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TECHNICAL MEMORANDUM N SUBJECT Santa Ana Recycling Site: 2002 W. 5th Street, Santa Ana, California DATE 6/6/2017 CLIENT Palmieri, Tyler, Wiener, Wilhelm, & Waldron LLP SUBMITTED TO Michael Leifer, Esq. and Michael Kehoe, Esq. NOREAS PROJECT PAL 015 PREPARED BY Essi Esmaili, PhD, PG NOREAS, Inc. (NOREAS) reviewed two available documents, prepared by Eco & Associates Inc. (Eco) related to the environmental conditions at the subject Site. Based on the information reviewed (Eco, 2016a and Eco 2016b), the following summarizes Eco's findings and recommendations: a. Shallow soil (mainly 0.5 feet to 2.5 feet) has been found to be impacted by petroleum hydrocarbon products, including volatile organic compounds (VOCs), and total petroleum hydrocarbon(TPH). b. Eco compared the detected concentrations of VOCs and TPH with Environmental Screening Levels (ESLs), developed by the San Francisco Bay Regional Water Quality Control Board for Commercial or Industrial Shallow Soil Exposure in northern California (February 2016). Based on this comparison, Eco concluded that an area of approximately 20,500 square feet, with a depth varying from 7 feet to 1.5 feet, is impacted with petroleum hydrocarbon constituents that require some form of remediation. Accordingly, Eco has estimated that 4,280 tons of soil needs to be excavated and hauled offsite for disposal, at a cost of $684,267.90. NOREAS does not agree with the Eco's conclusion and recommendation for the following reasons: 1. The nature of soil impact is petroleum hydrocarbons. As such, application of San Francisco ESLs is not justified for this Site. The California State Water Resources Control Board (State Water Board) has developed the Low -Threat Policy to administer the petroleum Cleanup Programs. The purpose of the Policy is to establish consistent statewide case closure criteria for low -threat petroleum sites. Low -Threat Policy includes concentrations of petroleum constituents in soil that will have no significant risk of adversely affecting human health (Table 1 of Low Threat Policy). Accordingly, only petroleum constituents detected in boring location SBI -14 (Eco, 2016a) at 2 feet would exceed such Low -Threat Policy concentrations. 2. The need for remediation, if required, is determined in consultation with a regulatory agency that has jurisdiction over the Site. NOREAS is not aware of involvement of any regulatory agency on this project. Therefore, Eco's recommendation is only an opinion and not supported by concurrence of a regulatory agency. 11paEe 2002 W. 5`h Street, Santa Ana, California Technical Memorandum