & 1B, Hamilton Air Force Base, Novato, CA

Attachment A

Plates

PARCEL 1A PARCEL 1B

¤£101

Drawn by A. Llewellyn. March 2013. Base layer is Bing aerial photography provided by ArcGIS Online.

Site EXPLANATION Approximate Site Boundary

0 1,000 2,000 ! California Marin County Novato Scale in Feet ¨ Site Location Map Plate Novato Unified School District Hamilton Air Force Base, Parcels 1A and 1B, Novato, California 1 (! (!0.017-0.58*^ (Chlordane(Chlordane -- 0.550.55 && g-Chlordaneg-Chlordane -- 0.58)0.58) 0.013*^, NDd Comp EB (17S, 18S, 19S, 20S): 0.020-0.040* (Dieldrin(Dieldrin -- 0.035)0.035) Comp EB (17B, 18B, 19B, 20B): 0.024-0.38* (Chlordane(Chlordane -- 0.38)0.38) (! (! ND^ NA 971

Comp EB (21S, 22S): 0.033-0.12* Comp EB (21B, 22B): ND (!ND^

(! NA, NDd Comp EB (13S, 14S, 15S, 16S): ND Comp EB (13B, 14B, 15B, 16B): ND (! (! NA NA 954 Comp EB (23S, 33S): ND (! Comp EB (23B, 33B): ND NA 926 NA (! 960 *# Comp EB (9B, 10B, 11B, 12B): ND (! Comp EB (9S, 10S, 11S, 12S): ND NA NA (! *# NA, NDd (! Comp EB (1B, 2B, 3B, 4B): ND NA, NDd (! NA Comp EB (1S, 2S, 3S, 4S): ND 955 NA 955 NA NA, NDd ND NA Comp EB (24S, 34S, 35S): ND NA NA NA (! ! Comp EB (24B, 34B, 35B): ND ( (! (! (! 965 (! NA NA 928 NA (! *# ND, ND (! (! ! ( (! NA (! 957

Comp EB (25B, 36B): ND 958 NA, NDd Comp EB (25B, 36B): ND *# NA, NDd NA NA NA 969 Comp EB (25S, 36S): ND ND, ND NA, NDd Comp EB (5S, 6S, 7S, 8S): 0.012* (! Comp EB (5B, 6B, 7B, 8B): ND

(! ND, ND *# ND, ND Comp EB (31S, 33S): ND 930 ! 930 NA ( NA *# (! 972 NA Comp EB (28S, 37S): ND 973 ND, ND Comp EB (28B, 37B): ND *# *# NA Drawn by A. Llewellyn. March 2013. Base layer is Marin County's aerial photography. All results are reported in mg/kg EXPLANATION 0.38 Concentration of analytes at or above ESL ND Analyte NOT DETECTED at or above laboratory reporting limits 0 50 100 0.012 Concentration of analytes above reporting limit NA Not Analyzed *# Sample Location in Asphalt Depression d Duplicate Scale in Feet (! Sample Location in Exposed Soil * See Table 2 for each specific OCP compound concentration ¨ Discrete samples analyzed for OCPs out of hold time Former Building ^ Approximate Site Boundary Soil Sampling Analytical Results for OCPs - Initial Assessment Plate Novato Unified School District Hamilton Air Force Base, Parcels 1A and 1B, Novato, California 2 (! 14 (! EB-20 9.4 EB-19

971 EB-18 (!180 (! EB-21 8.7

EB-17 (!11

EB-22 (! 15, 21d

(! EB-16 62 39 EB-15 (! 954 (! EB-1441 14 EB-13 (! 926 960 (! EB-12 12 *# EB-33 34 34 35 EB-11 (! *# EB-23 (! EB-10 88 11 49.88 (! 49.88 EB-9 955 51 18 21 20 (! ! ( (! (! EB-35 8.9 EB-1 EB-2 EB-24 (! 965 (! EB-3 EB-4 76 ND EB-30 928 (! EB-34 8.8 *# (! (! (! ! EB-3613 (! ( 957 EB-8 EB-7 EB-6 EB-7 EB-5 19 15 32 23 958 130 EB-29*# 969 (! EB-25 46, 240d

(! EB-27 15 EB-26 750 *# (! EB-32 32 EB-28 130 930 *# (! 38 972 EB-31

973 *# 290 EB-38 # 75 EB-37 *

Drawn by A. Llewellyn. March 2013. Base layer is Marin County's aerial photography. All results are reported in mg/kg EXPLANATION 290 Concentration of analytes at or above ESL 0 50 100 75 Concentration of analytes above reporting limit *# Sample Location in Asphalt Depression Scale in Feet (! Sample Location in Exposed Soil ¨ Former Building Approximate Site Boundary d Duplicate Soil Sampling Analytical Results for Lead - Initial Assessment Plate Novato Unified School District Hamilton Air Force Base, Parcels 1A and 1B, Novato, California 3 969

(! EB-48

!(! 35-Shed-02S 1" - 990 (! Shed EB-47 0" - 54 12" - 6.8 EB-46 0" - 240 12" - 6.9 12" - 9.1 EB-26 *# !( 0" - 11 (! EB-52 !(! 35-Shed-03S 1" - 420 12" - 7.2 1" - 2,600 35-Shed-04S !(! 969 !( 0" - 270 12" - 5.9 0" - 250 EB-44 !(! EB-45 0" - 360 12" - 72 12" - 9.7 1" - 2,400 35-972-06S EB-51 !( 1" - 8.9 35-969-01S 12" - 10 EB-25*# (!! (! EB-50 0" - 70 EB-49 12" - 11 0" - 9.7 12" - 7.4

0" - 25 EB-48 (! 12" - 6.2 !(! Shed (! *# !( !(! !(! !((!

972

12" - 12 (! 3" - 17 EB-38 12" - 7.9EB-42 (! *# (! EB-43 EB-40 3" - 8.4 35-972-05S ! (! ! 3" - 8.4 35-972-05S 3" - 15 ( 12" - 18 EB-41 1" - 16 12" - 7.3 EB-39 3" - 8.6 0" - 7.4 12" - 6.5 12" - 7.4

Drawn by A. Llewellyn. March 2013. Base layer is Marin County's aerial photography. EXPLANATION 80 Concentration of analyte at or above ESL of 80 (mg/kg) 16 Concentration of analyte above detection limit (mg/kg) 0 20 40 !( Sample Location with ESL Exceedance ! Pre-Excavation Sample Location (! Step-Out Sample Location Scale in Feet ¨ *# Step-Down Sample Location Former Building Soil Sampling Analytical Results for Lead in Soil - Step-Out/Step Down Soil Assessment and Pre Removal Action Assessment (Excavation) Plate Novato Unified School District Hamilton Air Force Base, Parcels 1A and 1B, Novato, California 4 965

Area C 969

! 35-969-01S 13 mg/kg

Area B ! 19 mg/kg Shed 35-Shed-02S 19 mg/kg ! ! 35-Shed-03S 13 mg/kg ! 35-Shed-03S 35-972-06S 35-Shed-04S 9.5 mg/kg 17 mg/kg

972

Area A

35-972-05S ! 19 mg/kg

Drawn by A. Llewellyn. March 2013. Base layer is Marin County's aerial photography.

EXPLANATION 19 Concentration of analyte above detection limit (mg/kg) 0 25 50 ! Sample Location with Concentration of analyte above detection limit (mg/kg) Soil Excavation Area Former Building Scale in Feet ¨ All samples taken from 1" below grade of excavation (6" below grade), for a total depth of 7" below ground surface.

Soil Sampling Analytical Results for Lead in Soil – Post Removal Action Assessment (Excavation) Plate Novato Unified School District Hamilton Air Force Base, Parcels 1A and 1B, Novato, California 5

Attachment B Lead and OCP Sampling Plan

TECHNICAL MEMORANDUM

Date: January 11, 2012 Prepared for: Neal Hutchison, DTSC Prepared by: Andy Rodgers, ECON On behalf of: Mark Silva, Novato Unified School District

Regarding: Lead and Organochlorine Pesticide Sampling Project: PBC Parcel 1, Former Department of Defense Housing Facility Novato, California ______

ECON is pleased to present this Technical Memorandum outlining the lead and organochlorine pesticide (OCP) sampling plan for PBC Parcels 1A and 1B (Parcels), Former Department of Defense Housing Facility, Novato, California. This Technical Memorandum is being prepared at the request of the State of California, Environmental Protection Agency, Department of Toxic Substances Control (DTSC) and will serve as a workplan, presenting information regarding the proposed sample locations, sample depths, Quality Assurance/Quality Control (QA/QC) samples, sample compositing, laboratory analysis, and reporting.

1.0 Purpose of Sampling

The purpose of the sampling is to evaluate the potential for soil contamination of the Parcels by lead and OCPs and, if concentrations are detected, determine if the levels pose a threat to human health. The sampling is required by DTSC after the Novato Unified School District (NUSD) received both parcels from the United States Department of the Navy by way of a public benefit conversion through the United States Department of Education. DTSC requires this sampling, along with sampling for polychlorinated biphenyls (PCBs), to initially evaluate proposed school sites where lead from lead-based paint, OCPs from termiticide application, and PCBs from electrical transformers are potential sources of soil contamination. Due to a previous assessment completed by the Navy on the subject parcels, DTSC is not requiring NUSD to sample for PCBs.

2.0 Proposed Sample Locations

The sample locations for both lead and OCPs were identified, based on the DTSC guidelines (DTSC, Interim Guidance Evaluation Of School Sites With Potential Soil Contamination As A Result Of Lead From Lead-Based Paint, Organochlorine Pesticides From Termiticides, And Polychlorinated Biphenyls From Electrical Transformers, Revised 06/09/06) and subsequent correspondence and input from Mr. Neal Hutchison, DTSC. Sample locations are shown on the attached Plate 1.

241 South Main Street, Sebastopol, California 95472 -- Tel 707-823-2324 -- Fax 707-921-7409

Technical Memorandum January 11, 2012 PBC Parcels 1A and 1B, Novato, California

The number of samples to be collected for each building is based on the size of the existing or former building footprints and on the accessibility of exposed soil or degraded surface asphalt for sampling within approximately 10 feet of the building’s footprint. Where possible, samples will be collected within 2 feet of the building; however, asphalt pavement surrounds many of the buildings, causing some proposed sample locations to be moved outward from the buildings. For larger buildings, up to three samples will be collected from each side, depending on whether the building is closer to square or to rectangular in shape. For square large buildings, up to two samples will be collected on each side, for a total of up to eight samples per building. For rectangular large buildings, up to one sample will be collected from each short side and up to two from each long side, for a total of up to six samples per building. For smaller buildings, up to one sample will be collected from each side, for a total of up to four samples per building. For shed- sized buildings, up to two samples will be collected in total.

Although DTSC does not require sampling beneath asphalt pavement, sample locations designated on Plate 1 with a triangle will be collected beneath asphalt pavement for due diligence purposes for potential future construction on the Parcel. The samples will be collected in areas in which the asphalt is depressed or degraded (for ease of drilling through the asphalt) and within 10 feet of the building or former building footprint.

Sample locations will be noted on a map. In addition, the locations from which post- demolition samples are collected will be staked.

3.0 Sample Collection and Depths

Discrete soil samples for both lead and OCPs will be collected at a depth of 0 to 6 inches below ground surface (bgs) and samples for OCPs will additionally be collected from between 2 and 3 feet bgs at each sample location. Samples will be collected in brass sample sleeves by hand slide hammer or with a drill rig 140 pound hammer. The top of the shallow (0 to 6 inches bgs) cores will be labeled in the field for use by the laboratory during analysis for lead. Samples will be labeled according to the attached sample identification table. Soil samples will be collected as described in the sampling and analysis protocol provided as Attachment A to this document.

4.0 Quality Assurance/Quality Control Samples

QA/QC samples will be collected as follows: duplicate samples – approximately 5% of the total number of discrete samples; water used for rinseate and rinseate blanks – one each.

5.0 Laboratory Sample Compositing and Analysis

Soil samples will be submitted for quantitative analysis as described in the sampling and analysis protocol in Attachment A. Samples for OCP will be composited by the

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Technical Memorandum January 11, 2012 PBC Parcels 1A and 1B, Novato, California

laboratory as follows: up to four adjacent samples from the same depth will be composited into one sample. The portion of each discrete sample that is not used in a composite will be placed on hold and used for analysis if OCPs are detected above the adjusted screening value for that composite sample. Screening values are adjusted by dividing the screening value by the number of discrete samples used for a composite.

Lead analysis will be conducted on the uppermost soil (closest to ground surface) from each shallow soil core. Lead samples will be analyzed in the laboratory for total lead by EPA method 6010/6020. OCP analysis will be by EPA method 8081.

6.0 Reporting

The results of the soil sampling will be presented in a summary report prepared after all the data has been collected and reviewed. The report will include a comparison of the detected COCs (if any) to the screening values for lead and OCPs, which are the California Human Health Screening Levels (CHHSLs) for soil for residential land use. The type of report (Preliminary Endangerment Assessment or Phase I) will be determined based on the sampling results.

7.0 Limitations

This sampling is only intended to evaluate the site for potential human health concerns associated with direct exposure of humans to the specific contaminants (lead and OCPs) in soil through incidental soil ingestion, dermal contact, and inhalation of dust in outdoor air. The screening values contained herein do not consider impact to groundwater or address ecological concerns.

ECON has prepared this Technical Memorandum in a manner consistent with the standards of care and skill normally exercised by members of the profession practicing under similar conditions in the geographic vicinity and at the time the services will be performed. No warranty or guarantee expressed or implied is part of the services offered in this work plan.

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Technical Memorandum January 11, 2012 PBC Parcels 1A and 1B, Novato, California

ECON is pleased to prepare this Technical Memorandum. If you need further information or have any questions please feel free to call Martha Murphy or me at (707) 823-2324.

Sincerely, ECON

Andrew S. Rodgers, CHMM, REA, CPESC Project Manager

Attachments: Attachment A – Soil Sampling and Analysis Protocol Plate 1 – Site Sampling Plan

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Technical Memorandum January 11, 2012 PBC Parcels 1A and 1B, Novato, California

ATTACHMENT A SOIL SAMPLING AND ANALYSIS PROTOCOL

A-1 Soil Sampling Protocol

The following describes soil sampling procedures used by ECON field personnel to collect soil samples.

Before samples are collected, careful consideration is given to the type of analysis to be performed so that precautions are taken to prevent loss of volatile components or contamination of the sample, and to preserve the sample for subsequent analysis. All sampling equipment is cleaned between sampling locations to prevent cross-contamination. The sample equipment is washed with an EPA approved detergent (such as liquinox or trisodium phosphate) or steam cleaned between sample collections.

Based on site information, appropriate Personal Protective Equipment (PPE) is selected and donned. Samples are collected using 1.5-, 2- or 2.5-inch I.D. x 4- or 6-inch long steamed-cleaned or new stainless steel or brass sleeves. The auger, shovel or lead sample tube is placed on the desired location. The sampler is then extracted from the borehole and the sample sleeve is carefully removed and immediately prepared for storage and possible analysis.

The soil material is immediately trimmed flush with the sleeve ends and sealed with Teflon tape beneath polyethylene end caps. Duct tape is not used to seal the end caps onto the tube. The sample is then labeled to include the date, location number, depth of sample, and project name. The samples are put into a plastic “zip-lock” type bag and placed into an ice chest maintained below 4ºC with blue ice or dry ice, for transport under chain of custody to the laboratory. The chain-of-custody form includes the project number, analysis requested, sample ID, date, time, sample matrix and the field personnel’s name. The form is signed, dated and timed by each person who yields or receives the samples beginning with the field personnel and ending with the laboratory personnel.

Upon completion of soil sample collection, the boring is grouted with Portland Cement and 3 to 5% bentonite or bentonite hole plug.

A-2 Decontamination Procedures

Decontamination will be conducted using a four-step process on all field equipment to avoid cross contamination between samples and to ensure the health and safety of the field personnel. Decontamination water will be collected in an appropriate container and disposed of. The following sequence will be used to clean equipment and sampling devices prior to and between each use:

1. Rinse with potable water 2. Wash with Liquinox detergent and tap water and clean with a stiff-bristle brush 3. Rinse with deionized water or steam clean

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Technical Memorandum January 11, 2012 PBC Parcels 1A and 1B, Novato, California

4. Place the sampling equipment on a clean surface to air dry.

Investigation Derived Wastes (IDW) produced during the site investigation activities will likely include minor amounts of soil cuttings and equipment decontamination water. IDW will be drummed and stored on site pending analytical results, then disposed of appropriately based on those results.

A-3 Laboratory Analysis

Samples will be labeled and chilled, and transported under chain of custody to a California certified laboratory where they will be analyzed in accordance with the following table:

Laboratory Analytical Methods for Soil

Analytical Parameter EPA Analytical Method Quantitation Limit Total Lead 6010/6020 50 mg/kg or ppm Organochlorine Pesticides 8081 Per CA DTSC 2006 Lead, OCPs and PCBS School Interim Guidance

Samples to be analyzed for OCPs will be composited at a rate of no more than four sample sleeves per composite. The portion of each discrete sample that is not used in a composite will be placed on hold for potential further analysis. Lead analysis will be conducted on the uppermost soil (closest to ground surface) from each shallow soil core and lead samples will not be composited.

Page 6 of 6

!( !( EB-20 EB-19

971 EB-18 !(

!( EB-21

EB-17 !( !( EB-22

EB-16 !( !( EB-15 954 EB-14 !(

960 !( EB-13 EB-12 !( *# EB-23 !( EB-11 955 EB-10 !( !( EB-9 EB-1 EB-2 EB-3 EB-4 !( *# 965 !( !( !( EB-24 *# EB-30 928 EB-30 !( !( !( !( EB-8 EB-7 EB-6 EB-5 957 969 EB-29 *# *# 958 EB-25 EB-26 *# EB-27 *# EB-28 930 *# 972

973

EXPLANATION

Approximate post-demolition sample grid based on field reconnaissance 0 50 100 and historic maps with former building locations Proposed Boring Locations Scale in Feet Surface Condition ¨ *# Asphalt Depression

!( Exposed Soil

Site Sampling Plan Plate Novato Unified School District Hamilton Air Force Base, Parcel 1, Novato, California 1

Attachment C Tables and Laboratory Analytical Reports

Table 1: Analytical Results for Lead/OCP in Soil - Initial Assessment Preliminary Endangerment Assessment Parcels 1A & 1B, Hamilton Air Force Base Novato, California

Sample ID Sample DateOCPs Total Lead EB-1S Pb/OCP 1/11/2012 NA 51 EB-2S Pb/OCP 1/11/2012 NA 18 EB-2B OCP-Dup 1/12/2012 ND<0.001 - 0.05 NA EB-3S Pb/OCP 1/11/2012 NA 21 EB-4S Pb/OCP 1/11/2012 NA 20 Comp EB(1S, 2S, 3S, 4S) 1/11/2012 ND<0.002 - 0.101 NA Comp EB(1B, 2B, 3B, 4B) 1/11/2012 ND<0.001 - 0.05 NA EB-5S Pb/OCP 1/11/2012 NA 23 EB-6S Pb/OCP 1/11/2012 NA 32 EB-7S Pb/OCP 1/11/2012 NA 15 EB-8S Pb/OCP 1/11/2012 NA 19 EB-8S Pb-Dup 1/13/2012 ND<0.10 - 5.01 30 Comp EB(5S, 6S, 7S, 8S) 1/11/2012 0.0122 NA Comp EB(5B, 6B, 7B, 8B) 1/11/2012 ND<0.001 - 0.05 NA EB-9S Pb/OCP 1/11/2012 NA 49.88 EB-10S Pb/OCP 1/11/2012 NA 88 EB-11S Pb/OCP 1/11/2012 NA 35 EB-11B OCP-Dup 1/11/2012 ND<0.005 - 0.251 NA EB-12S Pb/OCP 1/11/2012 NA 12 Comp EB(9S, 10S, 11S, 12S) 1/11/2012 ND<0.20 - 101 NA Comp EB(9B, 10B, 11B, 12B) 1/11/2012 ND<0.050 - 2.51 NA EB-13S Pb/OCP 1/11/2012 NA 14 EB-14S Pb/OCP 1/11/2012 NA 41 EB-15S Pb/OCP 1/11/2012 NA 39 EB-16S Pb/OCP 1/11/2012 NA 62 Comp EB(13S, 14S, 15S, 16S) 1/11/2012 ND<0.20 - 101 NA Comp EB(13B, 14B, 15B, 16B) 1/11/2012 ND<0.050 - 2.51 NA EB-17S Pb/OCP5 1/12/2012 ND<0.1 - 5.01 11 EB-18S Pb/OCP5 1/12/2012 ND<0.20 - 101 180 EB-19S Pb/OCP5 1/12/2012 0.017 - 0.582 9.4 EB-20S Pb/OCP5 1/12/2012 0.0132 14 EB-20B OCP-Dup 1/12/2012 ND<0.5 - 121 NA Comp EB(17S, 18S, 19S, 20S) 1/12/2012 0.020 - 0.0402 NA Comp EB(17B, 18B, 19B, 20B) 1/12/2012 0.024 - 0.382 NA EB-21S Pb/OCP 1/12/2012 NA 8.7 EB-22S Pb/OCP 1/12/2012 NA 15 EB-22S Pb-Dup 1/13/2012 ND<0.1 - 5.01 21 Comp EB(21S, 22S) 1/12/2012 0.033 - 0.122 NA Comp EB(21B, 22B) 1/12/2012 ND<0.1 - 5.01 NA EB-23S Pb/OCP 1/12/2012 NA 11 EB-23B OCP-Dup 1/12/2012 ND<0.001 - 0.05 NA Comp EB(23S, 33S) 1/12/2012 ND<0.1 - 5.01 NA Comp EB(23B, 33B) 1/12/2012 ND<0.001 - 0.05 NA EB-24S Pb/OCP 1/12/2012 NA 76 Comp EB(24S, 34S, 35S) 1/12/2012 ND<0.050 - 2.51 NA ESLs: x3 804 Table 1: Analytical Results for Lead/OCP in Soil - Initial Assessment (Continued) Preliminary Endangerment Assessment Parcels 1A & 1B, Hamilton Air Force Base Novato, California

Sample ID Date OCPs Total LeadSample Comp EB(24B, 34B, 35B) 1/12/2012 ND<0.010 - 0.51 NA EB-25S Pb/OCP 1/12/2012 NA 46 EB-25S Pb-Dup 1/12/2012 ND<0.5 - 121 240 Comp EB(25S, 36S) 1/12/2012 ND<0.1 - 5.01 NA Comp EB(25B, 36B) 1/12/2012 ND<0.020 - 1.01 NA EB-26S Pb/OCP 1/13/2012 ND<2.0 - 1001 750 EB-26B OCP 1/13/2012 ND<0.001 - 0.05 NA EB-27S Pb/OCP 1/13/2012 ND<0.1 - 5.01 15 EB-27B OCP 1/13/2012 ND<0.001 - 0.05 NA EB-28S Pb/OCP 1/13/2012 NA 130 Comp EB(28S, 37S) 1/13/2012 ND<1.0 - 501 NA Comp EB(28B, 37B) 1/13/2012 ND<0.001 - 0.05 NA EB-29S Pb/OCP 1/13/2012 ND<1.0 - 501 130 EB-29B OCP 1/13/2012 ND<0.001 - 0.05 NA EB-30S Pb/OCP 1/13/2012 ND<1.0 - 501 ND<5.0 EB-30B OCP 1/13/2012 ND<0.1 - 5.01 NA EB-31S Pb 1/12/2012 NA 38 EB-32S Pb/OCP 1/12/2012 NA 32 Comp EB(31S, 32S) 1/12/2012 ND<1 - 501 NA EB-33S Pb/OCP 1/12/2012 NA 34 EB-34S Pb/OCP 1/12/2012 NA 8.8 EB-35S Pb/OCP 1/12/2012 NA 8.9 EB-36S Pb/OCP 1/12/2012 NA 13 EB-37S Pb/OCP 1/13/2012 NA 75 EB-38S Pb/OCP 1/13/2012 ND<0.1 - 5.01 290 EB-38B OCP 1/13/2012 ND<0.001 - 0.05 NA 35-969-01S 1/31/2013 NA 8.9 35-Shed-02S 1/31/2013 NA 990 35-Shed-03S 1/31/2013 NA 420 35-Shed-04S 1/31/2013 NA 2,600 35-972-05S 1/31/2013 NA 16 35-972-06S 1/31/2013 NA 2,400 ESLs: x3 804 All results reported in mg/kg unless otherwise stated. Concentrations of analytes at or above ESL are in bold.

1: Sample diluted due to high organic content. 2: See Table 2 for CHHSLs of each OCP compound that is detected at a concentration that is above the reporting limit. 3: The ESLs being used for OCPs are Residential Land Use CHHSLs. Residential Land Use screening levels generally considered appropriate for other sensitive uses (e.g., day-care centers, hospitals, etc). California Human Health Screening Levels (CHHSLs) in Evaluation of Contaminated Properties - Jan. 2005. 4: The ESL value is derived from the Lead Soil Screening Levels and Cleanup at California Hazardous Waste Sites (2009) - Department of

Footnotes Toxic Substances Control (DTSC), CalRPA, Sacramento, CA, USA; Office of Environmental Health Hazard Assessment (OEHHA), CalEPA, Sacramento CA, USA. 5: Discrete samples analyzed for OCPs out of hold time.

mg/kg: milligrams per kilogram ND: Analyte NOT DETECTED at or above laboratory reporting limits NA: Not Analyzed CHHSLs: California Human Health Screening Levels OCPs: Organochlorine Pesticides Abbreviations ESLs: Environmental Screening Levels Table 2: Analytical Results for Specific OCP Compounds in Soil - Initial Assessment Preliminary Endangerment Assessment Parcels 1A & 1B, Hamilton Air Force Base Novato, California OCPs1 Sample ID Sample Date Chlordane (Technical) a-Chlordane g-Chlordane p,p-DDE p,p-DDT Dieldrin Heptachlor epoxide Comp EB(5S, 6S, 7S, 8S)14 1/11/12 ND<0.25 ND<0.010 ND<0.010 0.012 ND<0.010 ND<0.010 ND<0.010 EB-19S Pb/OCP5 1/12/12 0.55 0.089 0.58 ND<0.010 ND<0.010 ND<0.010 0.017 EB-20S Pb/OCP5 1/12/12 ND<0.25 0.013 ND<0.010 ND<0.010 ND<0.010 ND<0.010 ND<0.010 Comp EB(17S, 18S, 19S, 20S)14 1/12/12 ND<0.25 0.036 0.02 0.04 ND<0.010 0.0354 ND<0.010 Comp EB(17B, 18B, 19B, 20B)14 1/12/12 0.38 0.053 0.033 0.062 0.024 ND<0.0050 ND<0.0050 Comp EB(21S, 22S)13 1/12/12 ND<0.25 0.12 0.011 0.033 0.013 ND<0.010 ND<0.010 CHHSL 9: 0.43 11 0.43 11 0.43 11 1.6 1.6 0.035 0.13 12 CHHSL 9 - 2-Point Composite 10: 0.215 11 0.215 11 0.215 11 0.8 0.8 0.0175 0.065 CHHSL 9 - 4-Point Composite 10: 0.1075 11 0.1075 11 0.1075 11 0.4 0.4 0.00875 0.0325 6 3 3 3 6

2 Ingestion (TR ): 1.8 1.8 1.8 1.9 1.9 0.04 0.07 Dermal (TR6): 143 143 143 5.9 20 0.13 0.22 Inhalation (TR6): 33,0003 33,0003 33,0003 34,000 34,000 720 130 6 3 3 3 Carcinogenic Carcinogenic (TR ): 1.6 1.6 1.6 1.4 1.7 0.03 0.053 8 3 3 3

7 Ingestion (HQ ): 39 39 39 - 39 3.9 1.0 r r Dermal (HQ8) 3503 3503 3503 - 470 14 3.6 Inhalation (HQ8) 990,0003 990,0003 990,0003 ---- Regional Screening Levels Levels Screening Regional Noncance Noncarcinogenic (HI7) 353 353 353 - 36 3.1 0.79 All results reported in mg/kg unless otherwise stated. Concentrations of analytes at or above Regional Screening Levels are in bold. Concentrations of analytes at or above CHHSL are highlighted in grey.

1: For a full list of specific Organochlorine Pesticide compounds that are below the reporting limit (ND) see lab reports. 2: USEPA Pacific Southwest, Region 9, Regional Screening Levels (Formerly PRGs) for Chemical Contaminants, November 2012. mg/kg: milligrams per kilogram

3: Lab reports indicate OCP compounds as Chlordane (Technical), a-Chlordane, and g-Chlordane; however the Regional Screening ND: Not Detected Levels represent the OCP compound as strictly "Chlordane". OCPs: Organochlorine Pesticides 4: While the concentration of 0.035 mg/kg of Dieldrin for sample Comp EB (17S, 18S, 19S, 20S) does exceed the Regional Screen Level TR: Target Risk of 0.03 mg/kg for Carcinogenic SL, the screening value is divided by the number of discrete samples in a composited sample; therefore, HI: Hazard Index

the screening level for this 4-point composite sample is actually 0.0075 mg/kg (0.03/4) and the sample in fact does NOT exceed the Carcinogen SL.Abbreviations HQ: Hazard Quotient 5: Discrete samples analyzed for OCPs out of hold time. SL: Screening Level 6: TR is 0.000001 mg/kg. 7: HI is 1.0 mg/kg. 8 Footnotes : HQ is 1.0 mg/kg. 9: California Human Health Screening Levels (CHHLs) in Evaluation of Contaminated Properties - Jan. 2005. The CHHSLs being used are Residential Land Use. Residential Land Use screening levels generally considered appropriate for other sensitive uses (e.g., day-care centers, hospitals, etc.). 10: Screening value is divided by the number of discrete samples in a composited sample. 11: Lab reports indicate OCP compound as Chlordane (Technical), a-Chlordane, and g-Chlordane, and the CHHLs represent the OCP compound as Chlordane. 12: Lab reports indicate OCP compound as Heptachlor epoxide and the CHHLs represent the OCP compound as Heptachlor. 13: 2-Point Composite Sample. 14: 4-Point Composite Sample. Table 3: Analytical Results for Quality Control Water Samples - Initial Assessment Preliminary Endangerment Assessment Parcels 1A & 1B, Hamilton Air Force Base Novato, California

Sample ID Sample Date OCPs Total Lead Rinse1 1/13/12 ND<0.050 - 5.03 49 Rinse Blank2 1/13/12 ND<0.005 - 1.0 ND<0.5

All results reported in µg/L unless otherwise stated.

1: Rinse is rinsate collected as runnoff from augers during cleaning. 2: Rinse Blank is rinse water prior to use for cleaning augers. 3: Sample diluted due to high organic content. Footnotes

µg/L : micrograms per liter ND: Analyte NOT DETECTED at or above laboratory reporting limits OCPs: Organochlorine Pesticides Abbreviations Table 4: Analytical Results for Lead in Soil - Step Out/Step Down Assessment Preliminary Endangerment Assessment Parcels 1A & 1B, Hamilton Air Force Base Novato, California

Sample ID Sample Date Total Lead EB-39-0 5/4/2012 7.4 EB-39-12 5/4/2012 7.4 EB-38-12 5/4/2012 12 EB-40-3 5/4/2012 15 EB-40-12 5/4/2012 7.3 EB-41-3 5/4/2012 8.6 EB-41-12 5/4/2012 6.5 EB-42-3 5/4/2012 17 EB-42-12 5/4/2012 7.9 EB-43-3 5/4/2012 8.4 EB-43-12 5/4/2012 18 EB-44-0 5/4/2012 250 EB-44-12 5/4/2012 5.9 EB-45-0 5/4/2012 360 EB-45-12 5/4/2012 72 EB-46-0 5/4/2012 240 EB-46-12 5/4/2012 6.9 EB-47-0 5/4/2012 54 EB-47-12 5/4/2012 6.8 EB-26-12 5/4/2012 9.1 EB-48-0 5/4/2012 25 EB-48-12 5/4/2012 6.2 EB-49-0 5/4/2012 70 EB-49-12 5/4/2012 11 EB-50-0 5/4/2012 9.7 EB-50-12 5/4/2012 7.4 EB-51-0 5/4/2012 270 EB-51-12 5/4/2012 9.7 EB-25-12 5/4/2012 10 EB-52-0 5/4/2012 11 EB-52-12 5/4/2012 7.2 ESLs: 801

All results reported in mg/kg unless otherwise stated. Concentrations of analytes at or above ESL are in bold.

1: The ESL value is derived from the Lead Soil Screening Levels and Cleanup at California Hazardous Waste Sites (2009) - Department of Toxic Substances Control (DTSC), CalRPA, Sacramento, CA, USA; Office of Environmental Health Hazard Assessment (OEHHA), CalEPA, Sacramento CA, USA. Footnotes

mg/kg: milligrams per kilogram ESLs: Environmental Screening Levels Abbreviations Table 5: Analytical Results for Lead in Soil - Post Removal Action Preliminary Endangerment Assessment Parcels 1A & 1B, Hamilton Air Force Base Novato, California

Sample ID Sample Date Total Lead 35-969-01S 2/14/2013 13 35-Shed-02S 2/14/2013 19 35-Shed-03S 2/14/2013 13 35-Shed-04S 2/14/2013 9.5 with Previous Area Excavated Area

Lead Contamination Lead 35-972-05S 2/14/2013 19 35-972-06S 2/14/2013 17 EB-10S Pb/OCP 1/11/2012 88 EB-18S Pb/OCP 1/12/2012 180

with EB-28S Pb/OCP 1/13/2012 130 Area Not Excavated Excavated Not Area

Lead Contamination Lead EB-29S Pb/OCP 1/13/2012 130 ESLs: 801

All results reported in mg/kg unless otherwise stated. Concentrations of analytes at or above ESL are in bold.

mg/kg: milligrams per kilogram ESLs: Environmental Screening Levels Abbreviations

ECON Client Project ID: NUSD; Pb/OCP Sampling Date Sampled: 01/11/12

Date Received: 01/12/12 241 South Main Street Client Contact: Andy Rodgers Date Reported: 01/18/12

Sebastopol, CA 95472 Client P.O.: Date Completed: 01/18/12

WorkOrder: 1201266

January 18, 2012

Dear Andy:

Enclosed within are:

1) The results of the 20 analyzed samples from your project: NUSD; Pb/OCP Sampling, 2) QC data for the above samples, and 3) A copy of the chain of custody.

All analyses were completed satisfactorily and all QC samples were found to be within our control limits. If you have any questions or concerns, please feel free to give me a call. Thank you for choosing McCampbell Analytical Laboratories for your analytical needs.

Best regards,

Angela Rydelius Laboratory Manager McCampbell Analytical, Inc.

The analytical results relate only to the items tested.

Page 1 of 15

Page 2 of 15 Page 3 of 15 Page 4 of 15 Page 5 of 15

McCampbell Analytical, Inc. Page 1 of 2 1534 Willow Pass Rd CHAIN-OF-CUSTODY RECORD Pittsburg, CA 94565-1701 (925) 252-9262 WorkOrder: 1201266 ClientCode: ECON WaterTrax WriteOn EDF Excel Fax Email HardCopy ThirdParty J-flag

Report to: Bill to: Requested TAT: 5 days Andy Rodgers Email: [email protected]; [email protected] Andy Rodgers ECON cc: ECON 241 South Main Street PO: 241 South Main Street Date Received: 01/12/2012 Sebastopol, CA 95472 ProjectNo: NUSD; Pb/OCP Sampling Sebastopol, CA 95472 Date Printed: 01/12/2012 (707) 789-0262 FAX: 707-823-8725

Requested Tests (See legend below) Lab ID Client ID Matrix Collection Date Hold 1 2 3 4 5 6 7 8 9 10 11 12

1201266-001 Comp EB(1S,2S,3S,4S) Soil 1/11/2012 B 1201266-001 EB-1S Pb/OCP Soil 1/11/2012 A 1201266-002 Comp EB(1B,2B,3B,4B) Soil 1/11/2012 B 1201266-003 EB-2S Pb/OCP Soil 1/11/2012 A 1201266-005 EB-3S Pb/OCP Soil 1/11/2012 A 1201266-007 EB-4S Pb/OCP Soil 1/11/2012 A 1201266-009 Comp EB(5S,6S,7S,8S) Soil 1/11/2012 B 1201266-009 EB-5S Pb/OCP Soil 1/11/2012 A 1201266-010 Comp EB(5B,6B,7B,8B) Soil 1/11/2012 B 1201266-011 EB-6S Pb/OCP Soil 1/11/2012 A 1201266-013 EB-7S Pb/OCP Soil 1/11/2012 A 1201266-015 EB-8S Pb/OCP Soil 1/11/2012 A 1201266-017 Comp EB(9S,10S,11S,12S) Soil 1/11/2012 B 1201266-017 EB-9S Pb/OCP Soil 1/11/2012 A

Test Legend:

1 8081_S 2 PB_S 3 4 5 6 7 8 9 10 11 12

Prepared by: Ana Venegas

Comments: All discrete samples for 8081 placed on hold 1/12/12 per Y.S

NOTE: Soil samples are discarded 60 days after results are reported unless other arrangements are made (Water samples are 30 days). Hazardous samples will be returned to client or disposed of at client expense.

Page 6 of 15 McCampbell Analytical, Inc. Page 2 of 2 1534 Willow Pass Rd CHAIN-OF-CUSTODY RECORD Pittsburg, CA 94565-1701 (925) 252-9262 WorkOrder: 1201266 ClientCode: ECON WaterTrax WriteOn EDF Excel Fax Email HardCopy ThirdParty J-flag

Requested Tests (See legend below) Lab ID Client ID Matrix Collection Date Hold 1 2 3 4 5 6 7 8 9 10 11 12

1201266-018 Comp EB(9B,10B,11B,12B) Soil 1/11/2012 B 1201266-019 EB-10S Pb/OCP Soil 1/11/2012 A 1201266-021 EB-11S Pb/OCP Soil 1/11/2012 A 1201266-023 EB-12S Pb/OCP Soil 1/11/2012 A 1201266-025 Comp EB(13S,14S,15S,16S) Soil 1/11/2012 B 1201266-025 EB-13S Pb/OCP Soil 1/11/2012 A 1201266-026 Comp EB(13B,14B,15B,16B) Soil 1/11/2012 B 1201266-027 EB-14S Pb/OCP Soil 1/11/2012 A 1201266-029 EB-15S Pb/OCP Soil 1/11/2012 A 1201266-031 EB-16S Pb/OCP Soil 1/11/2012 A

Test Legend:

1 8081_S 2 PB_S 3 4 5 6 7 8 9 10 11 12

Prepared by: Ana Venegas

Comments: All discrete samples for 8081 placed on hold 1/12/12 per Y.S

Page 7 of 15

Sample Receipt Checklist

Client Name: ECON Date and Time Received: 1/12/2012 3:48:53 PM

Project Name: NUSD; Pb/OCP Sampling Checklist completed and reviewed by: Ana Venegas

WorkOrder N°: 1201266 Matrix: Soil Carrier: Benjamin Yslas (MAI Courier)

Chain of Custody (COC) Information

Chain of custody present? Yes No

Chain of custody signed when relinquished and received? Yes No

Chain of custody agrees with sample labels? Yes No

Sample IDs noted by Client on COC? Yes No

Date and Time of collection noted by Client on COC? Yes No

Sampler's name noted on COC? Yes No

Sample Receipt Information

Custody seals intact on shipping container/cooler? Yes No NA

Shipping container/cooler in good condition? Yes No

Samples in proper containers/bottles? Yes No

Sample containers intact? Yes No

Sufficient sample volume for indicated test? Yes No

Sample Preservation and Hold Time (HT) Information

All samples received within holding time? Yes No

Container/Temp Blank temperature Cooler Temp: 4.2°C NA

Water - VOA vials have zero headspace / no bubbles? Yes No No VOA vials submitted

Sample labels checked for correct preservation? Yes No

Metal - pH acceptable upon receipt (pH<2)? Yes No NA

Samples Received on Ice? Yes No (Ice Type: WET ICE )

* NOTE: If the "No" box is checked, see comments below.

Comments:

Page 8 of 15 1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected] ECON Client Project ID: NUSD; Pb/OCP Date Sampled: 01/11/12 Sampling Date Received: 01/12/12 241 South Main Street Client Contact: Andy Rodgers Date Extracted: 01/12/12 Sebastopol, CA 95472 Client P.O.: Date Analyzed: 01/13/12 Organochlorine Pesticides by GC-ECD (8080 Basic Target List)* Extraction Method: SW3550B Analytical Method: SW8081A Work Order: 1201266 Lab ID 1201266-001B 1201266-002B 1201266-009B 1201266-010B Reporting Limit for Client ID Comp Comp Comp Comp DF =1 EB(1S,2S,3S,4S) EB(1B,2B,3B,4B) EB(5S,6S,7S,8S) EB(5B,6B,7B,8B) Matrix S S S S S W DF 2 1 10 1 Compound Concentration mg/kg µg/L Aldrin ND<0.0020 ND ND<0.010 ND 0.001 NA a-BHC ND<0.0020 ND ND<0.010 ND 0.001 NA b-BHC ND<0.0020 ND ND<0.010 ND 0.001 NA d-BHC ND<0.0020 ND ND<0.010 ND 0.001 NA g-BHC ND<0.0020 ND ND<0.010 ND 0.001 NA Chlordane (Technical) ND<0.050 ND ND<0.25 ND 0.025 NA a-Chlordane ND<0.0020 ND ND<0.010 ND 0.001 NA g-Chlordane ND<0.0020 ND ND<0.010 ND 0.001 NA p,p-DDD ND<0.0020 ND ND<0.010 ND 0.001 NA p,p-DDE ND<0.0020 ND 0.012 ND 0.001 NA p,p-DDT ND<0.0020 ND ND<0.010 ND 0.001 NA Dieldrin ND<0.0020 ND ND<0.010 ND 0.001 NA Endosulfan I ND<0.0020 ND ND<0.010 ND 0.001 NA Endosulfan II ND<0.0020 ND ND<0.010 ND 0.001 NA Endosulfan sulfate ND<0.0020 ND ND<0.010 ND 0.001 NA Endrin ND<0.0020 ND ND<0.010 ND 0.001 NA Endrin aldehyde ND<0.0020 ND ND<0.010 ND 0.001 NA Endrin ketone ND<0.0020 ND ND<0.010 ND 0.001 NA Heptachlor ND<0.0020 ND ND<0.010 ND 0.001 NA Heptachlor epoxide ND<0.0020 ND ND<0.010 ND 0.001 NA Hexachlorobenzene ND<0.020 ND ND<0.10 ND 0.01 NA Hexachlorocyclopentadiene ND<0.040 ND ND<0.20 ND 0.02 NA Methoxychlor ND<0.0020 ND ND<0.010 ND 0.001 NA Toxaphene ND<0.10 ND ND<0.50 ND 0.05 NA Surrogate Recoveries (%) %SS: 90 85 107 99 Comments a3 * water samples in µg/L, soil/sludge/solid samples in mg/kg, wipe samples in µg/wipe, filter samples in µg/filter, product/oil/non-aqueous liquid samples and all TCLP & SPLP extracts are reported in mg/L.

ND means not detected above the reporting limit/method detection limit; N/A means analyte not applicable to this analysis; %SS = Percent Recovery of Surrogate Standard; DF = Dilution Factor.

# surrogate diluted out of range or surrogate coelutes with another peak/sample contains surrogate. a3) sample diluted due to high organic content.

DHS ELAP Certification 1644 Angela Rydelius, Lab Manager Page 9 of 15 1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected] ECON Client Project ID: NUSD; Pb/OCP Date Sampled: 01/11/12 Sampling Date Received: 01/12/12 241 South Main Street Client Contact: Andy Rodgers Date Extracted: 01/12/12 Sebastopol, CA 95472 Client P.O.: Date Analyzed: 01/13/12 Organochlorine Pesticides by GC-ECD (8080 Basic Target List)* Extraction Method: SW3550B Analytical Method: SW8081A Work Order: 1201266 Lab ID 1201266-017B 1201266-018B 1201266-025B 1201266-026B Reporting Limit for Client ID Comp Comp Comp Comp DF =1 EB(9S,10S,11S,12S EB(9B,10B,11B,12 EB(13S,14S,15S,16 EB(13B,14B,15B,1 Matrix S S S S S W DF 200 50 200 50 Compound Concentration mg/kg µg/L Aldrin ND<0.20 ND<0.050 ND<0.20 ND<0.050 0.001 NA a-BHC ND<0.20 ND<0.050 ND<0.20 ND<0.050 0.001 NA b-BHC ND<0.20 ND<0.050 ND<0.20 ND<0.050 0.001 NA d-BHC ND<0.20 ND<0.050 ND<0.20 ND<0.050 0.001 NA g-BHC ND<0.20 ND<0.050 ND<0.20 ND<0.050 0.001 NA Chlordane (Technical) ND<5.0 ND<1.2 ND<5.0 ND<1.2 0.025 NA a-Chlordane ND<0.20 ND<0.050 ND<0.20 ND<0.050 0.001 NA g-Chlordane ND<0.20 ND<0.050 ND<0.20 ND<0.050 0.001 NA p,p-DDD ND<0.20 ND<0.050 ND<0.20 ND<0.050 0.001 NA p,p-DDE ND<0.20 ND<0.050 ND<0.20 ND<0.050 0.001 NA p,p-DDT ND<0.20 ND<0.050 ND<0.20 ND<0.050 0.001 NA Dieldrin ND<0.20 ND<0.050 ND<0.20 ND<0.050 0.001 NA Endosulfan I ND<0.20 ND<0.050 ND<0.20 ND<0.050 0.001 NA Endosulfan II ND<0.20 ND<0.050 ND<0.20 ND<0.050 0.001 NA Endosulfan sulfate ND<0.20 ND<0.050 ND<0.20 ND<0.050 0.001 NA Endrin ND<0.20 ND<0.050 ND<0.20 ND<0.050 0.001 NA Endrin aldehyde ND<0.20 ND<0.050 ND<0.20 ND<0.050 0.001 NA Endrin ketone ND<0.20 ND<0.050 ND<0.20 ND<0.050 0.001 NA Heptachlor ND<0.20 ND<0.050 ND<0.20 ND<0.050 0.001 NA Heptachlor epoxide ND<0.20 ND<0.050 ND<0.20 ND<0.050 0.001 NA Hexachlorobenzene ND<2.0 ND<0.50 ND<2.0 ND<0.50 0.01 NA Hexachlorocyclopentadiene ND<4.0 ND<1.0 ND<4.0 ND<1.0 0.02 NA Methoxychlor ND<0.20 ND<0.050 ND<0.20 ND<0.050 0.001 NA Toxaphene ND<10 ND<2.5 ND<10 ND<2.5 0.05 NA Surrogate Recoveries (%) %SS: ---# 103 118 111 Comments a3 a3 a3 a3 * water samples in µg/L, soil/sludge/solid samples in mg/kg, wipe samples in µg/wipe, filter samples in µg/filter, product/oil/non-aqueous liquid samples and all TCLP & SPLP extracts are reported in mg/L.

ND means not detected above the reporting limit/method detection limit; N/A means analyte not applicable to this analysis; %SS = Percent Recovery of Surrogate Standard; DF = Dilution Factor.

# surrogate diluted out of range or surrogate coelutes with another peak/sample contains surrogate. a3) sample diluted due to high organic content.

DHS ELAP Certification 1644 Angela Rydelius, Lab Manager Page 10 of 15

1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected] ECON Client Project ID: NUSD; Pb/OCP Date Sampled: 01/11/12 Sampling Date Received: 01/12/12 241 South Main Street Client Contact: Andy Rodgers Date Extracted: 01/12/12

Sebastopol, CA 95472 Client P.O.: Date Analyzed: 01/13/12

Lead by ICP* Extraction method: SW3050B Analytical methods: SW6010B Work Order: 1201266 Lab ID Client ID Matrix Extraction Type Lead DF % SS Comments

1201266-001A EB-1S Pb/OCP S TOTAL 51 1 109

1201266-003A EB-2S Pb/OCP S TOTAL 18 1 88

1201266-005A EB-3S Pb/OCP S TOTAL 21 1 103

1201266-007A EB-4S Pb/OCP S TOTAL 20 1 106

1201266-009A EB-5S Pb/OCP S TOTAL 23 1 112

1201266-011A EB-6S Pb/OCP S TOTAL 32 1 108

1201266-013A EB-7S Pb/OCP S TOTAL 15 1 106

1201266-015A EB-8S Pb/OCP S TOTAL 19 1 105

1201266-017A EB-9S Pb/OCP S TOTAL 49.88 1 99

1201266-019A EB-10S Pb/OCP S TOTAL 88 1 106

1201266-021A EB-11S Pb/OCP S TOTAL 35 1 107

1201266-023A EB-12S Pb/OCP S TOTAL 12 1 105

1201266-025A EB-13S Pb/OCP S TOTAL 14 1 76

1201266-027A EB-14S Pb/OCP S TOTAL 41 1 97

Reporting Limit for DF =1; W TOTAL NA µg/L ND means not detected at or above the reporting limit S TOTAL 5.0 mg/Kg *water samples are reported in µg/L, product/oil/non-aqueous liquid samples and all TCLP / STLC / DISTLC / SPLP extracts are reported in mg/L, soil/sludge/solid samples in mg/kg, wipe samples in µg/wipe, filter samples in µg/filter.

# means surrogate diluted out of range; ND means not detected above the reporting limit/method detection limit; N/A means not applicable to this sample or instrument.

TOTAL = Hot acid digestion of a representative sample aliquot. TRM = Total recoverable metals is the "direct analysis" of a sample aliquot taken from its acid-preserved container. DISS = Dissolved metals by direct analysis of 0.45 µm filtered and acidified sample.

%SS = Percent Recovery of Surrogate Standard DF = Dilution Factor

DHS ELAP Certification 1644 Angela Rydelius, Lab Manager

Page 11 of 15 1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected] ECON Client Project ID: NUSD; Pb/OCP Date Sampled: 01/11/12 Sampling Date Received: 01/12/12 241 South Main Street Client Contact: Andy Rodgers Date Extracted: 01/12/12

Sebastopol, CA 95472 Client P.O.: Date Analyzed: 01/13/12

Lead by ICP* Extraction method: SW3050B Analytical methods: SW6010B Work Order: 1201266 Lab ID Client ID Matrix Extraction Type Lead DF % SS Comments

1201266-029A EB-15S Pb/OCP S TOTAL 39 1 103

1201266-031A EB-16S Pb/OCP S TOTAL 62 1 105

# means surrogate diluted out of range; ND means not detected above the reporting limit/method detection limit; N/A means not applicable to this sample or instrument.

%SS = Percent Recovery of Surrogate Standard DF = Dilution Factor

DHS ELAP Certification 1644 Angela Rydelius, Lab Manager

Page 12 of 15 1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected]

QC SUMMARY REPORT FOR SW8081A

W.O. Sample Matrix: Soil QC Matrix: Soil BatchID: 64014 WorkOrder: 1201266

EPA Method: SW8081A Extraction: SW3550B Spiked Sample ID: 1201266-026B

Sample Spiked MS MSD MS-MSD LCS Acceptance Criteria (%) Analyte mg/kg mg/kg % Rec. % Rec. % RPD % Rec. MS / MSD RPD LCS

Aldrin ND<0.050 0.020 NR NR NR 109 70 - 130 30 70 - 130 g-BHC ND<0.050 0.020 NR NR NR 93.3 70 - 130 30 70 - 130 p,p-DDT ND<0.050 0.050 NR NR NR 87.4 70 - 130 30 70 - 130 Dieldrin ND<0.050 0.050 NR NR NR 105 70 - 130 30 70 - 130 Endrin ND<0.050 0.050 NR NR NR 107 70 - 130 30 70 - 130 Heptachlor ND<0.050 0.020 NR NR NR 107 70 - 130 30 70 - 130 %SS: 111 0.050 109 87 22.5 108 70 - 130 30 70 - 130 All target compounds in the Method Blank of this extraction batch were ND less than the method RL with the following exceptions: NONE

BATCH 64014 SUMMARY Lab ID Date Sampled Date Extracted Date Analyzed Lab ID Date Sampled Date Extracted Date Analyzed 1201266-001B 01/11/12 01/12/12 01/13/12 7:49 AM 1201266-002B 01/11/12 01/12/12 01/13/12 8:45 AM 1201266-009B 01/11/12 01/12/12 01/13/12 4:35 PM 1201266-010B 01/11/12 01/12/12 01/13/12 11:19 PM 1201266-017B 01/11/12 01/12/12 01/13/12 5:31 PM 1201266-018B 01/11/12 01/12/12 01/13/12 7:22 PM 1201266-025B 01/11/12 01/12/12 01/13/12 6:27 PM 1201266-026B 01/11/12 01/12/12 01/13/12 8:18 PM

MS = Matrix Spike; MSD = Matrix Spike Duplicate; LCS = Laboratory Control Sample; LCSD = Laboratory Control Sample Duplicate; RPD = Relative Percent Deviation.

% Recovery = 100 * (MS-Sample) / (Amount Spiked); RPD = 100 * (MS - MSD) / ((MS + MSD) / 2).

MS / MSD spike recoveries and / or %RPD may fall outside of laboratory acceptance criteria due to one or more of the following reasons: a) the sample is inhomogenous AND contains significant concentrations of analyte relative to the amount spiked, or b) the spiked sample's matrix interferes with the spike recovery.

# surrogate diluted out of range or surrogate coelutes with another peak

N/A = not enough sample to perform matrix spike and matrix spike duplicate.

NR = matrix inteference and/or analyte concentration in sample exceeds spike amount for soil matrix or exceeds 2x spike amount for water matrix or sample diluted due to high matrix or analyte content.

DHS ELAP Certification 1644 QA/QC Officer

Page 13 of 15 1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected]

QC SUMMARY REPORT FOR 6010B

W.O. Sample Matrix: Soil QC Matrix: Soil BatchID: 63912 WorkOrder: 1201266

EPA Method: SW6010B Extraction: SW3050B Spiked Sample ID: 1201188-002A

Sample Spiked MS MSD MS-MSD LCS Acceptance Criteria (%) Analyte mg/Kg mg/Kg % Rec. % Rec. % RPD % Rec. MS / MSD RPD LCS

Lead 6.8 50 121 121 0 116 75 - 125 25 75 - 125 %SS: 116 500 115 119 3.08 115 70 - 130 20 70 - 130 All target compounds in the Method Blank of this extraction batch were ND less than the method RL with the following exceptions: NONE

BATCH 63912 SUMMARY Lab ID Date Sampled Date Extracted Date Analyzed Lab ID Date Sampled Date Extracted Date Analyzed 1201266-001A 01/11/12 01/12/12 01/13/12 3:20 PM 1201266-003A 01/11/12 01/12/12 01/13/12 3:22 PM 1201266-005A 01/11/12 01/12/12 01/13/12 3:24 PM 1201266-007A 01/11/12 01/12/12 01/13/12 3:26 PM 1201266-009A 01/11/12 01/12/12 01/13/12 3:28 PM 1201266-011A 01/11/12 01/12/12 01/13/12 3:31 PM 1201266-013A 01/11/12 01/12/12 01/13/12 3:33 PM

MS = Matrix Spike; MSD = Matrix Spike Duplicate; LCS = Laboratory Control Sample; LCSD = Laboratory Control Sample Duplicate; RPD = Relative Percent Deviation.

% Recovery = 100 * (MS-Sample) / (Amount Spiked); RPD = 100 * (MS - MSD) / ((MS + MSD) / 2).

N/A = not applicable to this method.

NR = analyte concentration in sample exceeds spike amount for soil matrix or exceeds 2x spike amount for water matrix or sample diluted due to high matrix or analyte content.

DHS ELAP Certification 1644 QA/QC Officer

Page 14 of 15 1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected]

QC SUMMARY REPORT FOR 6010B

W.O. Sample Matrix: Soil QC Matrix: Soil BatchID: 64011 WorkOrder: 1201266

EPA Method: SW6010B Extraction: SW3050B Spiked Sample ID: 1201266-031A

Sample Spiked MS MSD MS-MSD LCS Acceptance Criteria (%) Analyte mg/Kg mg/Kg % Rec. % Rec. % RPD % Rec. MS / MSD RPD LCS

Lead 62 50 NR NR NR 96.6 75 - 125 25 75 - 125 %SS: 105 500 101 103 1.57 101 70 - 130 20 70 - 130 All target compounds in the Method Blank of this extraction batch were ND less than the method RL with the following exceptions: NONE

BATCH 64011 SUMMARY Lab ID Date Sampled Date Extracted Date Analyzed Lab ID Date Sampled Date Extracted Date Analyzed 1201266-015A 01/11/12 01/12/12 01/13/12 3:35 PM 1201266-017A 01/11/12 01/12/12 01/13/12 3:41 PM 1201266-019A 01/11/12 01/12/12 01/13/12 3:43 PM 1201266-021A 01/11/12 01/12/12 01/13/12 3:45 PM 1201266-023A 01/11/12 01/12/12 01/13/12 3:48 PM 1201266-025A 01/11/12 01/12/12 01/13/12 3:50 PM 1201266-027A 01/11/12 01/12/12 01/13/12 3:52 PM 1201266-029A 01/11/12 01/12/12 01/13/12 3:54 PM 1201266-031A 01/11/12 01/12/12 01/13/12 4:00 PM

MS = Matrix Spike; MSD = Matrix Spike Duplicate; LCS = Laboratory Control Sample; LCSD = Laboratory Control Sample Duplicate; RPD = Relative Percent Deviation.

% Recovery = 100 * (MS-Sample) / (Amount Spiked); RPD = 100 * (MS - MSD) / ((MS + MSD) / 2).

N/A = not applicable to this method.

NR = analyte concentration in sample exceeds spike amount for soil matrix or exceeds 2x spike amount for water matrix or sample diluted due to high matrix or analyte content.

DHS ELAP Certification 1644 QA/QC Officer

Page 15 of 15

ECON Client Project ID: NUSD; Pb/OCP Sampling Date Sampled: 01/12/12-01/13/12

Date Received: 01/13/12 241 South Main Street Client Contact: Andy Rodgers Date Reported: 01/20/12

Sebastopol, CA 95472 Client P.O.: Date Completed: 01/19/12

WorkOrder: 1201339

January 20, 2012

Dear Andy:

Enclosed within are:

1) The results of the 35 analyzed samples from your project: NUSD; Pb/OCP Sampling, 2) QC data for the above samples, and 3) A copy of the chain of custody.

Best regards,

Angela Rydelius Laboratory Manager McCampbell Analytical, Inc.

The analytical results relate only to the items tested.

Page 1 of 23

Page 2 of 23 Page 3 of 23 Page 4 of 23 Page 5 of 23 Page 6 of 23 Page 7 of 23

McCampbell Analytical, Inc. Page 1 of 3 1534 Willow Pass Rd CHAIN-OF-CUSTODY RECORD Pittsburg, CA 94565-1701 (925) 252-9262 WorkOrder: 1201339 ClientCode: ECON WaterTrax WriteOn EDF Excel Fax Email HardCopy ThirdParty J-flag

Report to: Bill to: Requested TAT: 5 days Andy Rodgers Email: [email protected]; [email protected] Andy Rodgers ECON cc: ECON 241 South Main Street PO: 241 South Main Street Date Received: 01/13/2012 Sebastopol, CA 95472 ProjectNo: NUSD; Pb/OCP Sampling Sebastopol, CA 95472 Date Printed: 01/17/2012 (707) 789-0262 FAX: 707-823-8725

Requested Tests (See legend below) Lab ID Client ID Matrix Collection Date Hold 1 2 3 4 5 6 7 8 9 10 11 12

1201339-001 Comp EB (17S, 18S, 19S, 20S) Soil 1/12/2012 B 1201339-001 EB-17S Pb/OCP Soil 1/12/2012 A 1201339-002 Comp EB (17B, 18B, 19B, 20B) Soil 1/12/2012 B 1201339-003 EB-18S Pb/OCP Soil 1/12/2012 A 1201339-005 EB-19S Pb/OCP Soil 1/12/2012 A 1201339-007 EB-20S Pb/OCP Soil 1/12/2012 A 1201339-009 Comp EB (21S, 22S) Soil 1/12/2012 B 1201339-009 EB-21S Pb/OCP Soil 1/12/2012 A 1201339-010 Comp EB (21B, 22B) Soil 1/12/2012 B 1201339-011 EB-22S Pb/OCP Soil 1/12/2012 A 1201339-013 EB-31S Pb Soil 1/12/2012 A 1201339-014 Comp EB (31S, 32S) Soil 1/12/2012 B 1201339-015 EB-32S Pb/OCP Soil 1/12/2012 A 1201339-017 Comp EB (23S, 33S) Soil 1/12/2012 B

Test Legend:

1 8081_S 2 PB_S 3 4 5 6 7 8 9 10 11 12

Prepared by:

Comments:

Page 8 of 23 McCampbell Analytical, Inc. Page 2 of 3 1534 Willow Pass Rd CHAIN-OF-CUSTODY RECORD Pittsburg, CA 94565-1701 (925) 252-9262 WorkOrder: 1201339 ClientCode: ECON WaterTrax WriteOn EDF Excel Fax Email HardCopy ThirdParty J-flag

Report to: Bill to: Requested TAT: 5 days Andy Rodgers Email: [email protected]; [email protected] Andy Rodgers ECON cc: ECON 241 South Main Street PO: 241 South Main Street Date Received: 01/13/2012 Sebastopol, CA 95472 ProjectNo: NUSD; Pb/OCP Sampling Sebastopol, CA 95472 Date Printed: 01/17/2012 (707) 789-0262 FAX: 707-823-8725

Requested Tests (See legend below) Lab ID Client ID Matrix Collection Date Hold 1 2 3 4 5 6 7 8 9 10 11 12

1201339-017 EB-23S Pb/OCP Soil 1/12/2012 A 1201339-018 Comp EB(23B, 33B) Soil 1/12/2012 B 1201339-019 EB-33S Pb/OCP Soil 1/12/2012 A 1201339-021 Comp EB (24S, 34S, 35S) Soil 1/12/2012 B 1201339-021 EB-24S Pb/OCP Soil 1/12/2012 A 1201339-022 Comp EB (24B, 34B, 35B) Soil 1/12/2012 B 1201339-023 EB-34S Pb/OCP Soil 1/12/2012 A 1201339-025 EB-35S Pb/OCP Soil 1/12/2012 A 1201339-027 Comp EB (25S, 36S) Soil 1/12/2012 B 1201339-027 EB-25S Pb/OCP Soil 1/12/2012 A 1201339-028 Comp EB (25B, 36B) Soil 1/12/2012 B 1201339-029 EB-36S Pb/OCP Soil 1/12/2012 A 1201339-031 EB-26S Pb/OCP Soil 1/13/2012 A A 1201339-032 EB-26B OCP Soil 1/13/2012 A

Test Legend:

1 8081_S 2 PB_S 3 4 5 6 7 8 9 10 11 12

Prepared by:

Comments:

Page 9 of 23 McCampbell Analytical, Inc. Page 3 of 3 1534 Willow Pass Rd CHAIN-OF-CUSTODY RECORD Pittsburg, CA 94565-1701 (925) 252-9262 WorkOrder: 1201339 ClientCode: ECON WaterTrax WriteOn EDF Excel Fax Email HardCopy ThirdParty J-flag

Report to: Bill to: Requested TAT: 5 days Andy Rodgers Email: [email protected]; [email protected] Andy Rodgers ECON cc: ECON 241 South Main Street PO: 241 South Main Street Date Received: 01/13/2012 Sebastopol, CA 95472 ProjectNo: NUSD; Pb/OCP Sampling Sebastopol, CA 95472 Date Printed: 01/17/2012 (707) 789-0262 FAX: 707-823-8725

Requested Tests (See legend below) Lab ID Client ID Matrix Collection Date Hold 1 2 3 4 5 6 7 8 9 10 11 12

1201339-033 EB-27SPb/OCP Soil 1/13/2012 A A 1201339-034 EB-27B OCP Soil 1/13/2012 A 1201339-035 EB-38S Pb/OCP Soil 1/13/2012 A A 1201339-036 EB-38B OCP Soil 1/13/2012 A 1201339-037 EB-30S Pb/OCP Soil 1/13/2012 A A 1201339-038 EB-30B OCP Soil 1/13/2012 A 1201339-040 Comp EB (28S, 37S) Soil 1/13/2012 B 1201339-040 EB-28S Pb/OCP Soil 1/13/2012 A 1201339-041 Comp EB(28B, 37B) Soil 1/13/2012 B 1201339-042 EB-37S Pb/OCP Soil 1/13/2012 A 1201339-044 EB-29S Pb/OCP Soil 1/13/2012 A A 1201339-045 EB-29B OCP Soil 1/13/2012 A

Test Legend:

1 8081_S 2 PB_S 3 4 5 6 7 8 9 10 11 12

Prepared by:

Comments:

Page 10 of 23

Sample Receipt Checklist

Client Name: ECON Date and Time Received: 1/13/2012 6:53:25 PM

Project Name: NUSD; Pb/OCP Sampling Checklist completed and reviewed by: Zoraida Cortez

WorkOrder N°: 1201339 Matrix: Soil Carrier: Benjamin Yslas (MAI Courier)

Chain of Custody (COC) Information

Chain of custody present? Yes No

Chain of custody signed when relinquished and received? Yes No

Chain of custody agrees with sample labels? Yes No

Sample IDs noted by Client on COC? Yes No

Date and Time of collection noted by Client on COC? Yes No

Sampler's name noted on COC? Yes No

Sample Receipt Information

Custody seals intact on shipping container/cooler? Yes No NA

Shipping container/cooler in good condition? Yes No

Samples in proper containers/bottles? Yes No

Sample containers intact? Yes No

Sufficient sample volume for indicated test? Yes No

Sample Preservation and Hold Time (HT) Information

All samples received within holding time? Yes No

Container/Temp Blank temperature Cooler Temp: 1.2°C NA

Water - VOA vials have zero headspace / no bubbles? Yes No No VOA vials submitted

Sample labels checked for correct preservation? Yes No

Metal - pH acceptable upon receipt (pH<2)? Yes No NA

Samples Received on Ice? Yes No (Ice Type: WET ICE )

* NOTE: If the "No" box is checked, see comments below.

Comments:

Page 11 of 23 1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected] ECON Client Project ID: NUSD; Pb/OCP Date Sampled: 01/12/12-01/13/12 Sampling Date Received: 01/13/12 241 South Main Street Client Contact: Andy Rodgers Date Extracted: 01/13/12 Sebastopol, CA 95472 Client P.O.: Date Analyzed: 01/14/12-01/19/12 Organochlorine Pesticides by GC-ECD (8080 Basic Target List)* Extraction Method: SW3550B Analytical Method: SW8081A Work Order: 1201339 Lab ID 1201339-001B 1201339-002B 1201339-009B 1201339-010B Reporting Limit for Client ID Comp EB (17S, Comp EB (17B, Comp EB (21S, Comp EB (21B, DF =1 18S, 19S, 20S) 18B, 19B, 20B) 22S) 22B) Matrix S S S S S W DF 10 5 10 100 Compound Concentration mg/kg µg/L Aldrin ND<0.010 ND<0.0050 ND<0.010 ND<0.10 0.001 NA a-BHC ND<0.010 ND<0.0050 ND<0.010 ND<0.10 0.001 NA b-BHC ND<0.010 ND<0.0050 ND<0.010 ND<0.10 0.001 NA d-BHC ND<0.010 ND<0.0050 ND<0.010 ND<0.10 0.001 NA g-BHC ND<0.010 ND<0.0050 ND<0.010 ND<0.10 0.001 NA Chlordane (Technical) ND<0.25 0.38 ND<0.25 ND<2.5 0.025 NA a-Chlordane 0.036 0.053 0.12 ND<0.10 0.001 NA g-Chlordane 0.020 0.033 0.011 ND<0.10 0.001 NA p,p-DDD ND<0.010 ND<0.0050 ND<0.010 ND<0.10 0.001 NA p,p-DDE 0.040 0.062 0.033 ND<0.10 0.001 NA p,p-DDT ND<0.010 0.024 0.013 ND<0.10 0.001 NA Dieldrin 0.035 ND<0.0050 ND<0.010 ND<0.10 0.001 NA Endosulfan I ND<0.010 ND<0.0050 ND<0.010 ND<0.10 0.001 NA Endosulfan II ND<0.010 ND<0.0050 ND<0.010 ND<0.10 0.001 NA Endosulfan sulfate ND<0.010 ND<0.0050 ND<0.010 ND<0.10 0.001 NA Endrin ND<0.010 ND<0.0050 ND<0.010 ND<0.10 0.001 NA Endrin aldehyde ND<0.010 ND<0.0050 ND<0.010 ND<0.10 0.001 NA Endrin ketone ND<0.010 ND<0.0050 ND<0.010 ND<0.10 0.001 NA Heptachlor ND<0.010 ND<0.0050 ND<0.010 ND<0.10 0.001 NA Heptachlor epoxide ND<0.010 ND<0.0050 ND<0.010 ND<0.10 0.001 NA Hexachlorobenzene ND<0.10 ND<0.050 ND<0.10 ND<1.0 0.01 NA Hexachlorocyclopentadiene ND<0.20 ND<0.10 ND<0.20 ND<2.0 0.02 NA Methoxychlor ND<0.010 ND<0.0050 ND<0.010 ND<0.10 0.001 NA Toxaphene ND<0.50 ND<0.25 ND<0.50 ND<5.0 0.05 NA Surrogate Recoveries (%) %SS: 115 106 114 110 Comments a3 * water samples in µg/L, soil/sludge/solid samples in mg/kg, wipe samples in µg/wipe, filter samples in µg/filter, product/oil/non-aqueous liquid samples and all TCLP & SPLP extracts are reported in mg/L.

ND means not detected above the reporting limit/method detection limit; N/A means analyte not applicable to this analysis; %SS = Percent Recovery of Surrogate Standard; DF = Dilution Factor.

# surrogate diluted out of range or surrogate coelutes with another peak/sample contains surrogate. a3) sample diluted due to high organic content.

DHS ELAP Certification 1644 Angela Rydelius, Lab Manager Page 12 of 23 1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected] ECON Client Project ID: NUSD; Pb/OCP Date Sampled: 01/12/12-01/13/12 Sampling Date Received: 01/13/12 241 South Main Street Client Contact: Andy Rodgers Date Extracted: 01/13/12 Sebastopol, CA 95472 Client P.O.: Date Analyzed: 01/14/12-01/19/12 Organochlorine Pesticides by GC-ECD (8080 Basic Target List)* Extraction Method: SW3550B Analytical Method: SW8081A Work Order: 1201339 Lab ID 1201339-014B 1201339-017B 1201339-018B 1201339-021B Reporting Limit for Client ID Comp EB (31S, Comp EB (23S, Comp EB(23B, Comp EB (24S, DF =1 32S) 33S) 33B) 34S, 35S) Matrix S S S S S W DF 1000 100 1 5 Compound Concentration mg/kg µg/L Aldrin ND<1.0 ND<0.10 ND ND<0.0050 0.001 NA a-BHC ND<1.0 ND<0.10 ND ND<0.0050 0.001 NA b-BHC ND<1.0 ND<0.10 ND ND<0.0050 0.001 NA d-BHC ND<1.0 ND<0.10 ND ND<0.0050 0.001 NA g-BHC ND<1.0 ND<0.10 ND ND<0.0050 0.001 NA Chlordane (Technical) ND<25 ND<2.5 ND ND<0.12 0.025 NA a-Chlordane ND<1.0 ND<0.10 ND ND<0.0050 0.001 NA g-Chlordane ND<1.0 ND<0.10 ND ND<0.0050 0.001 NA p,p-DDD ND<1.0 ND<0.10 ND ND<0.0050 0.001 NA p,p-DDE ND<1.0 ND<0.10 ND ND<0.0050 0.001 NA p,p-DDT ND<1.0 ND<0.10 ND ND<0.0050 0.001 NA Dieldrin ND<1.0 ND<0.10 ND ND<0.0050 0.001 NA Endosulfan I ND<1.0 ND<0.10 ND ND<0.0050 0.001 NA Endosulfan II ND<1.0 ND<0.10 ND ND<0.0050 0.001 NA Endosulfan sulfate ND<1.0 ND<0.10 ND ND<0.0050 0.001 NA Endrin ND<1.0 ND<0.10 ND ND<0.0050 0.001 NA Endrin aldehyde ND<1.0 ND<0.10 ND ND<0.0050 0.001 NA Endrin ketone ND<1.0 ND<0.10 ND ND<0.0050 0.001 NA Heptachlor ND<1.0 ND<0.10 ND ND<0.0050 0.001 NA Heptachlor epoxide ND<1.0 ND<0.10 ND ND<0.0050 0.001 NA Hexachlorobenzene ND<10 ND<1.0 ND ND<0.050 0.01 NA Hexachlorocyclopentadiene ND<20 ND<2.0 ND ND<0.10 0.02 NA Methoxychlor ND<1.0 ND<0.10 ND ND<0.0050 0.001 NA Toxaphene ND<50 ND<5.0 ND ND<0.25 0.05 NA Surrogate Recoveries (%) %SS: ---# 124 86 97 Comments a3 a3 a3 * water samples in µg/L, soil/sludge/solid samples in mg/kg, wipe samples in µg/wipe, filter samples in µg/filter, product/oil/non-aqueous liquid samples and all TCLP & SPLP extracts are reported in mg/L.

ND means not detected above the reporting limit/method detection limit; N/A means analyte not applicable to this analysis; %SS = Percent Recovery of Surrogate Standard; DF = Dilution Factor.

# surrogate diluted out of range or surrogate coelutes with another peak/sample contains surrogate. a3) sample diluted due to high organic content.

DHS ELAP Certification 1644 Angela Rydelius, Lab Manager Page 13 of 23 1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected] ECON Client Project ID: NUSD; Pb/OCP Date Sampled: 01/12/12-01/13/12 Sampling Date Received: 01/13/12 241 South Main Street Client Contact: Andy Rodgers Date Extracted: 01/13/12 Sebastopol, CA 95472 Client P.O.: Date Analyzed: 01/14/12-01/19/12 Organochlorine Pesticides by GC-ECD (8080 Basic Target List)* Extraction Method: SW3550B Analytical Method: SW8081A Work Order: 1201339 Lab ID 1201339-022B 1201339-027B 1201339-028B 1201339-031A Reporting Limit for Client ID Comp EB (24B, Comp EB (25S, Comp EB (25B, EB-26S Pb/OCP DF =1 34B, 35B) 36S) 36B) Matrix S S S S S W DF 10 100 20 2000 Compound Concentration mg/kg µg/L Aldrin ND<0.010 ND<0.10 ND<0.020 ND<2.0 0.001 NA a-BHC ND<0.010 ND<0.10 ND<0.020 ND<2.0 0.001 NA b-BHC ND<0.010 ND<0.10 ND<0.020 ND<2.0 0.001 NA d-BHC ND<0.010 ND<0.10 ND<0.020 ND<2.0 0.001 NA g-BHC ND<0.010 ND<0.10 ND<0.020 ND<2.0 0.001 NA Chlordane (Technical) ND<0.25 ND<2.5 ND<0.50 ND<50 0.025 NA a-Chlordane ND<0.010 ND<0.10 ND<0.020 ND<2.0 0.001 NA g-Chlordane ND<0.010 ND<0.10 ND<0.020 ND<2.0 0.001 NA p,p-DDD ND<0.010 ND<0.10 ND<0.020 ND<2.0 0.001 NA p,p-DDE ND<0.010 ND<0.10 ND<0.020 ND<2.0 0.001 NA p,p-DDT ND<0.010 ND<0.10 ND<0.020 ND<2.0 0.001 NA Dieldrin ND<0.010 ND<0.10 ND<0.020 ND<2.0 0.001 NA Endosulfan I ND<0.010 ND<0.10 ND<0.020 ND<2.0 0.001 NA Endosulfan II ND<0.010 ND<0.10 ND<0.020 ND<2.0 0.001 NA Endosulfan sulfate ND<0.010 ND<0.10 ND<0.020 ND<2.0 0.001 NA Endrin ND<0.010 ND<0.10 ND<0.020 ND<2.0 0.001 NA Endrin aldehyde ND<0.010 ND<0.10 ND<0.020 ND<2.0 0.001 NA Endrin ketone ND<0.010 ND<0.10 ND<0.020 ND<2.0 0.001 NA Heptachlor ND<0.010 ND<0.10 ND<0.020 ND<2.0 0.001 NA Heptachlor epoxide ND<0.010 ND<0.10 ND<0.020 ND<2.0 0.001 NA Hexachlorobenzene ND<0.10 ND<1.0 ND<0.20 ND<20 0.01 NA Hexachlorocyclopentadiene ND<0.20 ND<2.0 ND<0.40 ND<40 0.02 NA Methoxychlor ND<0.010 ND<0.10 ND<0.020 ND<2.0 0.001 NA Toxaphene ND<0.50 ND<5.0 ND<1.0 ND<100 0.05 NA Surrogate Recoveries (%) %SS: 89 117 101 ---# Comments a3 a3 a3 a3 * water samples in µg/L, soil/sludge/solid samples in mg/kg, wipe samples in µg/wipe, filter samples in µg/filter, product/oil/non-aqueous liquid samples and all TCLP & SPLP extracts are reported in mg/L.

ND means not detected above the reporting limit/method detection limit; N/A means analyte not applicable to this analysis; %SS = Percent Recovery of Surrogate Standard; DF = Dilution Factor.

# surrogate diluted out of range or surrogate coelutes with another peak/sample contains surrogate. a3) sample diluted due to high organic content.

DHS ELAP Certification 1644 Angela Rydelius, Lab Manager Page 14 of 23 1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected] ECON Client Project ID: NUSD; Pb/OCP Date Sampled: 01/12/12-01/13/12 Sampling Date Received: 01/13/12 241 South Main Street Client Contact: Andy Rodgers Date Extracted: 01/13/12 Sebastopol, CA 95472 Client P.O.: Date Analyzed: 01/14/12-01/19/12 Organochlorine Pesticides by GC-ECD (8080 Basic Target List)* Extraction Method: SW3550B Analytical Method: SW8081A Work Order: 1201339 Lab ID 1201339-032A 1201339-033A 1201339-034A 1201339-035A Reporting Limit for Client ID EB-26B OCP EB-27SPb/OCP EB-27B OCP EB-38S Pb/OCP DF =1

Matrix S S S S S W DF 1 100 1 100 Compound Concentration mg/kg µg/L Aldrin ND ND<0.10 ND ND<0.10 0.001 NA a-BHC ND ND<0.10 ND ND<0.10 0.001 NA b-BHC ND ND<0.10 ND ND<0.10 0.001 NA d-BHC ND ND<0.10 ND ND<0.10 0.001 NA g-BHC ND ND<0.10 ND ND<0.10 0.001 NA Chlordane (Technical) ND ND<2.5 ND ND<2.5 0.025 NA a-Chlordane ND ND<0.10 ND ND<0.10 0.001 NA g-Chlordane ND ND<0.10 ND ND<0.10 0.001 NA p,p-DDD ND ND<0.10 ND ND<0.10 0.001 NA p,p-DDE ND ND<0.10 ND ND<0.10 0.001 NA p,p-DDT ND ND<0.10 ND ND<0.10 0.001 NA Dieldrin ND ND<0.10 ND ND<0.10 0.001 NA Endosulfan I ND ND<0.10 ND ND<0.10 0.001 NA Endosulfan II ND ND<0.10 ND ND<0.10 0.001 NA Endosulfan sulfate ND ND<0.10 ND ND<0.10 0.001 NA Endrin ND ND<0.10 ND ND<0.10 0.001 NA Endrin aldehyde ND ND<0.10 ND ND<0.10 0.001 NA Endrin ketone ND ND<0.10 ND ND<0.10 0.001 NA Heptachlor ND ND<0.10 ND ND<0.10 0.001 NA Heptachlor epoxide ND ND<0.10 ND ND<0.10 0.001 NA Hexachlorobenzene ND ND<1.0 ND ND<1.0 0.01 NA Hexachlorocyclopentadiene ND ND<2.0 ND ND<2.0 0.02 NA Methoxychlor ND ND<0.10 ND ND<0.10 0.001 NA Toxaphene ND ND<5.0 ND ND<5.0 0.05 NA Surrogate Recoveries (%) %SS: 83 118 92 98 Comments a3 a3 * water samples in µg/L, soil/sludge/solid samples in mg/kg, wipe samples in µg/wipe, filter samples in µg/filter, product/oil/non-aqueous liquid samples and all TCLP & SPLP extracts are reported in mg/L.

ND means not detected above the reporting limit/method detection limit; N/A means analyte not applicable to this analysis; %SS = Percent Recovery of Surrogate Standard; DF = Dilution Factor.

# surrogate diluted out of range or surrogate coelutes with another peak/sample contains surrogate. a3) sample diluted due to high organic content.

DHS ELAP Certification 1644 Angela Rydelius, Lab Manager Page 15 of 23 1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected] ECON Client Project ID: NUSD; Pb/OCP Date Sampled: 01/12/12-01/13/12 Sampling Date Received: 01/13/12 241 South Main Street Client Contact: Andy Rodgers Date Extracted: 01/13/12 Sebastopol, CA 95472 Client P.O.: Date Analyzed: 01/14/12-01/19/12 Organochlorine Pesticides by GC-ECD (8080 Basic Target List)* Extraction Method: SW3550B Analytical Method: SW8081A Work Order: 1201339 Lab ID 1201339-036A 1201339-037A 1201339-038A 1201339-040B Reporting Limit for Client ID EB-38B OCP EB-30S Pb/OCP EB-30B OCP Comp EB (28S, DF =1 37S) Matrix S S S S S W DF 1 1000 100 1000 Compound Concentration mg/kg µg/L Aldrin ND ND<1.0 ND<0.10 ND<1.0 0.001 NA a-BHC ND ND<1.0 ND<0.10 ND<1.0 0.001 NA b-BHC ND ND<1.0 ND<0.10 ND<1.0 0.001 NA d-BHC ND ND<1.0 ND<0.10 ND<1.0 0.001 NA g-BHC ND ND<1.0 ND<0.10 ND<1.0 0.001 NA Chlordane (Technical) ND ND<25 ND<2.5 ND<25 0.025 NA a-Chlordane ND ND<1.0 ND<0.10 ND<1.0 0.001 NA g-Chlordane ND ND<1.0 ND<0.10 ND<1.0 0.001 NA p,p-DDD ND ND<1.0 ND<0.10 ND<1.0 0.001 NA p,p-DDE ND ND<1.0 ND<0.10 ND<1.0 0.001 NA p,p-DDT ND ND<1.0 ND<0.10 ND<1.0 0.001 NA Dieldrin ND ND<1.0 ND<0.10 ND<1.0 0.001 NA Endosulfan I ND ND<1.0 ND<0.10 ND<1.0 0.001 NA Endosulfan II ND ND<1.0 ND<0.10 ND<1.0 0.001 NA Endosulfan sulfate ND ND<1.0 ND<0.10 ND<1.0 0.001 NA Endrin ND ND<1.0 ND<0.10 ND<1.0 0.001 NA Endrin aldehyde ND ND<1.0 ND<0.10 ND<1.0 0.001 NA Endrin ketone ND ND<1.0 ND<0.10 ND<1.0 0.001 NA Heptachlor ND ND<1.0 ND<0.10 ND<1.0 0.001 NA Heptachlor epoxide ND ND<1.0 ND<0.10 ND<1.0 0.001 NA Hexachlorobenzene ND ND<10 ND<1.0 ND<10 0.01 NA Hexachlorocyclopentadiene ND ND<20 ND<2.0 ND<20 0.02 NA Methoxychlor ND ND<1.0 ND<0.10 ND<1.0 0.001 NA Toxaphene ND ND<50 ND<5.0 ND<50 0.05 NA Surrogate Recoveries (%) %SS: 96 ---# 112 ---# Comments a3 a3 a3 * water samples in µg/L, soil/sludge/solid samples in mg/kg, wipe samples in µg/wipe, filter samples in µg/filter, product/oil/non-aqueous liquid samples and all TCLP & SPLP extracts are reported in mg/L.

ND means not detected above the reporting limit/method detection limit; N/A means analyte not applicable to this analysis; %SS = Percent Recovery of Surrogate Standard; DF = Dilution Factor.

# surrogate diluted out of range or surrogate coelutes with another peak/sample contains surrogate. a3) sample diluted due to high organic content.

DHS ELAP Certification 1644 Angela Rydelius, Lab Manager Page 16 of 23 1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected] ECON Client Project ID: NUSD; Pb/OCP Date Sampled: 01/12/12-01/13/12 Sampling Date Received: 01/13/12 241 South Main Street Client Contact: Andy Rodgers Date Extracted: 01/13/12 Sebastopol, CA 95472 Client P.O.: Date Analyzed: 01/14/12-01/19/12 Organochlorine Pesticides by GC-ECD (8080 Basic Target List)* Extraction Method: SW3550B Analytical Method: SW8081A Work Order: 1201339 Lab ID 1201339-041B 1201339-044A 1201339-045A Reporting Limit for Client ID Comp EB(28B, EB-29S Pb/OCP EB-29B OCP DF =1 37B) Matrix S S S S W DF 1 1000 1 Compound Concentration mg/kg µg/L Aldrin ND ND<1.0 ND 0.001 NA a-BHC ND ND<1.0 ND 0.001 NA b-BHC ND ND<1.0 ND 0.001 NA d-BHC ND ND<1.0 ND 0.001 NA g-BHC ND ND<1.0 ND 0.001 NA Chlordane (Technical) ND ND<25 ND 0.025 NA a-Chlordane ND ND<1.0 ND 0.001 NA g-Chlordane ND ND<1.0 ND 0.001 NA p,p-DDD ND ND<1.0 ND 0.001 NA p,p-DDE ND ND<1.0 ND 0.001 NA p,p-DDT ND ND<1.0 ND 0.001 NA Dieldrin ND ND<1.0 ND 0.001 NA Endosulfan I ND ND<1.0 ND 0.001 NA Endosulfan II ND ND<1.0 ND 0.001 NA Endosulfan sulfate ND ND<1.0 ND 0.001 NA Endrin ND ND<1.0 ND 0.001 NA Endrin aldehyde ND ND<1.0 ND 0.001 NA Endrin ketone ND ND<1.0 ND 0.001 NA Heptachlor ND ND<1.0 ND 0.001 NA Heptachlor epoxide ND ND<1.0 ND 0.001 NA Hexachlorobenzene ND ND<10 ND 0.01 NA Hexachlorocyclopentadiene ND ND<20 ND 0.02 NA Methoxychlor ND ND<1.0 ND 0.001 NA Toxaphene ND ND<50 ND 0.05 NA Surrogate Recoveries (%) %SS: 92 ---# 95 Comments a3 * water samples in µg/L, soil/sludge/solid samples in mg/kg, wipe samples in µg/wipe, filter samples in µg/filter, product/oil/non-aqueous liquid samples and all TCLP & SPLP extracts are reported in mg/L.

ND means not detected above the reporting limit/method detection limit; N/A means analyte not applicable to this analysis; %SS = Percent Recovery of Surrogate Standard; DF = Dilution Factor.

# surrogate diluted out of range or surrogate coelutes with another peak/sample contains surrogate. a3) sample diluted due to high organic content.

DHS ELAP Certification 1644 Angela Rydelius, Lab Manager Page 17 of 23

1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected] ECON Client Project ID: NUSD; Pb/OCP Date Sampled: 01/12/12-01/13/12 Sampling Date Received: 01/13/12 241 South Main Street Client Contact: Andy Rodgers Date Extracted: 01/13/12

Sebastopol, CA 95472 Client P.O.: Date Analyzed: 01/17/12

Lead by ICP* Extraction method: SW3050B Analytical methods: SW6010B Work Order: 1201339 Lab ID Client ID Matrix Extraction Type Lead DF % SS Comments

1201339-001A EB-17S Pb/OCP S TOTAL 11 1 90

1201339-003A EB-18S Pb/OCP S TOTAL 180 1 103

1201339-005A EB-19S Pb/OCP S TOTAL 9.4 1 93

1201339-007A EB-20S Pb/OCP S TOTAL 14 1 97

1201339-009A EB-21S Pb/OCP S TOTAL 8.7 1 93

1201339-011A EB-22S Pb/OCP S TOTAL 15 1 93

1201339-013A EB-31S Pb S TOTAL 38 1 100

1201339-015A EB-32S Pb/OCP S TOTAL 32 1 91

1201339-017A EB-23S Pb/OCP S TOTAL 11 1 98

1201339-019A EB-33S Pb/OCP S TOTAL 34 1 100

1201339-021A EB-24S Pb/OCP S TOTAL 76 1 95

1201339-023A EB-34S Pb/OCP S TOTAL 8.8 1 96

1201339-025A EB-35S Pb/OCP S TOTAL 8.9 1 95

1201339-027A EB-25S Pb/OCP S TOTAL 46 1 96

# means surrogate diluted out of range; ND means not detected above the reporting limit/method detection limit; N/A means not applicable to this sample or instrument.

%SS = Percent Recovery of Surrogate Standard DF = Dilution Factor

DHS ELAP Certification 1644 Angela Rydelius, Lab Manager

Page 18 of 23 1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected] ECON Client Project ID: NUSD; Pb/OCP Date Sampled: 01/12/12-01/13/12 Sampling Date Received: 01/13/12 241 South Main Street Client Contact: Andy Rodgers Date Extracted: 01/13/12

Sebastopol, CA 95472 Client P.O.: Date Analyzed: 01/17/12

Lead by ICP* Extraction method: SW3050B Analytical methods: SW6010B Work Order: 1201339 Lab ID Client ID Matrix Extraction Type Lead DF % SS Comments

1201339-029A EB-36S Pb/OCP S TOTAL 13 1 93

1201339-031A EB-26S Pb/OCP S TOTAL 750 1 104

1201339-033A EB-27SPb/OCP S TOTAL 15 1 102

1201339-035A EB-38S Pb/OCP S TOTAL 290 1 94

1201339-037A EB-30S Pb/OCP S TOTAL ND 1 99

1201339-040A EB-28S Pb/OCP S TOTAL 130 1 96

1201339-042A EB-37S Pb/OCP S TOTAL 75 1 90

1201339-044A EB-29S Pb/OCP S TOTAL 130 1 96

# means surrogate diluted out of range; ND means not detected above the reporting limit/method detection limit; N/A means not applicable to this sample or instrument.

%SS = Percent Recovery of Surrogate Standard DF = Dilution Factor

DHS ELAP Certification 1644 Angela Rydelius, Lab Manager

Page 19 of 23 1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected]

QC SUMMARY REPORT FOR SW8081A

W.O. Sample Matrix: Soil QC Matrix: Soil BatchID: 64014 WorkOrder: 1201339

EPA Method: SW8081A Extraction: SW3550B Spiked Sample ID: 1201266-026B

Sample Spiked MS MSD MS-MSD LCS Acceptance Criteria (%) Analyte mg/kg mg/kg % Rec. % Rec. % RPD % Rec. MS / MSD RPD LCS

Aldrin ND<0.050 0.020 NR NR NR 109 N/A N/A 70 - 130 g-BHC ND<0.050 0.020 NR NR NR 93.3 N/A N/A 70 - 130 p,p-DDT ND<0.050 0.050 NR NR NR 87.4 N/A N/A 70 - 130 Dieldrin ND<0.050 0.050 NR NR NR 105 N/A N/A 70 - 130 Endrin ND<0.050 0.050 NR NR NR 107 N/A N/A 70 - 130 Heptachlor ND<0.050 0.020 NR NR NR 107 N/A N/A 70 - 130 %SS: 111 0.050 109 87 22.5 108 70 - 130 30 70 - 130 All target compounds in the Method Blank of this extraction batch were ND less than the method RL with the following exceptions: NONE

BATCH 64014 SUMMARY Lab ID Date Sampled Date Extracted Date Analyzed Lab ID Date Sampled Date Extracted Date Analyzed 1201339-001B 01/12/12 01/13/12 01/14/12 7:37 AM 1201339-002B 01/12/12 01/13/12 01/18/12 10:33 AM 1201339-009B 01/12/12 01/13/12 01/14/12 8:33 AM 1201339-010B 01/12/12 01/13/12 01/18/12 12:24 PM 1201339-014B 01/12/12 01/13/12 01/18/12 8:46 PM 1201339-017B 01/12/12 01/13/12 01/19/12 2:17 AM 1201339-018B 01/12/12 01/13/12 01/18/12 8:30 PM 1201339-021B 01/12/12 01/13/12 01/18/12 9:37 AM 1201339-022B 01/12/12 01/13/12 01/18/12 11:29 AM 1201339-027B 01/12/12 01/13/12 01/14/12 9:29 AM

MS = Matrix Spike; MSD = Matrix Spike Duplicate; LCS = Laboratory Control Sample; LCSD = Laboratory Control Sample Duplicate; RPD = Relative Percent Deviation.

% Recovery = 100 * (MS-Sample) / (Amount Spiked); RPD = 100 * (MS - MSD) / ((MS + MSD) / 2).

# surrogate diluted out of range or surrogate coelutes with another peak

N/A = not enough sample to perform matrix spike and matrix spike duplicate.

DHS ELAP Certification 1644 QA/QC Officer

Page 20 of 23 1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected]

QC SUMMARY REPORT FOR SW8081A

W.O. Sample Matrix: Soil QC Matrix: Soil BatchID: 64015 WorkOrder: 1201339

EPA Method: SW8081A Extraction: SW3550B Spiked Sample ID: 1201339-045A

Sample Spiked MS MSD MS-MSD LCS Acceptance Criteria (%) Analyte mg/kg mg/kg % Rec. % Rec. % RPD % Rec. MS / MSD RPD LCS

Aldrin ND 0.020 111 112 0.921 106 70 - 130 30 70 - 130 g-BHC ND 0.020 80.3 80.4 0.234 88.8 70 - 130 30 70 - 130 p,p-DDT ND 0.050 80.4 78.5 2.35 70.4 70 - 130 30 70 - 130 Dieldrin ND 0.050 105 106 0.714 97.7 70 - 130 30 70 - 130 Endrin ND 0.050 100 99.6 0.599 94.3 70 - 130 30 70 - 130 Heptachlor ND 0.020 112 113 0.701 97.4 70 - 130 30 70 - 130 %SS: 95 0.050 94 96 1.57 94.9 70 - 130 30 70 - 130 All target compounds in the Method Blank of this extraction batch were ND less than the method RL with the following exceptions: NONE

BATCH 64015 SUMMARY Lab ID Date Sampled Date Extracted Date Analyzed Lab ID Date Sampled Date Extracted Date Analyzed 1201339-028B 01/12/12 01/13/12 01/14/12 10:25 AM 1201339-031A 01/13/12 01/13/12 01/18/12 10:37 PM 1201339-032A 01/13/12 01/13/12 01/18/12 10:21 PM 1201339-033A 01/13/12 01/13/12 01/19/12 3:12 AM 1201339-034A 01/13/12 01/13/12 01/18/12 11:17 PM 1201339-035A 01/13/12 01/13/12 01/18/12 1:19 PM 1201339-036A 01/13/12 01/13/12 01/18/12 7:34 PM 1201339-037A 01/13/12 01/13/12 01/18/12 9:42 PM 1201339-038A 01/13/12 01/13/12 01/18/12 2:15 PM 1201339-040B 01/13/12 01/13/12 01/18/12 11:32 PM 1201339-041B 01/13/12 01/13/12 01/19/12 12:12 AM 1201339-044A 01/13/12 01/13/12 01/18/12 3:11 PM 1201339-045A 01/13/12 01/13/12 01/18/12 12:28 AM

MS = Matrix Spike; MSD = Matrix Spike Duplicate; LCS = Laboratory Control Sample; LCSD = Laboratory Control Sample Duplicate; RPD = Relative Percent Deviation.

% Recovery = 100 * (MS-Sample) / (Amount Spiked); RPD = 100 * (MS - MSD) / ((MS + MSD) / 2).

# surrogate diluted out of range or surrogate coelutes with another peak

N/A = not enough sample to perform matrix spike and matrix spike duplicate.

DHS ELAP Certification 1644 QA/QC Officer

Page 21 of 23 1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected]

QC SUMMARY REPORT FOR 6010B

W.O. Sample Matrix: Soil QC Matrix: Soil BatchID: 64037 WorkOrder: 1201339

EPA Method: SW6010B Extraction: SW3050B Spiked Sample ID: 1201315-037A

Sample Spiked MS MSD MS-MSD LCS Acceptance Criteria (%) Analyte mg/Kg mg/Kg % Rec. % Rec. % RPD % Rec. MS / MSD RPD LCS

Lead ND 50 106 110 4.22 89.9 75 - 125 25 75 - 125 %SS: 92 500 95 95 0 100 70 - 130 20 70 - 130 All target compounds in the Method Blank of this extraction batch were ND less than the method RL with the following exceptions: NONE

BATCH 64037 SUMMARY Lab ID Date Sampled Date Extracted Date Analyzed Lab ID Date Sampled Date Extracted Date Analyzed 1201339-001A 01/12/12 01/13/12 01/17/12 11:46 AM 1201339-005A 01/12/12 01/13/12 01/17/12 11:50 AM 1201339-007A 01/12/12 01/13/12 01/17/12 11:52 AM 1201339-009A 01/12/12 01/13/12 01/17/12 11:54 AM 1201339-011A 01/12/12 01/13/12 01/17/12 12:02 PM 1201339-013A 01/12/12 01/13/12 01/17/12 12:04 PM 1201339-015A 01/12/12 01/13/12 01/17/12 12:06 PM 1201339-017A 01/12/12 01/13/12 01/17/12 12:09 PM 1201339-019A 01/12/12 01/13/12 01/17/12 12:11 PM 1201339-021A 01/12/12 01/13/12 01/17/12 12:13 PM 1201339-023A 01/12/12 01/13/12 01/17/12 12:15 PM 1201339-025A 01/12/12 01/13/12 01/17/12 12:17 PM 1201339-027A 01/12/12 01/13/12 01/17/12 12:19 PM 1201339-029A 01/12/12 01/13/12 01/17/12 12:21 PM

MS = Matrix Spike; MSD = Matrix Spike Duplicate; LCS = Laboratory Control Sample; LCSD = Laboratory Control Sample Duplicate; RPD = Relative Percent Deviation.

% Recovery = 100 * (MS-Sample) / (Amount Spiked); RPD = 100 * (MS - MSD) / ((MS + MSD) / 2).

N/A = not applicable to this method.

NR = analyte concentration in sample exceeds spike amount for soil matrix or exceeds 2x spike amount for water matrix or sample diluted due to high matrix or analyte content.

DHS ELAP Certification 1644 QA/QC Officer

Page 22 of 23 1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected]

QC SUMMARY REPORT FOR 6010B

W.O. Sample Matrix: Soil QC Matrix: Soil BatchID: 64052 WorkOrder: 1201339

EPA Method: SW6010B Extraction: SW3050B Spiked Sample ID: 1201339-044A

Sample Spiked MS MSD MS-MSD LCS Acceptance Criteria (%) Analyte mg/Kg mg/Kg % Rec. % Rec. % RPD % Rec. MS / MSD RPD LCS

Lead 130 50 110 113 0.952 104 75 - 125 25 75 - 125 %SS: 96 500 103 98 5.27 97 70 - 130 20 70 - 130 All target compounds in the Method Blank of this extraction batch were ND less than the method RL with the following exceptions: NONE

BATCH 64052 SUMMARY Lab ID Date Sampled Date Extracted Date Analyzed Lab ID Date Sampled Date Extracted Date Analyzed 1201339-003A 01/12/12 01/13/12 01/17/12 11:48 AM 1201339-031A 01/13/12 01/13/12 01/17/12 12:29 PM 1201339-033A 01/13/12 01/13/12 01/17/12 12:31 PM 1201339-035A 01/13/12 01/13/12 01/17/12 12:33 PM 1201339-037A 01/13/12 01/13/12 01/17/12 12:35 PM 1201339-040A 01/13/12 01/13/12 01/17/12 12:38 PM 1201339-042A 01/13/12 01/13/12 01/17/12 12:40 PM 1201339-044A 01/13/12 01/13/12 01/17/12 12:42 PM

MS = Matrix Spike; MSD = Matrix Spike Duplicate; LCS = Laboratory Control Sample; LCSD = Laboratory Control Sample Duplicate; RPD = Relative Percent Deviation.

% Recovery = 100 * (MS-Sample) / (Amount Spiked); RPD = 100 * (MS - MSD) / ((MS + MSD) / 2).

N/A = not applicable to this method.

NR = analyte concentration in sample exceeds spike amount for soil matrix or exceeds 2x spike amount for water matrix or sample diluted due to high matrix or analyte content.

DHS ELAP Certification 1644 QA/QC Officer

Page 23 of 23

ECON Client Project ID: NUSD; Pb/OCP Sampling Date Sampled: 01/12/12-01/13/12

Date Received: 01/13/12 241 South Main Street Client Contact: Andy Rodgers Date Reported: 01/23/12

Sebastopol, CA 95472 Client P.O.: Date Completed: 01/23/12

WorkOrder: 1201417

January 24, 2012

Dear Andy:

Enclosed within are:

1) The results of the 9 analyzed samples from your project: NUSD; Pb/OCP Sampling, 2) QC data for the above samples, and 3) A copy of the chain of custody.

Best regards,

Angela Rydelius Laboratory Manager McCampbell Analytical, Inc.

The analytical results relate only to the items tested.

Page 1 of 14

Page 2 of 14

McCampbell Analytical, Inc. Page 1 of 1 1534 Willow Pass Rd CHAIN-OF-CUSTODY RECORD Pittsburg, CA 94565-1701 (925) 252-9262 WorkOrder: 1201417 ClientCode: ECON WaterTrax WriteOn EDF Excel Fax Email HardCopy ThirdParty J-flag

Report to: Bill to: Requested TAT: 5 days Andy Rodgers Email: [email protected]; [email protected] Andy Rodgers ECON cc: ECON 241 South Main Street PO: 241 South Main Street Date Received: 01/13/2012 Sebastopol, CA 95472 ProjectNo: NUSD; Pb/OCP Sampling Sebastopol, CA 95472 Date Printed: 01/19/2012 (707) 789-0262 FAX: 707-823-8725

Requested Tests (See legend below) Lab ID Client ID Matrix Collection Date Hold 1 2 3 4 5 6 7 8 9 10 11 12

1201417-001 EB-8s-Pb-Dup Soil 1/13/2012 A A 1201417-002 EB-2B OCP-Dup Soil 1/12/2012 A 1201417-003 EB-11B OCP-Dup Soil 1/12/2012 A 1201417-004 EB-20B OCP-Dup Soil 1/12/2012 A 1201417-005 EB-22S PB-Dup Soil 1/13/2012 A A 1201417-006 EB-23B OCP-Dup Soil 1/12/2012 A 1201417-007 EB-25S Pb-Dup Soil 1/12/2012 A A 1201417-008 Rinse Water 1/13/2012 B A 1201417-009 Rinse Bk Water 1/13/2012 B A

Test Legend:

1 8081_S 2 8081_W 3 PB_S 4 PBMS_W 5 6 7 8 9 10 11 12

Prepared by: Melissa Valles

Comments:

Page 3 of 14

Sample Receipt Checklist

Client Name: ECON Date and Time Received: 1/13/2012 5:35:00 PM

Project Name: NUSD; Pb/OCP Sampling Checklist completed and reviewed by: Melissa Valles

WorkOrder N°: 1201417 Matrix: Soil/Water Carrier: Benjamin Yslas (MAI Courier)

Chain of Custody (COC) Information

Chain of custody present? Yes No

Chain of custody signed when relinquished and received? Yes No

Chain of custody agrees with sample labels? Yes No

Sample IDs noted by Client on COC? Yes No

Date and Time of collection noted by Client on COC? Yes No

Sampler's name noted on COC? Yes No

Sample Receipt Information

Custody seals intact on shipping container/cooler? Yes No NA

Shipping container/cooler in good condition? Yes No

Samples in proper containers/bottles? Yes No

Sample containers intact? Yes No

Sufficient sample volume for indicated test? Yes No

Sample Preservation and Hold Time (HT) Information

All samples received within holding time? Yes No

Container/Temp Blank temperature Cooler Temp: 1.2°C NA

Water - VOA vials have zero headspace / no bubbles? Yes No No VOA vials submitted

Sample labels checked for correct preservation? Yes No

Metal - pH acceptable upon receipt (pH<2)? Yes No NA

Samples Received on Ice? Yes No (Ice Type: WET ICE )

* NOTE: If the "No" box is checked, see comments below.

Comments:

Page 4 of 14 1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected] ECON Client Project ID: NUSD; Pb/OCP Date Sampled: 01/12/12-01/13/12 Sampling Date Received: 01/13/12 241 South Main Street Client Contact: Andy Rodgers Date Extracted: 01/18/12-01/19/12 Sebastopol, CA 95472 Client P.O.: Date Analyzed: 01/19/12 Organochlorine Pesticides by GC-ECD (8080 Basic Target List)* Extraction Method: SW3550B Analytical Method: SW8081A Work Order: 1201417 Lab ID 1201417-001A 1201417-002A 1201417-003A 1201417-004A Reporting Limit for Client ID EB-8s-Pb-Dup EB-2B OCP-Dup EB-11B OCP-Dup EB-20B OCP-Dup DF =1

Matrix S S S S S W DF 100 1 5 500 Compound Concentration mg/kg µg/L Aldrin ND<0.10 ND ND<0.0050 ND<0.50 0.001 NA a-BHC ND<0.10 ND ND<0.0050 ND<0.50 0.001 NA b-BHC ND<0.10 ND ND<0.0050 ND<0.50 0.001 NA d-BHC ND<0.10 ND ND<0.0050 ND<0.50 0.001 NA g-BHC ND<0.10 ND ND<0.0050 ND<0.50 0.001 NA Chlordane (Technical) ND<2.5 ND ND<0.12 ND<12 0.025 NA a-Chlordane ND<0.10 ND ND<0.0050 ND<0.50 0.001 NA g-Chlordane ND<0.10 ND ND<0.0050 ND<0.50 0.001 NA p,p-DDD ND<0.10 ND ND<0.0050 ND<0.50 0.001 NA p,p-DDE ND<0.10 ND ND<0.0050 ND<0.50 0.001 NA p,p-DDT ND<0.10 ND ND<0.0050 ND<0.50 0.001 NA Dieldrin ND<0.10 ND ND<0.0050 ND<0.50 0.001 NA Endosulfan I ND<0.10 ND ND<0.0050 ND<0.50 0.001 NA Endosulfan II ND<0.10 ND ND<0.0050 ND<0.50 0.001 NA Endosulfan sulfate ND<0.10 ND ND<0.0050 ND<0.50 0.001 NA Endrin ND<0.10 ND ND<0.0050 ND<0.50 0.001 NA Endrin aldehyde ND<0.10 ND ND<0.0050 ND<0.50 0.001 NA Endrin ketone ND<0.10 ND ND<0.0050 ND<0.50 0.001 NA Heptachlor ND<0.10 ND ND<0.0050 ND<0.50 0.001 NA Heptachlor epoxide ND<0.10 ND ND<0.0050 ND<0.50 0.001 NA Hexachlorobenzene ND<1.0 ND ND<0.050 ND<5.0 0.01 NA Hexachlorocyclopentadiene ND<2.0 ND ND<0.10 ND<10 0.02 NA Methoxychlor ND<0.10 ND ND<0.0050 ND<0.50 0.001 NA Toxaphene ND<5.0 ND ND<0.25 ND<25 0.05 NA Surrogate Recoveries (%) %SS: 126 93 105 ---# Comments a3 a3 a3 * water samples in µg/L, soil/sludge/solid samples in mg/kg, wipe samples in µg/wipe, filter samples in µg/filter, product/oil/non-aqueous liquid samples and all TCLP & SPLP extracts are reported in mg/L.

ND means not detected above the reporting limit/method detection limit; N/A means analyte not applicable to this analysis; %SS = Percent Recovery of Surrogate Standard; DF = Dilution Factor.

# surrogate diluted out of range or surrogate coelutes with another peak/sample contains surrogate. a3) sample diluted due to high organic content.

DHS ELAP Certification 1644 Angela Rydelius, Lab Manager Page 5 of 14 1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected] ECON Client Project ID: NUSD; Pb/OCP Date Sampled: 01/12/12-01/13/12 Sampling Date Received: 01/13/12 241 South Main Street Client Contact: Andy Rodgers Date Extracted: 01/18/12-01/19/12 Sebastopol, CA 95472 Client P.O.: Date Analyzed: 01/19/12 Organochlorine Pesticides by GC-ECD (8080 Basic Target List)* Extraction Method: SW3550B Analytical Method: SW8081A Work Order: 1201417 Lab ID 1201417-005A 1201417-006A 1201417-007A Reporting Limit for Client ID EB-22S PB-Dup EB-23B OCP-Dup EB-25S Pb-Dup DF =1

Matrix S S S S W DF 100 1 500 Compound Concentration mg/kg µg/L Aldrin ND<0.10 ND ND<0.50 0.001 NA a-BHC ND<0.10 ND ND<0.50 0.001 NA b-BHC ND<0.10 ND ND<0.50 0.001 NA d-BHC ND<0.10 ND ND<0.50 0.001 NA g-BHC ND<0.10 ND ND<0.50 0.001 NA Chlordane (Technical) ND<2.5 ND ND<12 0.025 NA a-Chlordane ND<0.10 ND ND<0.50 0.001 NA g-Chlordane ND<0.10 ND ND<0.50 0.001 NA p,p-DDD ND<0.10 ND ND<0.50 0.001 NA p,p-DDE ND<0.10 ND ND<0.50 0.001 NA p,p-DDT ND<0.10 ND ND<0.50 0.001 NA Dieldrin ND<0.10 ND ND<0.50 0.001 NA Endosulfan I ND<0.10 ND ND<0.50 0.001 NA Endosulfan II ND<0.10 ND ND<0.50 0.001 NA Endosulfan sulfate ND<0.10 ND ND<0.50 0.001 NA Endrin ND<0.10 ND ND<0.50 0.001 NA Endrin aldehyde ND<0.10 ND ND<0.50 0.001 NA Endrin ketone ND<0.10 ND ND<0.50 0.001 NA Heptachlor ND<0.10 ND ND<0.50 0.001 NA Heptachlor epoxide ND<0.10 ND ND<0.50 0.001 NA Hexachlorobenzene ND<1.0 ND ND<5.0 0.01 NA Hexachlorocyclopentadiene ND<2.0 ND ND<10 0.02 NA Methoxychlor ND<0.10 ND ND<0.50 0.001 NA Toxaphene ND<5.0 ND ND<25 0.05 NA Surrogate Recoveries (%) %SS: 112 92 ---# Comments a3 a3 * water samples in µg/L, soil/sludge/solid samples in mg/kg, wipe samples in µg/wipe, filter samples in µg/filter, product/oil/non-aqueous liquid samples and all TCLP & SPLP extracts are reported in mg/L.

ND means not detected above the reporting limit/method detection limit; N/A means analyte not applicable to this analysis; %SS = Percent Recovery of Surrogate Standard; DF = Dilution Factor.

# surrogate diluted out of range or surrogate coelutes with another peak/sample contains surrogate. a3) sample diluted due to high organic content.

DHS ELAP Certification 1644 Angela Rydelius, Lab Manager Page 6 of 14 1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected] ECON Client Project ID: NUSD; Pb/OCP Date Sampled: 01/13/12 Sampling Date Received: 01/13/12 241 South Main Street Client Contact: Andy Rodgers Date Extracted: 01/18/12 Sebastopol, CA 95472 Client P.O.: Date Analyzed: 01/19/12 Organochlorine Pesticides by GC-ECD (8080 Basic Target List)* Extraction Method: SW3510C Analytical Method: SW8081A Work Order: 1201417 Lab ID 1201417-008B 1201417-009B Reporting Limit for Client ID Rinse Rinse Bk DF =1

Matrix W W S W DF 5 1 Compound Concentration µg/kg µg/L Aldrin ND<0.025 ND NA 0.005 a-BHC ND<0.050 ND NA 0.01 b-BHC ND<0.025 ND NA 0.005 d-BHC ND<0.025 ND NA 0.005 g-BHC ND<0.10 ND NA 0.02 Chlordane (Technical) ND<0.50 ND NA 0.1 a-Chlordane ND<0.25 ND NA 0.05 g-Chlordane ND<0.25 ND NA 0.05 p,p-DDD ND<0.050 ND NA 0.01 p,p-DDE ND<0.050 ND NA 0.01 p,p-DDT ND<0.050 ND NA 0.01 Dieldrin ND<0.050 ND NA 0.01 Endosulfan I ND<0.10 ND NA 0.02 Endosulfan II ND<0.10 ND NA 0.02 Endosulfan sulfate ND<0.25 ND NA 0.05 Endrin ND<0.050 ND NA 0.01 Endrin aldehyde ND<0.25 ND NA 0.05 Endrin ketone ND<0.25 ND NA 0.05 Heptachlor ND<0.050 ND NA 0.01 Heptachlor epoxide ND<0.050 ND NA 0.01 Hexachlorobenzene ND<2.5 ND NA 0.5 Hexachlorocyclopentadiene ND<5.0 ND NA 1.0 Methoxychlor ND<0.50 ND NA 0.1 Toxaphene ND<2.5 ND NA 0.5 Surrogate Recoveries (%) %SS: 86 82 Comments a3 * water samples in µg/L, soil/sludge/solid samples in mg/kg, wipe samples in µg/wipe, filter samples in µg/filter, product/oil/non-aqueous liquid samples and all TCLP & SPLP extracts are reported in mg/L.

ND means not detected above the reporting limit/method detection limit; N/A means analyte not applicable to this analysis; %SS = Percent Recovery of Surrogate Standard; DF = Dilution Factor.

# surrogate diluted out of range or surrogate coelutes with another peak. a3) sample diluted due to high organic content.

DHS ELAP Certification 1644 Angela Rydelius, Lab Manager Page 7 of 14

1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected] ECON Client Project ID: NUSD; Pb/OCP Date Sampled: 01/12/12-01/13/12 Sampling Date Received: 01/13/12 241 South Main Street Client Contact: Andy Rodgers Date Extracted: 01/18/12

Sebastopol, CA 95472 Client P.O.: Date Analyzed: 01/19/12

Lead by ICP* Extraction method: SW3050B Analytical methods: SW6010B Work Order: 1201417 Lab ID Client ID Matrix Extraction Type Lead DF % SS Comments

1201417-001A EB-8s-Pb-Dup S TOTAL 30 1 96

1201417-005A EB-22S PB-Dup S TOTAL 21 1 92

1201417-007A EB-25S Pb-Dup S TOTAL 240 1 94

# means surrogate diluted out of range; ND means not detected above the reporting limit/method detection limit; N/A means not applicable to this sample or instrument.

%SS = Percent Recovery of Surrogate Standard DF = Dilution Factor

DHS ELAP Certification 1644 Angela Rydelius, Lab Manager

Page 8 of 14

1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected] ECON Client Project ID: NUSD; Pb/OCP Date Sampled: 01/13/12 Sampling Date Received: 01/13/12 241 South Main Street Client Contact: Andy Rodgers Date Extracted: 01/18/12

Sebastopol, CA 95472 Client P.O.: Date Analyzed: 01/19/12

Lead by ICP-MS* Extraction method: E200.8 Analytical methods: E200.8 Work Order: 1201417 Lab ID Client ID Matrix Extraction Type Lead DF % SS Comments

1201417-008A Rinse W TOTAL 49 1 111

1201417-009A Rinse Bk W TOTAL ND 1 111

Reporting Limit for DF =1; W TOTAL 0.5 µg/L ND means not detected at or above the reporting limit S TOTAL NA mg/Kg *water samples are reported in µg/L, product/oil/non-aqueous liquid samples and all TCLP / STLC / DISTLC / SPLP extracts are reported in mg/L, soil/sludge/solid samples in mg/kg, wipe samples in µg/wipe, filter samples in µg/filter.

# means surrogate diluted out of range; ND means not detected above the reporting limit/method detection limit; N/A means not applicable to this sample or instrument.

%SS = Percent Recovery of Surrogate Standard DF = Dilution Factor

DHS ELAP Certification 1644 Angela Rydelius, Lab Manager

Page 9 of 14 1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected]

QC SUMMARY REPORT FOR SW8081A

W.O. Sample Matrix: Soil QC Matrix: Soil BatchID: 64015 WorkOrder: 1201417

EPA Method: SW8081A Extraction: SW3550B Spiked Sample ID: 1201339-045A

Sample Spiked MS MSD MS-MSD LCS Acceptance Criteria (%) Analyte mg/kg mg/kg % Rec. % Rec. % RPD % Rec. MS / MSD RPD LCS

BATCH 64015 SUMMARY Lab ID Date Sampled Date Extracted Date Analyzed Lab ID Date Sampled Date Extracted Date Analyzed 1201417-001A 01/13/12 01/18/12 01/19/12 6:47 PM 1201417-002A 01/12/12 01/18/12 01/19/12 10:13 PM 1201417-004A 01/12/12 01/18/12 01/19/12 8:38 PM 1201417-005A 01/13/12 01/18/12 01/19/12 7:42 PM 1201417-006A 01/12/12 01/18/12 01/19/12 5:51 PM 1201417-007A 01/12/12 01/18/12 01/19/12 9:34 PM

MS = Matrix Spike; MSD = Matrix Spike Duplicate; LCS = Laboratory Control Sample; LCSD = Laboratory Control Sample Duplicate; RPD = Relative Percent Deviation.

% Recovery = 100 * (MS-Sample) / (Amount Spiked); RPD = 100 * (MS - MSD) / ((MS + MSD) / 2).

# surrogate diluted out of range or surrogate coelutes with another peak

N/A = not enough sample to perform matrix spike and matrix spike duplicate.

DHS ELAP Certification 1644 QA/QC Officer

Page 10 of 14 1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected]

QC SUMMARY REPORT FOR SW8081A

W.O. Sample Matrix: Soil QC Matrix: Soil BatchID: 64022 WorkOrder: 1201417

EPA Method: SW8081A Extraction: SW3550B Spiked Sample ID: 1201281-003A

Sample Spiked MS MSD MS-MSD LCS Acceptance Criteria (%) Analyte mg/kg mg/kg % Rec. % Rec. % RPD % Rec. MS / MSD RPD LCS

Aldrin ND<0.10 0.020 NR NR NR 111 N/A N/A 70 - 130 g-BHC ND<0.10 0.020 NR NR NR 91.7 N/A N/A 70 - 130 p,p-DDT ND<0.10 0.050 NR NR NR 80.2 N/A N/A 70 - 130 Dieldrin ND<0.10 0.050 NR NR NR 103 N/A N/A 70 - 130 Endrin ND<0.10 0.050 NR NR NR 103 N/A N/A 70 - 130 Heptachlor ND<0.10 0.020 NR NR NR 102 N/A N/A 70 - 130 %SS: 112 0.050 103 116 12.4 104 70 - 130 30 70 - 130 All target compounds in the Method Blank of this extraction batch were ND less than the method RL with the following exceptions: NONE

BATCH 64022 SUMMARY Lab ID Date Sampled Date Extracted Date Analyzed Lab ID Date Sampled Date Extracted Date Analyzed 1201417-003A 01/12/12 01/19/12 01/19/12 9:17 PM

MS = Matrix Spike; MSD = Matrix Spike Duplicate; LCS = Laboratory Control Sample; LCSD = Laboratory Control Sample Duplicate; RPD = Relative Percent Deviation.

% Recovery = 100 * (MS-Sample) / (Amount Spiked); RPD = 100 * (MS - MSD) / ((MS + MSD) / 2).

# surrogate diluted out of range or surrogate coelutes with another peak

N/A = not enough sample to perform matrix spike and matrix spike duplicate.

DHS ELAP Certification 1644 QA/QC Officer

Page 11 of 14 1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected]

QC SUMMARY REPORT FOR SW8081A

W.O. Sample Matrix: Water QC Matrix: Water BatchID: 64120 WorkOrder: 1201417

EPA Method: SW8081A Extraction: SW3510C Spiked Sample ID: N/A

Sample Spiked MS MSD MS-MSD LCS Acceptance Criteria (%) Analyte µg/L µg/L % Rec. % Rec. % RPD % Rec. MS / MSD RPD LCS

Aldrin N/A 0.50 N/A N/A N/A 109 N/A N/A 70 - 130 g-BHC N/A 0.50 N/A N/A N/A 90.6 N/A N/A 70 - 130 p,p-DDT N/A 1.25 N/A N/A N/A 76.3 N/A N/A 70 - 130 Dieldrin N/A 1.25 N/A N/A N/A 100 N/A N/A 70 - 130 Endrin N/A 1.25 N/A N/A N/A 101 N/A N/A 70 - 130 Heptachlor N/A 0.50 N/A N/A N/A 102 N/A N/A 70 - 130 %SS: N/A 1.25 N/A N/A N/A 87 N/A N/A 70 - 130 All target compounds in the Method Blank of this extraction batch were ND less than the method RL with the following exceptions: NONE

BATCH 64120 SUMMARY Lab ID Date Sampled Date Extracted Date Analyzed Lab ID Date Sampled Date Extracted Date Analyzed 1201417-008B 01/13/12 01/18/12 01/19/12 8:21 PM 1201417-009B 01/13/12 01/18/12 01/19/12 7:24 PM

MS = Matrix Spike; MSD = Matrix Spike Duplicate; LCS = Laboratory Control Sample; LCSD = Laboratory Control Sample Duplicate; RPD = Relative Percent Deviation.

% Recovery = 100 * (MS-Sample) / (Amount Spiked); RPD = 100 * (MS - MSD) / ((MS + MSD) / 2).

N/A = not enough sample to perform matrix spike and matrix spike duplicate.

NR = matrix interference and/or analyte concentration in sample exceeds spike amount for soil matrix or exceeds 2x spike amount for water matrix or sample diluted due to high matrix or analyte content.

DHS ELAP Certification 1644 QA/QC Officer

Page 12 of 14 1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected]

QC SUMMARY REPORT FOR 6010B

W.O. Sample Matrix: Soil QC Matrix: Soil BatchID: 64078 WorkOrder: 1201417

EPA Method: SW6010B Extraction: SW3050B Spiked Sample ID: 1201369-053A

Sample Spiked MS MSD MS-MSD LCS Acceptance Criteria (%) Analyte mg/Kg mg/Kg % Rec. % Rec. % RPD % Rec. MS / MSD RPD LCS

Lead 10 50 93.1 98 4.22 105 75 - 125 25 75 - 125 %SS: 104 500 95 99 4.42 97 70 - 130 20 70 - 130 All target compounds in the Method Blank of this extraction batch were ND less than the method RL with the following exceptions: NONE

BATCH 64078 SUMMARY Lab ID Date Sampled Date Extracted Date Analyzed Lab ID Date Sampled Date Extracted Date Analyzed 1201417-001A 01/13/12 01/18/12 01/19/12 12:57 PM 1201417-005A 01/13/12 01/18/12 01/19/12 12:59 PM 1201417-007A 01/12/12 01/18/12 01/19/12 1:01 PM

MS = Matrix Spike; MSD = Matrix Spike Duplicate; LCS = Laboratory Control Sample; LCSD = Laboratory Control Sample Duplicate; RPD = Relative Percent Deviation.

% Recovery = 100 * (MS-Sample) / (Amount Spiked); RPD = 100 * (MS - MSD) / ((MS + MSD) / 2).

N/A = not applicable to this method.

NR = analyte concentration in sample exceeds spike amount for soil matrix or exceeds 2x spike amount for water matrix or sample diluted due to high matrix or analyte content.

DHS ELAP Certification 1644 QA/QC Officer

Page 13 of 14 1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected]

QC SUMMARY REPORT FOR E200.8

W.O. Sample Matrix: Water QC Matrix: Water BatchID: 64080 WorkOrder: 1201417

EPA Method: E200.8 Extraction: E200.8 Spiked Sample ID: 1201141-008A

Sample Spiked MS MSD MS-MSD LCS Acceptance Criteria (%) Analyte µg/L µg/L % Rec. % Rec. % RPD % Rec. MS / MSD RPD LCS

Lead ND 50 91.6 90.5 1.14 90.1 70 - 130 20 85 - 115 %SS: 103 750 102 100 1.63 98 70 - 130 20 70 - 130 All target compounds in the Method Blank of this extraction batch were ND less than the method RL with the following exceptions: NONE

BATCH 64080 SUMMARY Lab ID Date Sampled Date Extracted Date Analyzed Lab ID Date Sampled Date Extracted Date Analyzed 1201417-008A 01/13/12 01/18/12 01/19/12 3:03 PM 1201417-009A 01/13/12 01/18/12 01/19/12 3:09 PM

MS = Matrix Spike; MSD = Matrix Spike Duplicate; LCS = Laboratory Control Sample; LCSD = Laboratory Control Sample Duplicate; RPD = Relative Percent Deviation.

% Recovery = 100 * (MS-Sample) / (Amount Spiked); RPD = 100 * (MS - MSD) / ((MS + MSD) / 2).

N/A = not applicable to this method.

NR = analyte concentration in sample exceeds spike amount for soil matrix or exceeds 2x spike amount for water matrix or sample diluted due to high matrix or analyte content.

DHS ELAP Certification 1644 QA/QC Officer

Page 14 of 14

ECON Client Project ID: NUSD; Pb/OCP Sampling Date Sampled: 01/12/12

Date Received: 01/13/12 241 South Main Street Client Contact: Andy Rodgers Date Reported: 02/03/12

Sebastopol, CA 95472 Client P.O.: Date Completed: 02/03/12

WorkOrder: 1201339 A

February 06, 2012

Dear Andy:

Enclosed within are:

1) The results of the 4 analyzed samples from your project: NUSD; Pb/OCP Sampling, 2) QC data for the above samples, and 3) A copy of the chain of custody.

Best regards,

Angela Rydelius Laboratory Manager McCampbell Analytical, Inc.

The analytical results relate only to the items tested.

Page 1 of 10

Page 2 of 10 Page 3 of 10 Page 4 of 10 Page 5 of 10 Page 6 of 10 Page 7 of 10

McCampbell Analytical, Inc. Page 1 of 1 1534 Willow Pass Rd CHAIN-OF-CUSTODY RECORD Pittsburg, CA 94565-1701 (925) 252-9262 WorkOrder: 1201339 A ClientCode: ECON WaterTrax WriteOn EDF Excel Fax Email HardCopy ThirdParty J-flag

Report to: Bill to: Requested TAT: 5 days Andy Rodgers Email: [email protected]; [email protected] Andy Rodgers Date Received: 01/13/2012 ECON cc: ECON 241 South Main Street PO: 241 South Main Street Date Add-On: 01/30/2012 Sebastopol, CA 95472 ProjectNo: NUSD; Pb/OCP Sampling Sebastopol, CA 95472 Date Printed: 01/30/2012 (707) 789-0262 FAX: 707-823-8725

Requested Tests (See legend below) Lab ID Client ID Matrix Collection Date Hold 1 2 3 4 5 6 7 8 9 10 11 12

1201339-001 EB-17S Pb/OCP Soil 1/12/2012 A 1201339-003 EB-18S Pb/OCP Soil 1/12/2012 A 1201339-005 EB-19S Pb/OCP Soil 1/12/2012 A 1201339-007 EB-20S Pb/OCP Soil 1/12/2012 A

Test Legend:

1 8081_S 2 3 4 5 6 7 8 9 10 11 12

Prepared by:

Comments: 8081 added to #001, 003, 005, 007 on a std TAT. 1/30/12.

Page 8 of 10 1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected] ECON Client Project ID: NUSD; Pb/OCP Date Sampled: 01/12/12 Sampling Date Received: 01/13/12 241 South Main Street Client Contact: Andy Rodgers Date Extracted: 01/30/12 Sebastopol, CA 95472 Client P.O.: Date Analyzed: 01/30/12-02/02/12 Organochlorine Pesticides by GC-ECD (8080 Basic Target List)* Extraction Method: SW3550B Analytical Method: SW8081A Work Order: 1201339 Lab ID 1201339-001A 1201339-003A 1201339-005A 1201339-007A Reporting Limit for Client ID EB-17S Pb/OCP EB-18S Pb/OCP EB-19S Pb/OCP EB-20S Pb/OCP DF =1

Matrix S S S S S W DF 10 200 10 10 Compound Concentration mg/kg µg/L Aldrin ND<0.010 ND<0.20 ND<0.010 ND<0.010 0.001 NA a-BHC ND<0.010 ND<0.20 ND<0.010 ND<0.010 0.001 NA b-BHC ND<0.010 ND<0.20 ND<0.010 ND<0.010 0.001 NA d-BHC ND<0.010 ND<0.20 ND<0.010 ND<0.010 0.001 NA g-BHC ND<0.010 ND<0.20 ND<0.010 ND<0.010 0.001 NA Chlordane (Technical) ND<0.25 ND<5.0 0.55 ND<0.25 0.025 NA a-Chlordane ND<0.010 ND<0.20 0.089 0.013 0.001 NA g-Chlordane ND<0.010 ND<0.20 0.058 ND<0.010 0.001 NA p,p-DDD ND<0.010 ND<0.20 ND<0.010 ND<0.010 0.001 NA p,p-DDE ND<0.010 ND<0.20 ND<0.010 ND<0.010 0.001 NA p,p-DDT ND<0.010 ND<0.20 ND<0.010 ND<0.010 0.001 NA Dieldrin ND<0.010 ND<0.20 ND<0.010 ND<0.010 0.001 NA Endosulfan I ND<0.010 ND<0.20 ND<0.010 ND<0.010 0.001 NA Endosulfan II ND<0.010 ND<0.20 ND<0.010 ND<0.010 0.001 NA Endosulfan sulfate ND<0.010 ND<0.20 ND<0.010 ND<0.010 0.001 NA Endrin ND<0.010 ND<0.20 ND<0.010 ND<0.010 0.001 NA Endrin aldehyde ND<0.010 ND<0.20 ND<0.010 ND<0.010 0.001 NA Endrin ketone ND<0.010 ND<0.20 ND<0.010 ND<0.010 0.001 NA Heptachlor ND<0.010 ND<0.20 ND<0.010 ND<0.010 0.001 NA Heptachlor epoxide ND<0.010 ND<0.20 0.017 ND<0.010 0.001 NA Hexachlorobenzene ND<0.10 ND<2.0 ND<0.10 ND<0.10 0.01 NA Hexachlorocyclopentadiene ND<0.20 ND<4.0 ND<0.20 ND<0.20 0.02 NA Methoxychlor ND<0.010 ND<0.20 ND<0.010 ND<0.010 0.001 NA Toxaphene ND<0.50 ND<10 ND<0.50 ND<0.50 0.05 NA Surrogate Recoveries (%) %SS: 94 90 97 97 Comments a3 a3 * water samples in µg/L, soil/sludge/solid samples in mg/kg, wipe samples in µg/wipe, filter samples in µg/filter, product/oil/non-aqueous liquid samples and all TCLP & SPLP extracts are reported in mg/L.

ND means not detected above the reporting limit/method detection limit; N/A means analyte not applicable to this analysis; %SS = Percent Recovery of Surrogate Standard; DF = Dilution Factor.

# surrogate diluted out of range or surrogate coelutes with another peak/sample contains surrogate. a3) sample diluted due to high organic content.

DHS ELAP Certification 1644 Angela Rydelius, Lab Manager Page 9 of 10 1534 Willow Pass Road, Pittsburg, CA 94565-1701 McCampbell Analytical, Inc. Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269 "When Quality Counts" http://www.mccampbell.com / E-mail: [email protected]

QC SUMMARY REPORT FOR SW8081A

W.O. Sample Matrix: Soil QC Matrix: Soil BatchID: 64391 WorkOrder: 1201339

EPA Method: SW8081A Extraction: SW3550B Spiked Sample ID: 1201369-026A

Sample Spiked MS MSD MS-MSD LCS Acceptance Criteria (%) Analyte mg/kg mg/kg % Rec. % Rec. % RPD % Rec. MS / MSD RPD LCS

Aldrin ND<0.01 0.020 NR NR NR 109 N/A N/A 70 - 130 g-BHC ND<0.01 0.020 NR NR NR 95.6 N/A N/A 70 - 130 p,p-DDT ND<0.01 0.050 NR NR NR 93.6 N/A N/A 70 - 130 Dieldrin ND<0.01 0.050 NR NR NR 103 N/A N/A 70 - 130 Endrin ND<0.01 0.050 NR NR NR 89.9 N/A N/A 70 - 130 Heptachlor ND<0.01 0.020 NR NR NR 112 N/A N/A 70 - 130 %SS: 95 0.050 NR NR NR 86 N/A N/A 70 - 130 All target compounds in the Method Blank of this extraction batch were ND less than the method RL with the following exceptions: NONE

BATCH 64391 SUMMARY Lab ID Date Sampled Date Extracted Date Analyzed Lab ID Date Sampled Date Extracted Date Analyzed 1201339-001A 01/12/12 01/30/12 02/02/12 11:00 AM 1201339-003A 01/12/12 01/30/12 02/02/12 11:57 AM 1201339-005A 01/12/12 01/30/12 02/02/12 12:53 PM 1201339-007A 01/12/12 01/30/12 01/30/12 11:45 PM

MS = Matrix Spike; MSD = Matrix Spike Duplicate; LCS = Laboratory Control Sample; LCSD = Laboratory Control Sample Duplicate; RPD = Relative Percent Deviation.

% Recovery = 100 * (MS-Sample) / (Amount Spiked); RPD = 100 * (MS - MSD) / ((MS + MSD) / 2).

# surrogate diluted out of range or surrogate coelutes with another peak

N/A = not enough sample to perform matrix spike and matrix spike duplicate.

DHS ELAP Certification 1644 QA/QC Officer

Page 10 of 10

Attachment D Technical Memorandum with Statistical Analysis

TECHNICAL MEMORANDUM

Date: June 27, 2012 Prepared for: Neal Hutchison, Project Manager, DTSC Eric Sciullo, Associate Toxicologist, DTSC Prepared by: Christina Kennedy and Andy Rodgers, ECON On behalf of: Mark Silva, Novato Unified School District

Regarding: Summary of Statistical Analyses for Lead in Soil for Novato Unified School District

Project: PBC Parcel 1, Former Department of Defense Housing Facility Novato, California ______

ECON performed statistical analyses on the lead in soil data collected at the former Hamilton Air Force Base property presently owned by the Novato Unified School District. ECON completed an initial evaluation of the data and found that it did not display a normal distribution and concluded that an Upper Confidence Level (UCL) for the lead could not be calculated. This information was provided to the State of California Department of Toxic Substances Control (DTSC) on May 31, 2012 by e-mail. DTSC responded by e-mail that same day and suggested that a UCL could be calculated, disregarding the lack of normality of the data. They used the United States Environmental Protection Agency (EPA) statistical software ProUCL 4.0 to do some rough analyses and suggested that by eliminating “lead hot spots” it might be possible to calculate a UCL that was below the DTSC lead standard for schools of 80 mg/kg.

ECON analyzed the data using ProUCL 4.1. Initially ECON analyzed the full set of data (excluding all composite samples). As anticipated, the presence of a few very high concentrations resulted in a 95% Chebyshev UCL of 118.8 which exceeds the 80 mg/kg standard. A second iteration was performed in which the highest data point of 750 mg/kg was eliminated resulting in a 95% Chebyshev UCL of 90.77 which still exceeds 80 mg/kg. ECON then eliminated all samples with concentrations at 250 mg/kg or higher (total 5 samples) and the result was a 95% Chebyshev UCL of 62.21.

The locations of three of the five highest samples are clustered near the skid-mounted shed south of Building 969 (Plates 1 and 2). One of the five samples (with a lead concentration of 270 mg/kg), was located at the back of Building 969 on the west side (EB-51). The fifth sample was located south of Building 972 (EB-38), but step out sampling did not confirm the initial result. All of the highest lead concentrations occur in the upper six inches of soil. It may be possible to complete a limited soil removal in the area of the skid mounted shed and remediate any concern

______

241 South Main Street, Sebastopol, California 95472 -- Tel 707-823-2324 -- Fax 707-921-7409

Neal Hutchison and Eric Sciullo Summary of Statistical Analyses for Lead in Soil Hamilton AFB Parcel 1, Novato, CA June 27, 2012

regarding lead in soil at the site. The question however is whether or not the areas east of Building 969 and south of Building 972 also should be remediated.

To evaluate whether or not this would be necessary ECON ran the analysis including the data from south of Building 972 (EB-38) which returned a 95% Chebyshev UCL of 70.42, which is still below the standard of 80 mg/kg. Then ECON ran the analysis with the sample from east of Building 969 (EB-51) added back in, and the analysis returned a 95% Chebyshev UCL of 76.75, which is also below the 80 mg/kg standard.

Attached to this memorandum are the output sheets from the five statistical analyses completed using ProUCL 4.1. This data along with a site plan showing the locations of the soil samples and the lead data could be used to develop “next steps” for the site, to be approved by the DTSC. Please feel free to contact ECON if you have any questions or would like to discuss the information presented in this memorandum further.

Chris Kennedy P.G.

c: Mark Silva, NUSD

Attachments: Plate 1: Initial Analytical Results for Lead in Soil Plate 2: Step-Out Analytical Results for Lead in Soil ProUCL 4.1 Output Sheets

Page 2 of 2

!( 14 !( EB-20 9.4 EB-19

971 EB-18 !( 180 !( EB-21 8.7

EB-17 !( 11

EB-22 !( 15, 21d

!( EB-16 62 EB-15 !( 39 39 954 !( EB-14 EB-13 41 14 !( 960 !( EB-12 *# EB-33 12 34 EB-11 !( *# 35 EB-23 35 !( EB-10 11 !( 88 EB-9 51 955 18 21 20 49.88 !( !( !( !( EB-35 EB-1 EB-2 EB-24 !( 965 !( EB-3 EB-4 76 8.9 EB-30 928 8.8 !( EB-34 *# ND !( !( !( 13 !( EB-36 !( EB-8 EB-7 EB-6 EB-7 EB-5 957 19 19 15 32 23 EB-29*# 23 969 130 46,240d !( 958 EB-25

!( 750* EB-27 EB-26 *# 15 930 !( EB-32 EB-28 32 *# 130 !( 972 38 EB-31

973 290* 973 *# EB-38 EB-38 *# EB-37 75

EXPLANATION 290 Concentration of analytes at or above ESL (mg/kg) 75 Concentration of analytes above reporting limit (mg/kg) 0 50 100 Duplicated Analytical Result Eliminated from Statistical Analysis Scale in Feet *# Sample Location in Asphalt Depression ¨ !( Sample Location in Exposed Soil Approximate post-demolition sample grid based on field reconnaissance Initial Analytical Results for Lead in Soil Plate Novato Unified School District Hamilton Air Force Base, Parcel 1, Novato, California 1 965

0" - 11 EB-52 12" - 7.2 ") 0" - 270* 969 12" - 9.7 EB-51 ") 12" - 10 EB-25 !( ") EB-50 ") 0" - 9.7 0" - 70 EB-49 12" - 7.4 12" - 11 0" - 25 EB-48 ") 12" - 6.2 0" - 54 Shed EB-47 Shed ") 12" - 6.8 12" - 9.1 EB-26 !( ") EB-46 0" - 240 ") ") EB-45 12" - 6.9 EB-44 0" - 360* 0" - 250* 12" - 72 12" - 5.9

972

12" - 12 ") EB-38 EB-42 ") !( ") EB-40 EB-43 ") 3" - 15 ") 3" - 8.4 3" - 17 3" - 15 EB-41 12" - 7.3 EB-39 12" - 18 12" - 7.9 12" - 7.3 3" - 8.6 0" - 7.4 12" - 6.5 12" - 7.4

EXPLANATION Concentration of analyte at or above ESL (mg/kg) 360 0 25 50 72 Concentration of analyte above reporting limit (mg/kg) * Analytical Result Eliminated from Statistical Analysis ") Step-Out Sample Location Scale in Feet ¨ !( Step-Down Sample Location Approximate post-demolition sample grid based on field reconnaissance Step-Out Analytical Results for Lead in Soil Plate Novato Unified School District Hamilton Air Force Base, Parcel 1, Novato, California 2 Nonparametric UCL Statistics for Full Data User Selected Options From File Z:\CKG\CKG\Active Clients\ECON, INC\NUSD\Statistical Analysis for Lead\lnitial analysis.wst Full Precision OFF Confidence Coefficient 95% Number of Bootstrap Operations 2000

Number of Valid Observations 71 Number of Distinct Observations 55 Minimum 5.9 Maximum 750 Mean 60.34 Geometric Mean 25.07 Median 18 SO 113.1 Variance 12786 Std. Error of Mean 13.42 Coefficient of Variation 1.874 Skewness 3.985 Mean of log data 3.222 SO of log data 1.195

Data do not follow a Discernable Distribution

95% Useful UCLs Student's-t UCL 82.71

95% UCLs (Adjusted for Skewness) 95% Adjusted-CLT UCL (Chen-1995) 89.19 95% Modified-t UCL (Johnson-1978) 83.77

Non-Parametric UCLs 95% CLT UCL 82.41 95% Jackknife UCL 82.71 95% Standard Bootstrap UCL 82.07 95% Bootstrap-t UCL 96.37 95% Hall's Bootstrap UCL 103.5 95% Percentile Bootstrap UCL 83.08 95% SCA Bootstrap UCL 90.26 95% Chebyshev(Mean, Sd) UCL 118.8 97.5% Chebyshev(Mean, Sd) UCL 144.1 99% Chebyshev(Mean, Sd) UCL 193.9

Potential UCL to Use Use 95% Chebyshev (Mean, Sd) UCL 118.8 Nonparametric Sets User Selected Options From File Z:\CKG\CKG\Active Clients\ECON, INC\NUSD\Statistical Analysis for Lead\lnitial analysis.wst Full Precision OFF Confidence Coefficient 95% Number of Bootstrap Operations 2000

Number of Valid Observations 70 Number of Distinct Observations 54 Minimum 5.9 Maximum 360 Mean 50.49 Geometric Mean 23.88 Median 17.5 SD 77.33 Variance 5980 Std. Error of Mean 9.242 Coefficient of Variation 1.532 Skewness 2.459 Mean of log data 3.173 SD of log data 1.13

Data do not follow a Discernable Distribution

95% Useful UCLs Student's-t UCL 65.9

95% UCLs (Adjusted for Skewness) 95% Adjusted-CLT UCL (Chen-1995) 68.59 95% Modified-t UCL (Johnson-1978) 66.35

Non-Parametric UCLs 95% CLT UCL 65.69 95% Jackknife UCL 65.9 95% Standard Bootstrap UCL 65.66 95% Bootstrap-t UCL 70.27 95% Hall's Bootstrap UCL 67.87 95% Percentile Bootstrap UCL 66.38 95% BCA Bootstrap UCL 68.89 95% Chebyshev(Mean, Sd) UCL 90.77 97.5% Chebyshev(Mean, Sd) UCL 108.2 99% Chebyshev(Mean, Sd) UCL 142.4

Potential UCL to Use Use 95% Chebyshev (Mean, Sd) UCL 90.77 Nonpararnetric Full User Selected Options From File Z:\CKG\CKG\Active Clients\ECON, INC\NUSD\Statistical Analysis for Lead\lnitial analysis.wst Full Precision OFF Confidence Coefficient 95% Number of Bootstrap Operations 2000

Number of Valid Observations 66 Number of Distinct Observations 50 Minimum 5.9 Maximum 240 Mean 35.82 Geometric Mean 20.53 Median 15 SO 49.18 Variance 2419 Std. Error of Mean 6.054 Coefficient of Variation 1.373 Skewness 2.858 Mean of log data 3.022 SO of log data 0.974

Data do not follow a Discernable Distribution

95% Useful UCLs Student's-t UCL 45.92

95% UCLs (Adjusted for Skewness) 95% Adjusted-CLT UCL (Chen-1995) 48.05 95% Modified-t UCL (Johnson-1978) 46.28

Non-Parametric UCLs 95% CLT UCL 45.78 95% Jackknife UCL 45.92 95% Standard Bootstrap UCL 45.52 95% Bootstrap-t UCL 49.94 95% Hall's Bootstrap UCL 48.01 95% Percentile Bootstrap UCL 46.34 95% BCA Bootstrap UCL 47.37 95% Chebyshev(Mean, Sd) UCL 62.21 97.5% Chebyshev(Mean, Sd) UCL 73.63 99% Chebyshev(Mean, Sd) UCL 96.06

Potential UCL to Use Use 95% Chebyshev (Mean, Sd) UCL 62.21

Attachment E Waste Manifest

Attachment F Oaks Environmental Testing Analytical Report

Attachment G Statistical Analysis

Statistical Analysis for Post Remediation Lead Data Hamilton Air Force Base Parcels 1A and 1B

Primary Data Distribution of Primary Data Distribution of Lognormal Data Sample # Date Sampled Pb mg/kg LNBIN LN BIN EB-1S Pb/OCP 1/11/2012 51 3.93182563 7.2 10 9 3.93 1.97 1 0.00 EB-2S Pb/OCP 1/11/2012 18 2.89037176 7.4 20 18 2.89 2.00 1.5 1.00 EB-3S Pb/OCP 1/11/2012 21 3.04452244 7.4 30 4 3.04 2.00 2 2.00 EB-4S Pb/OCP 1/11/2012 20 2.99573227 8.4 40 9 3.00 2.13 2.5 9.00 EB-5S Pb/OCP 1/11/2012 23 3.13549422 8.7 50 2 3.14 2.16 3 14.00 EB-6S Pb/OCP 1/11/2012 32 3.4657359 8.8 60 1 3.47 2.17 3.5 7.00 EB-7S Pb/OCP 1/11/2012 15 2.7080502 8.9 70 1 2.71 2.19 4 9.00 EB-8S Pb/OCP 1/11/2012 19 2.94443898 9.4 80 2 2.94 2.24 4.5 7.00 EB-8S Pb-Dup 1/13/2012 30 3.40119738 9.5 90 1 3.40 2.25 5 3.00 EB-9S Pb/OCP 1/11/2012 49.88 3.90962012 11 100 0 3.91 2.40 5.5 1.00 EB-10S Pb/OCP 1/11/2012 88 4.47733681 11 110 0 4.48 2.40 6 0.00 EB-11S Pb/OCP 1/11/2012 35 3.55534806 11 120 0 3.56 2.40 6.5 0.00 EB-12S Pb/OCP 1/11/2012 12 2.48490665 12 130 2 2.48 2.48 EB-13S Pb/OCP 1/11/2012 14 2.63905733 13 140 0 2.64 2.56 EB-14S Pb/OCP 1/11/2012 41 3.71357207 13 150 0 3.71 2.56 EB-15S Pb/OCP 1/11/2012 39 3.66356165 13 160 0 3.66 2.56 EB-16S Pb/OCP 1/11/2012 62 4.12713439 14 170 0 4.13 2.64 EB-17S Pb/OCP 1/12/2012 11 2.39789527 14 180 1 2.40 2.64 EB-18S Pb/OCP 1/12/2012 180 5.19295685 15 5.19 2.71 EB-19S Pb/OCP 1/12/2012 9.4 2.24070969 15 2.24 2.71 EB-20S Pb/OCP 1/12/2012 14 2.63905733 15 2.64 2.71 EB-21S Pb/OCP 1/12/2012 8.7 2.16332303 17 2.16 2.83 EB-22S Pb/OCP 1/12/2012 15 2.7080502 18 2.71 2.89 EB-22S Pb-Dup 1/13/2012 21 3.04452244 18 3.04 2.89 EB-23S Pb/OCP 1/12/2012 11 2.39789527 19 2.40 2.94 EB-24S Pb/OCP 1/12/2012 76 4.33073334 19 4.33 2.94 EB-27S Pb/OCP 1/13/2012 15 2.7080502 19 2.71 2.94 EB-28S Pb/OCP 1/13/2012 130 4.86753445 20 4.87 3.00 EB-29S Pb/OCP 1/13/2012 130 4.86753445 21 4.87 3.04 EB-31S Pb 1/12/2012 38 3.63758616 21 3.64 3.04 EB-32S Pb/OCP 1/12/2012 32 3.4657359 23 3.47 3.14 EB-33S Pb/OCP 1/12/2012 34 3.52636052 30 3.53 3.40 EB-34S Pb/OCP 1/12/2012 8.8 2.17475172 32 2.17 3.47 EB-35S Pb/OCP 1/12/2012 8.9 2.18605128 32 2.19 3.47 EB-36S Pb/OCP 1/12/2012 13 2.56494936 34 2.56 3.53 EB-37S Pb/OCP 1/13/2012 75 4.31748811 35 4.32 3.56 EB-39-0 5/4/2012 7.4 2.00148 38 2.00 3.64 EB-39-12 5/4/2012 7.4 2.00148 39 2.00 3.66 EB-43-2 5/4/2012 8.4 2.12823171 41 2.13 3.71 EB-43-12 5/4/2012 18 2.89037176 49.88 Mean 34.76380952 2.89 3.91 EB-52-0 5/4/2012 11 2.39789527 51 2.40 3.93 EB-52-12 5/4/2012 7.2 1.97408103 62 Lognormal 3.083664854 1.97 4.13 35-969-01S 2/14/2013 13 2.56494936 75 Mean 2.56 4.32 35-Shed-02S 2/14/2013 19 2.94443898 76 2.94 4.33 35-Shed-03S 2/14/2013 13 2.56494936 88 2.56 4.48 35-Shed-04S 2/14/2013 9.5 2.2512918 130 2.25 4.87 35-972-05S 2/14/2013 19 2.94443898 130 2.94 4.87 35-972-06S 2/14/2013 17 2.83321334 180 2.83 5.19

Page 1 of 3 Statistical Analysis for Post Remediation Lead Data Hamilton Air Force Base Parcels 1A and 1B

Lead Statistical Analysis Lead Frequency Diagram Total Samples Considered 48 20 Frequency of Detection 48/48 15

Minimum 7.2 10 Series1 5 Maximum 180 0 Average/Mean of LN value 3.08 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18

Ln 95% UCL 4.34

95% UCL 76.7075393 lognormal Lead Frequency Diagram 15.00

LN Mean: 3.08 LN Stdev: 0.83 10.00 UCL 95%: 0.23 Series1 5.00 Inverse log of UCL: 1.26 0.00 1 2 3 4 5 6 7 8 9 10 11 12 13

Page 2 of 3 Nonparametric UCL Statistics for Full Data Sets Hamilton Air Force Base Parcels 1A and 1B

User Selected Options Full Precision: OFF Confidence Coeffcient: 95% Number of Bootstrap Operations: 2000

Number of Valid Observations 48 Number of Distinct Observations 34 Minimum 7.2 Maximum 180 Mean 32.3 Geometric Mean 21.84 Median 18.50 SD 35.94 Variance 1292 Std. Error of Mean 5.188 Coeffceint of Variation 1.113 Skewness 2.5 Mean of log data 3.084 SD of log data 0.827

Data do not follow a Discernable Distribution

95% Useful UCLs Student's-UCL 41.01

95% Useful UCLs (adjusted for Skewness) 95% Adjusted-CLT UCL (Chen-1995) 42.84 95% Modified-t UCL (Johnson-1978) 41.32

Non-Parametric UCLs 95% CLT UCL 40.84 95% Jackknife UCL 41.01 95% Standard Bootstrap UCL 40.49 95% Bootstrap-t UCL 44.8 95% Hall's Bootsrap UCL 43.71 95% Percentile Bootsrap UCL 41.15 95% BCA Bootstrap UCL 42.52 95% Chebshev(Mean, Sd) UCL 54.92 97.5% Chebshev(Mean, Sd) UCL 64.7 99% Chebshev(Mean, Sd) UCL 83.92

Potential UCL to Use Use 95% Chebychev (mean, Sd) UCL 54.92

Note: Suggestions regarding the selection of a 95% UCL are proivded to help the user to select the most apporpriate 95% UCL. These recommendations are based upon the results of the simulation studies summarized in Singh, Singh, and laci (2002) and Singh and Singh (2003). For additional insight, the use may want to consult a statistician.

Page 3 of 3

Appendix C

Covenants to Restrict Use of Property

Appendix D

Johnson Ettinger (J&E) Output Data for Soil Gas and Groundwater

Table 1: Summary of Soil Gas Toxicities Hamilton Air Force Base Parcels 1A and 1B

Maximum Concentration 3 Chemical (µg/m ) Cal-EPA Toxicity Cal-EPA Toxicity Risk Hazard % risk %haz 1,1-Dichloroethene 6.20E+00 NA 1.20E-04 0.0% 1,2,4-Trimethylbenzene 6.10E+02 NA 9.80E-02 3.5% 1,3,5-Trimethylbenzene 2.40E+02 NA 4.50E-02 1.6% 1,3-Butadiene 1.30E+01 6.20E-07 2.40E-02 6.0% 0.9% Acetone 4.20E+02 NA 2.10E-05 0.0% Benzene 1.80E+02 1.60E-06 1.60E-02 15.5% 0.6% cis-1,2-Dichloroethene 4.20E+03 NA 1.50E-01 5.4% Ethylbenzene 3.20E+02 4.30E-07 4.00E-04 4.2% 0.0% Isopropylbenzene 3.80E+01 NA 1.11E-04 0.0% m,p-Xylenes 1.50E+02 NA 1.60E-02 0.6% Methyl-t-butyl ether (MTBE) 1.50E+04 2.40E-06 7.20E-03 23.2% 0.3% o-Xylene 8.30E+01 NA 5.90E-03 0.2% Toluene 9.00E+01 NA 7.60E-03 0.3% trans-1,2-Dichloroethene 2.90E+02 NA 5.90E-03 0.2% Trichloroethene 6.90E+02 3.10E-06 8.90E-01 29.9% 31.8% 2,2,4-Trimethylpentane 4.00E+06 NA NA 2-Butanone 7.90E+01 NA 2.00E-05 0.0% 4-Ethyltoluene 6.70E+02 NA NA Carbon Disulfide 2.20E+02 NA 4.50E-04 Cyclohexane 2.70E+05 NA 1.10E-01 3.9% Heptane 1.30E+05 NA NA Hexane 5.50E+05 NA 1.40E+00 50.0% n-Propylbenzene 1.10E+02 NA 8.82E-04 0.0% sec-Butylbenzene 5.74E+01 NA 4.50E-04 0.0% Styrene 2.80E+01 NA 3.80E-05 0.0% Tetrahydrofuran 1.30E+04 NA NA Vinyl chloride 4.10E+02 2.20E-06 1.20E-02 21.3% 0.4% 2-Propanol 2.00E+01 NA NA Bromomethane 4.10E+01 NA 1.00E-02 0.4% Ethanol 6.20E+01 NA NA Freon 11 1.40E+01 NA 2.70E-05 0.0% Freon 12 1.90E+01 NA 1.10E-04 0.0% Methylene chloride 4.60E+00 2.80E-09 1.60E-05 0.0% 0.0% 4-Methyl-2-Pentanone 2.10E+01 NA 8.80E-06 0.0%

Total: 1.04E-05 2.80E+00 100.0% 100% DATA ENTRY SHEET: MTBE

GW-SCREEN CALCULATE RISK-BASED GROUNDWATER CONCENTRATION (enter "X" in "YES" box) Version 3.1; 02/04 YES Reset to OR Defaults CALCULATE INCREMENTAL RISKS FROM ACTUAL GROUNDWATER CONCENTRATION (enter "X" in "YES" box and initial groundwater conc. below)

YES X

ENTER ENTER Initial Chemical groundwater CAS No. conc.,

(numbers only, CW no dashes) (µg/L) Chemical

1634044 1.00E+02 MTBE

ENTER ENTER ENTER ENTER MORE Depth  below grade Average ENTER to bottom Depth soil/ Average vapor of enclosed below grade SCS groundwater flow rate into bldg. space floor, to water table, soil type temperature, (Leave blank to calculate)

LF LWT directly above TS Qsoil o (cm) (cm) water table ( C) (L/m)

15 242.32 SL 19 5

MORE  ENTER ENTER Vadose zone User-defined ENTER ENTER ENTER ENTER SCS vandose zone Vadose zone Vadose zone Vadose zone Vadose zone soil type soil vapor SCS soil dry soil total soil water-filled (used to estimate OR permeability, soil type bulk density, porosity, porosity, V V V soil vapor kv Lookup Soil ρb n θw 2 Parameters 3 3 3 permeability) (cm ) (g/cm ) (unitless) (cm /cm )

3.10E-08 1.4 0.48 0.1

MORE  ENTER ENTER ENTER ENTER ENTER ENTER Target Target hazard Averaging Averaging risk for quotient for time for time for Exposure Exposure carcinogens, noncarcinogens, carcinogens, noncarcinogens, duration, frequency,

TR THQ ATC ATNC ED EF (unitless) (unitless) (yrs) (yrs) (yrs) (days/yr)

1.0E-06 1 70 30 30 350

Used to calculate risk-based groundwater concentration.

1 of 4 CHEMICAL PROPERTIES SHEET: MTBE ABC Henry's Henry's Enthalpy of Organic Pure law constant law constant vaporization at Normal carbon component Unit Diffusivity Diffusivity at reference reference the normal boiling Critical partition water risk Reference in air, in water, temperature, temperature, boiling point, point, temperature, coefficient, solubility, factor, conc.,

Da Dw HTR ∆Hv,b TB TC Koc S URF RfC 2 2 3 o o o 3 3 -1 3 (cm /s) (cm /s) (atm-m /mol) ( C) (cal/mol) ( K) ( K) (cm /g) (mg/L) (µg/m ) (mg/m )

1.02E-01 1.05E-05 6.23E-04 25 6,678 328.30 497.10 7.26E+00 5.10E+04 0.0E+00 3.0E+00

END

2 of 4 INTERMEDIATE CALCULATIONS SHEET: MTBE

Vadose Vadose zone Vadose zone Vadose zone Vadose zone Total Air-filled Water-filled Floor- Source- zone soil effective soil soil soil Thickness of porosity in porosity in porosity in wall building air-filled total fluid intrinsic relative air effective vapor capillary capillary capillary capillary seam separation, porosity, saturation, permeability, permeability, permeability, zone, zone, zone, zone, perimeter, V LT θa Ste ki krg kv Lcz ncz θa,cz θw,cz Xcrack 3 3 3 3 2 2 2 3 3 3 3 3 3 (cm) (cm /cm ) (cm /cm ) (cm ) (cm ) (cm ) (cm) (cm /cm ) (cm /cm ) (cm /cm ) (cm)

227.32 0.380 #N/A #N/A #N/A 3.10E-08 25.00 0.387 0.067 0.320 4,000

Area of Capillary Total enclosed Crack- Crack Enthalpy of Henry's law Henry's law Vapor Vadose zone zone overall Bldg. space to-total depth vaporization at constant at constant at viscosity at effective effective effective ventilation below area below ave. groundwater ave. groundwater ave. groundwater ave. soil diffusion diffusion diffusion rate, grade, ratio, grade, temperature, temperature, temperature, temperature, coefficient, coefficient, coefficient, eff eff eff Qbuilding AB η Zcrack ∆Hv,TS HTS H'TS µTS D V D cz D T 3 2 3 2 2 2 (cm /s) (cm ) (unitless) (cm) (cal/mol) (atm-m /mol) (unitless) (g/cm-s) (cm /s) (cm /s) (cm /s)

1.69E+04 1.00E+06 4.00E-04 15 7,179 4.86E-04 2.03E-02 1.78E-04 1.77E-02 1.63E-04 1.38E-03

Exponent of Infinite Average Crack equivalent source Infinite Diffusion Convection Source vapor effective foundation indoor source Unit path path vapor Crack flow rate diffusion Area of Peclet attenuation bldg. risk Reference length, length, conc., radius, into bldg., coefficient, crack, number, coefficient, conc., factor, conc., crack f Ld Lp Csource rcrack Qsoil D Acrack exp(Pe ) α Cbuilding URF RfC 3 3 2 2 3 3 -1 3 (cm) (cm) (µg/m ) (cm) (cm /s) (cm /s) (cm ) (unitless) (unitless) (µg/m )(µg/m ) (mg/m )

227.32 15 2.03E+03 0.10 8.33E+01 1.77E-02 4.00E+02 1.13E+51 3.34E-04 6.77E-01 NA 3.0E+00

3 of 4 RESULTS SHEET: MTBE

RISK-BASED GROUNDWATER CONCENTRATION CALCULATIONS: INCREMENTAL RISK CALCULATIONS:

Incremental Hazard Indoor Indoor Risk-based Pure Final risk from quotient exposure exposure indoor component indoor vapor from vapor groundwater groundwater exposure water exposure intrusion to intrusion to conc., conc., groundwater solubility, groundwater indoor air, indoor air, carcinogen noncarcinogen conc., S conc., carcinogen noncarcinogen (µg/L) (µg/L) (µg/L) (µg/L) (µg/L) (unitless) (unitless)

NA NA NA 5.10E+07 NA NA 2.2E-04

MESSAGE SUMMARY BELOW:

END

4 of 4 DATA ENTRY SHEET: 1,3-Butadiene

SG-SCREEN Version 3.1; 02/04 Soil Gas Concentration Data Reset to ENTER ENTER ENTER Defaults Soil Soil Chemical gas OR gas CAS No. conc., conc.,

(numbers only, Cg Cg 3 no dashes) (µg/m ) (ppmv) Chemical

106990 1.30E+01 1,3-Butadiene

ENTER ENTER ENTER ENTER ENTER Depth MORE below grade Soil gas Vadose zone User-defined  to bottom sampling Average SCS vadose zone of enclosed depth soil soil type soil vapor space floor, below grade, temperature, (used to estimate OR permeability,

LF Ls TS soil vapor kv o 2 (15 or 200 cm) (cm) ( C) permeability) (cm )

15 152.4 19 3.01E+00

ENTER ENTER ENTER ENTER ENTER MORE Vandose zone Vadose zone Vadose zone Vadose zone Average vapor  SCS soil dry soil total soil water-filled flow rate into bldg. soil type bulk density, porosity, porosity, (Leave blank to calculate) A V V Lookup Soil ρb n θw Qsoil Parameters 3 3 3 (g/cm ) (unitless) (cm /cm ) (L/m)

1.4 0.48 0.1 5

MORE  ENTER ENTER ENTER ENTER Averaging Averaging time for time for Exposure Exposure carcinogens, noncarcinogens, duration, frequency,

ATC ATNC ED EF (yrs) (yrs) (yrs) (days/yr)

70 30 30 350

END

1 o f 4 CHEMICAL PROPERTIES SHEET: 1,3-Butadiene

Henry's Henry's Enthalpy of law constant law constant vaporization at Normal Unit Diffusivity Diffusivity at reference reference the normal boiling Critical risk Reference Molecular in air, in water, temperature, temperature, boiling point, point, temperature, factor, conc., weight,

Da Dw HTR ∆Hv,b TB TC URF RfC MW 2 2 3 o o o 3 -1 3 (cm /s) (cm /s) (atm-m /mol) ( C) (cal/mol) ( K) ( K) (µg/m ) (mg/m ) (g/mol)

2.49E-01 1.08E-05 7.34E-02 25 5,370 268.60 425.00 3.0E-05 2.0E-03 54.09

END

2 of 4 INTERMEDIATE CALCULATIONS SHEET: 1,3-Butadiene

Vadose zone Vadose zone Vadose zone Vadose zone Vadose zone Floor- Source- soil effective soil soil soil wall Bldg. building air-filled total fluid intrinsic relative air effective vapor seam Soil ventilation separation, porosity, saturation, permeability, permeability, permeability, perimeter, gas rate, V LT θa Ste ki krg kv Xcrack conc. Qbuilding 3 3 3 3 2 2 2 3 3 (cm) (cm /cm ) (cm /cm ) (cm ) (cm ) (cm ) (cm) (µg/m ) (cm /s)

137.4 0.380 #N/A #N/A #N/A 3.01E+00 4,000 1.30E+01 1.69E+04

Area of Vadose enclosed Crack- Crack Enthalpy of Henry's law Henry's law Vapor zone space to-total depth vaporization at constant at constant at viscosity at effective Diffusion below area below ave. soil ave. soil ave. soil ave. soil diffusion path grade, ratio, grade, temperature, temperature, temperature, temperature, coefficient, length, eff AB η Zcrack ∆Hv,TS HTS H'TS µTS D V Ld 2 3 2 (cm ) (unitless) (cm) (cal/mol) (atm-m /mol) (unitless) (g/cm-s) (cm /s) (cm)

1.00E+06 4.00E-04 15 5,071 6.16E-02 2.57E+00 1.78E-04 4.31E-02 137.4

Exponent of Infinite Average Crack equivalent source Infinite Convection Source vapor effective foundation indoor source path vapor Crack flow rate diffusion Area of Peclet attenuation bldg. length, conc., radius, into bldg., coefficient, crack, number, coefficient, conc., crack f Lp Csource rcrack Qsoil D Acrack exp(Pe ) α Cbuilding 3 3 2 2 3 (cm) (µg/m ) (cm) (cm /s) (cm /s) (cm ) (unitless) (unitless) (µg/m )

15 1.30E+01 0.10 8.33E+01 4.31E-02 4.00E+02 9.92E+20 3.89E-03 5.05E-02

Unit risk Reference factor, conc., URF RfC (µg/m3)-1 (mg/m3)

3.0E-05 2.0E-03

END

3 of 4 RESULTS SHEET: 1,3-Butadiene

INCREMENTAL RISK CALCULATIONS:

Incremental Hazard risk from quotient vapor from vapor intrusion to intrusion to indoor air, indoor air, carcinogen noncarcinogen (unitless) (unitless)

6.2E-07 2.4E-02

MESSAGE SUMMARY BELOW:

END

JE Model 1,3-Butadiene 4 of 4 DATA ENTRY SHEET: Benzene

SG-SCREEN Version 3.1; 02/04 Soil Gas Concentration Data Reset to ENTER ENTER ENTER Defaults Soil Soil Chemical gas OR gas CAS No. conc., conc.,

(numbers only, Cg Cg 3 no dashes) (µg/m ) (ppmv) Chemical

71432 1.80E+02 Benzene

LF Ls TS soil vapor kv o 2 (15 or 200 cm) (cm) ( C) permeability) (cm )

15 152.4 19 3.01E+00

1.4 0.48 0.1 5

MORE  ENTER ENTER ENTER ENTER Averaging Averaging time for time for Exposure Exposure carcinogens, noncarcinogens, duration, frequency,

ATC ATNC ED EF (yrs) (yrs) (yrs) (days/yr)

70 30 30 350

END

1 of 4 CHEMICAL PROPERTIES SHEET: Benzene

Da Dw HTR ∆Hv,b TB TC URF RfC MW 2 2 3 o o o 3 -1 3 (cm /s) (cm /s) (atm-m /mol) ( C) (cal/mol) ( K) ( K) (µg/m ) (mg/m ) (g/mol)

8.80E-02 9.80E-06 5.54E-03 25 7,342 353.24 562.16 7.8E-06 3.0E-02 78.11

END

2 of 4 INTERMEDIATE CALCULATIONS SHEET: Benzene

137.4 0.380 #N/A #N/A #N/A 3.01E+00 4,000 1.80E+02 1.69E+04

1.00E+06 4.00E-04 15 8,030 4.19E-03 1.75E-01 1.78E-04 1.52E-02 137.4

15 1.80E+02 0.10 8.33E+01 1.52E-02 4.00E+02 2.57E+59 2.81E-03 5.05E-01

Unit risk Reference factor, conc., URF RfC (µg/m3)-1 (mg/m3)

7.8E-06 3.0E-02

END

3 of 4 RESULTS SHEET: Benzene

INCREMENTAL RISK CALCULATIONS:

Incremental Hazard risk from quotient vapor from vapor intrusion to intrusion to indoor air, indoor air, carcinogen noncarcinogen (unitless) (unitless)

1.6E-06 1.6E-02

MESSAGE SUMMARY BELOW:

END

JE Model Benzene 4 of 4 DATA ENTRY SHEET: TCE

SG-SCREEN Version 3.1; 02/04 Soil Gas Concentration Data Reset to ENTER ENTER ENTER Defaults Soil Soil Chemical gas OR gas CAS No. conc., conc.,

(numbers only, Cg Cg 3 no dashes) (µg/m ) (ppmv) Chemical

79016 6.90E+02 Trichloroethylene

LF Ls TS soil vapor kv o 2 (15 or 200 cm) (cm) ( C) permeability) (cm )

15 152.4 19 3.01E+00

1.4 0.48 0.1 5

MORE  ENTER ENTER ENTER ENTER Averaging Averaging time for time for Exposure Exposure carcinogens, noncarcinogens, duration, frequency,

ATC ATNC ED EF (yrs) (yrs) (yrs) (days/yr)

70 30 30 350

END

1 of 4 CHEMICAL PROPERTIES SHEET: TCE

Da Dw HTR ∆Hv,b TB TC URF RfC MW 2 2 3 o o o 3 -1 3 (cm /s) (cm /s) (atm-m /mol) ( C) (cal/mol) ( K) ( K) (µg/m ) (mg/m ) (g/mol)

7.90E-02 9.10E-06 1.03E-02 25 7,505 360.36 544.20 4.1E-06 2.0E-03 131.39

END

2 of 4 INTERMEDIATE CALCULATIONS SHEET: TCE

137.4 0.380 #N/A #N/A #N/A 3.01E+00 4,000 6.90E+02 1.69E+04

1.00E+06 4.00E-04 15 8,445 7.67E-03 3.20E-01 1.78E-04 1.37E-02 137.4

15 6.90E+02 0.10 8.33E+01 1.37E-02 4.00E+02 1.51E+66 2.68E-03 1.85E+00

Unit risk Reference factor, conc., URF RfC (µg/m3)-1 (mg/m3)

4.1E-06 2.0E-03

END

3 of 4 RESULTS SHEET: TCE

INCREMENTAL RISK CALCULATIONS:

Incremental Hazard risk from quotient vapor from vapor intrusion to intrusion to indoor air, indoor air, carcinogen noncarcinogen (unitless) (unitless)

3.1E-06 8.9E-01

MESSAGE SUMMARY BELOW:

MESSAGE: Risk/HQ or risk-based soil concentration is based on a route-to-route extrapolation.

END

JE Model TCE 4 of 4 DATA ENTRY SHEET: Vinyl Chloride

SG-SCREEN Version 3.1; 02/04 Soil Gas Concentration Data Reset to ENTER ENTER ENTER Defaults Soil Soil Chemical gas OR gas CAS No. conc., conc.,

(numbers only, Cg Cg 3 no dashes) (µg/m ) (ppmv) Chemical

75014 4.10E+02 Vinyl chloride (chloroethene)

LF Ls TS soil vapor kv o 2 (15 or 200 cm) (cm) ( C) permeability) (cm )

15 152.4 19 3.01E+00

1.4 0.48 0.1 5

MORE  ENTER ENTER ENTER ENTER Averaging Averaging time for time for Exposure Exposure carcinogens, noncarcinogens, duration, frequency,

ATC ATNC ED EF (yrs) (yrs) (yrs) (days/yr)

70 30 30 350

END

1 of 4 CHEMICAL PROPERTIES SHEET: Vinyl Chloride

Da Dw HTR ∆Hv,b TB TC URF RfC MW 2 2 3 o o o 3 -1 3 (cm /s) (cm /s) (atm-m /mol) ( C) (cal/mol) ( K) ( K) (µg/m ) (mg/m ) (g/mol)

1.06E-01 1.23E-05 2.69E-02 25 5,250 259.25 432.00 4.4E-06 1.0E-01 62.50

END

2 of 4 INTERMEDIATE CALCULATIONS SHEET: Vinyl Chloride

137.4 0.380 #N/A #N/A #N/A 3.01E+00 4,000 4.10E+02 1.69E+04

1.00E+06 4.00E-04 15 4,898 2.27E-02 9.48E-01 1.78E-04 1.83E-02 137.4

15 4.10E+02 0.10 8.33E+01 1.83E-02 4.00E+02 2.10E+49 3.03E-03 1.24E+00

Unit risk Reference factor, conc., URF RfC (µg/m3)-1 (mg/m3)

4.4E-06 1.0E-01

END

3 of 4 RESULTS SHEET: Vinyl Chloride

INCREMENTAL RISK CALCULATIONS:

Incremental Hazard risk from quotient vapor from vapor intrusion to intrusion to indoor air, indoor air, carcinogen noncarcinogen (unitless) (unitless)

2.2E-06 1.2E-02

MESSAGE SUMMARY BELOW:

END

JE Model Vinyl Chloride 4 of 4