Attachement B_Final Report Phase One.pdf

Phase I Wildfire Assessment Report Brush Creek Work Center Plumas National Forest

12815 Oro Quincy Highway Berry Creek, Butte County, California

Task Order No. 129AES21R0001 Contract No. AG‐91S8‐C‐17‐0013

Prepared for:

Ms. Justine Zeni, Facilities Engineer USDA Forest Service

Plumas National Forest 159 Lawrence Street Quincy, CA 95971

Prepared by:

Broadbent & Associates, Inc.

1370 Ridgewood Drive, Suite 5

Chico, California 95973

(530) 566‐1400

May 13, 2021

Project No. 20‐08‐158

Plumas National Forest, Plumas County, California

TABLE OF CONTENTS

No. Section Page

1.0 Introduction and Site Location

2.0 General Site Background

3.0 Work Purpose

4.0 Health and Safety Plan

4.1 Training

4.2 Personal Protective Equipment

5.0 Field Activities

5.1 Project Set-up

5.1.1 Utility Clearance

5.1.2 Regulatory Notification

5.1.3 Cultural Resource Protection

5.1.4 Investigation-derived Residuals Disposal

5.2 Hazmat Inspection and Removal

5.2.1 Field Screening

5.2.2 Waste Collection and Management

5.2.2.1 PACMS

5.2.2.2 Hazardous Wastes

5.2.3 Large Propane Tanks

5.2.4 Bulged Drum Opening and Characterization

5.3 Transportation and Disposal

5.3.1 PACMs

5.3.2 Hazardous Wastes

5.3.3 Non-Hazardous Wastes

5.3.4 Large Propane Tanks

5.4 Sampling

5.4.1 Ash Samples

5.4.1.1 Sampling Methods

5.4.2 Soil Samples

5.4.2.1 Sampling Methods

5.4.3 Spilled Drum – Unknown Contents

5.4.4 Sample Preparation

5.4.5 Laboratories and Analytical Methods

5.5 Analytical Results

5.5.1 Comparison of Regulatory Screening Levels and Risks

5.5.1.1 Asbestos

5.5.1.2 Dioxins & Furans

5.5.1.3 Heavy Metals, VOCs, SVOCs, PCBs and Pesticides

5.6 Estimated Soil and Ash Volumes

6.0 Summary & Conclusions

7.0 Recommendations

8.0 Limitations

9.0 References

FIGURES

Figure 1 Site Vicinity Map Figure 2 Site Map Figure 3 Soil and Drum Contents Results in Excess of Screening Levels Figure 4 Ash Results in Excess of Screening Levels

TABLES

Table 1 Sampling Locations and Analyses Table 2 Bulk Asbestos Analytical Results Table 3 Dioxins/Furans Analytical Results Table 4 Heavy Metals Analytical Results Table 5 Volatile Organic Compounds (VOCs) Analytical Results Table 6 Semi Volatile Organic Compounds (SVOCs) Analytical Results Table 7 Polychlorinated Biphenyls (PCBs) Analytical Results Table 8 Pesticides Analytical Results Table 9 Estimated Ash and Soil Volumes

APPENDICES

Appendix A Daily Field Reports Appendix B CAC Certification Appendix C MSDS Form for Tree Marking Paint Appendix D Waste Shipping Documentation Appendix E Laboratory Analytical Reports and Chain of Custody Records

1.0 INTRODUCTION AND SITE LOCATION

Broadbent & Associates, Inc. (Broadbent) is pleased to provide this Phase I Wildfire Assessment Report (Report) associated with hazardous materials inspection, removal, and ash and debris sampling results conducted at the Brush Creek Work Center (Site or the Site) located at 12815 Oro Quincy Highway, Berry Creek, Butte County, California. Work described in the Report was conducted in response to Task Order No. 129AES21R0001 under Region 5 IDIQ Contract No. AG-91S8-C-17-0013 for conduct of Non-CERLCA site investigation activities. A Site Location Map is provided as Figure 1.

Field work was conducted between January 10 through 12, 2021 to inspect burned debris for the presence of asbestos containing materials (ACM) and other potentially hazardous wastes. Readily identifiable and accessible ACM and other potentially hazardous wastes and materials were removed, categorized, and transportation off-Site for disposal. In addition, ash and underlying soil were sampled and submitted for analysis to initiate profiling of these media prior to initiation of burned debris removal actions. Appendix A provides copies of Daily Field Reports prepared during conduct of field work.

The Brush Creek Work Center is located in Brush Creek, Butte County, California, an unincorporated area located approximately six (6) miles northeast of Berry Creek at the intersection of Oro Quincy Highway and Bald Rock Road. The Site is situated at an approximate elevation of 3,555 feet above datum and its general map coordinates are 39.6909 N, -121.3393 W. The facility appears to be primarily located in Township 21N, Range 6E in the SE ¼ of the NE ¼ of Section 7 within the Big Bend Mountain Quadrangle, but it is possible that part of the facility may extend to the east into Section 8.

2.0 GENERAL SITE BACKGROUND

The Site was operated as a work center by Plumas National Forest to station work and firefighting crews, equipment, and administrative operations prior to the 2020 fire season. The wildfire referred to as the North Complex Fire burned through the work center in September 2020 resulting in the total loss of nine

(9) wood framed and sheathed structures, two (2) Conex shipping containers being used for storage, an extra Conex used as a hazardous materials storage shed on skids in addition to various pieces of equipment and materials. A facility map depicting both the nine (9) burned building footprints and the seven (7) remaining unburned structures is provided as Figure 2.

The following is a list of the burned structures and areas of concern that were inspected and sampled as part of this initial assessment project included:

• Building 1040/1500: Composed of a residential house (Bldg. 1040) which was wood framed and sheathed with a full basement and sheet metal roof. An adjacent small shed (Bldg. 1500) was wood framed with sheet metal roof built on a concrete slab. Debris from the shed had been pushed into the basement of Building 1040 by others.

• Building 1044: Wood framed and sheathed with a sheet metal roof built on piers. The most recent use was for administrative office space.

• Building 1316: Wood framed and sheathed with a sheet metal roof built on piers. The reported use was personnel barracks.

Broadbent & Associates, Inc. Phase I Wildfire Assessment Report Chico, California Brush Creek Work Center

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• Building 2040: Wood framed and sheathed with a sheet metal roof built on piers. The building had been vacant prior to the fire with the most recent use reported as administrative office space. The building had been designated as historic per Plumas National Forest.

• Building 2140: Wood framed and sheathed with sheet metal roof built on raised concrete slab.

The structure was reportedly used for maintenance and repair work.

• Building 2340: Wood framed and sheathed with a sheet metal roof built on concrete slab. The reported use was as the Engineering Building which housed maintenance equipment and operations. A single Conex storage container was located adjacent to the northeast corner of the building. An above ground heating oil tank was located south of the structure. The heating oil tank was reported by Plumas National Forest personnel to have been out of service for at least 20 years.

• Building 2640: Wood framed and sheathed with a sheet metal roof built on concrete slab. The reported use was as storage. Welding equipment and materials were observed within it.

• Fuel Container Pile: No structure. Location encompassed a large pile of fuel cans and a few truck bed fuel caddys.

• Extra Connexes: Applies to a Conex container and adjacent mobile hazardous materials storage locker.

• Spilled Drum: A heavily corroded, breached and emptied 55-gallon steel drum observed down a steep slope to the north of the facility. A hardened black residue extended several feet down the slope from the drum.

3.0 WORK PURPOSE

Work activities at the Site generally included the conduct of inspections to locate and remove readily accessible hazardous materials for packaging and off-Site disposal. The work scope also encompassed field screening for the presence of sources of ionizing radiation, asbestos containing materials (ACM), volatile organic chemical residues, and flammable and/or explosive items.

Additional tasks per Plumas National Forest included the collection of composite ash samples from building footprints and samples of underlying soil to assist with waste profiling for future removal actions and sampling of the apparent former contents of the spilled drum.

4.0 HEALTH AND SAFETY PLAN

A comprehensive Site-specific health and safety plan (HASP) was prepared based on the Task Order activities for burned debris inspection/evaluation and packaging and removal of hazardous materials and ACM removal. A copy of the site-specific HASP prepared for use by personnel directly involved with implementation of this project was provided to the attending Plumas National Forest representative and a copy was maintained on-Site during field activities.

The Broadbent representative lead a daily tailgate safety meeting prior to initiation of work each day which included our subcontractor and Plumas National Forest staff, if present, to discuss the contents of

Page No. 3 the HASP, previous day’s lessons learned, and specific topics of safety relating to the current day’s planned activities. The initial safety meeting included a general Site walk to identify the appropriate work zones and potential areas of high risk (such as high traffic routes or Site security) for discussion and modification of the HASP as needed.

4.1 Training

The Broadbent representative responsible for field activities was Tim Babcock, California Certified Asbestos Consultant (CAC) #19-6693. A copy of Mr. Babcock’s CAC certification card is included in Appendix B.

All field staff working for or under Broadbent had completed valid HAZWOPER 40-hour training and possessed a current 8-hour refresher certificate. All persons engaged in bulk asbestos removal had additionally completed a valid AHERA 32-hour asbestos worker training course and possessed a current 8-hour refresher certificate. Asbestos supervisors had additionally completed a valid 8-hour AHERA 8-hour asbestos supervisor training course.

4.2 Personal Protective Equipment

Personal protective equipment (PPE) was designated in the HASP. Burned structure footprints were designated as exclusion zones.

Workers entering footprints were required to don Level C PPE including at a minimum a half face air purifying respirator fitted with high efficiency purifying air (HEPA) filters, hard hat, eye protection, nitril gloves, disposable coveralls (Tyvek or similar), and steel toe/composite toe footwear.

Workers operating outside of the footprints were required to don Level D PPE at a minimum including hard hat, eye protection, and steel toe/composite toe footwear.

5.0 FIELD ACTIVITIES

Broadbent partnered with Alliance Environmental Services (AES) to complete Site investigation activities. Broadbent’s CAC was on-Site for the duration of work from January 10 through January 12, 2021 to initiate the scope of work, lead daily safety meetings, provide client communication, perform asbestos inspections, perform sample collection/preservation, record/observe work activities, and participate in the final inspection. A second Broadbent representative was present on January 11 to assist with soil and ash sample collection. AES provided field staff including an equipment operator and two (2) to three (3) technicians. A representative of Plumas National Forest was on-Site during the duration of the field activities. Daily field sheets are provided in Appendix A.

5.1 Project Set-up

The work center remains closed to the public with limited use by Plumas National Forest personnel. A water trailer was mobilized with the work crew and was filled on-Site to use as needed for dust suppression and decontamination.

5.1.1 Utility Clearance

No excavation was included in this phase of cleanup. Utility clearance was not required.

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5.1.2 Regulatory Notification

No permits were required for this scope of work. Broadbent provided appropriate notification of Site activities to Plumas National Forest before commencing with the scope of work.

5.1.3 Cultural Resource Protection

Plumas National Forest personnel informed Broadbent that building 2040 was a historic structure.

Although completely consumed by the fire, a low wall around the perimeter, and a chimney remained and were to be protected.

5.1.4 Investigation-derived Residuals Disposal

No investigation-derived residual (IDR) was generated during the project. Miscellaneous wastes, such as personal protective equipment, disposable sampling equipment, polyethylene sheeting, and general trash, was transported off-Site and disposed at independent office locations.

5.2 Hazmat Inspection and Removal

For the purpose of this project, the term “inspection” refers to a visual inspection to identify hazardous materials of concern including those of a chemical nature (oils and petroleum products, paints, aerosol cans, pesticides, propane cylinders) identified visually or with the RAE Systems MiniRAE 3000 photoionization detector (PID) utilized, easily identifiable presumed ACM, potential radioactive isotope containing materials such as tritium containing exit signs, americium containing smoke detectors, and any source of ionizing radiation discernable through use of the Ludlum Model 19 microR Survey Meter (Ludlum) utilized, and visually identifiable explosive or incendiary materials. Particulates in air were monitored using a Thermo Scientific pDR-1000AN (PDR).

The building footprints were tarped with plastic. Water as well as snow and ice were present on top of the tarps necessitating additional efforts to remove snow and ice and drain water before removing the tarps to make each footprint accessible. No characterization of overlying water and snow was requested at the time of the work, nor would it be deemed necessary as it was segregated from underlying ash and debris by intact plastic sheeting.

The Broadbent CAC performed an initial screening of each building footprint using PID, Ludlum, and PDR to assess safety for continued access to conduct the scope of work. After completing the screen, a visual inspection for readily identifiable presumed asbestos materials was then conducted by the CAC.

AES crews conducted bulk removal of readily identifiable presumed asbestos containing materials (PACMs) and performed visual inspection for and removal of hazardous materials from each footprint. A total of eight (8) bags of PACM were removed from the footprints.

5.2.1 Field Screening

Initial screening of each footprint for volatile organic vapors, ionizing radiation, and airborne particulates was performed after removal of overlying tarps. No positive results were recorded from ash footprints during the initial screening process.

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5.2.2 Waste Collection & Management

5.2.2.1 PACMs

PACMs were identified and removed from the footprints of Buildings 1040, 1044, 1316, 2140, and 2340.

Removals were performed by AES personnel using wet methods. PACMs were wetted prior to removal, double bagged and properly sealed. Each bag was checked to ensure visual evidence of moisture and then properly labeled as an asbestos waste.

A total of eight (8) bags of PACM weighing approximately 100-pounds in total were collected from the five (5) footprints involved. Wastes were consolidated, labeled as Asbestos Containing Fire Debris (Floor tile, Ash Debris) and temporarily stored on Site pending profiling and disposal facility acceptance.

5.2.2.2 Hazardous Wastes

Each building footprint was visually inspected for the presence of hazardous wastes and compressed gas cylinders. Compressed gas cylinders including acetylene, oxygen, and propane were removed from the building footprint and checked for pressure. Each recovered cylinder was safely de-headed and left on Site to be disposed of as scrap metal in a subsequent phase of cleanup. None of the recovered cylinders remained under pressure.

Eight (8) fluorescent light ballasts potentially contain polychlorinated biphenyls were recovered from the footprints. The ballasts were stored inside a 10-gallon metal drum, properly labelled as hazardous waste, and temporarily stored on-Site pending profiling and disposal facility acceptance.

183 quarts of tree marking paint with liquid or partially liquid contents were recovered from the Conex container adjacent to the portable hazardous materials storage shed. The paint containers were collected and stored inside a 55-gallon drum. The drum was labelled as a Non-RCRA Hazardous waste and temporarily stored on-Site pending profiling and disposal facility acceptance. The tree marking paint was profiled as a non-RCRA hazardous waste based upon generator knowledge according to the material safety data sheet (MSDS) provided to Broadbent by Plumas National Forest. A copy of the MSDS received by Broadbent is included in Appendix C.

5.2.3 Large Propane Tanks

Three (3) large propane tanks located on the Site were designated for removal. AES utilized a skidsteer type loader to lift each tank onto a trailer. Tanks were secured onto the trailer and subsequently transported off-Site for recycling.

5.2.4 Bulged Drum Opening and Characterization

A 55-gallon metal drum labelled as containing lubricant was found in the northwest corner of the facility commonly referred to as “the boneyard” where materials and equipment are stored in the open. The drum was observed to be bulged requiring additional safety measures to be employed prior to opening the drum and confirming the nature of any contents.

Broadbent conducted a safety meeting specifically addressing the plan and specific roles assigned to the entrant and attendants. Given the contents identified on the label and the location of the drum in a materials and equipment storage yard it was determined that contents were likely to be accurately labelled or similar in nature.

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An AES entrant equipped in level C PPE approached the drum while others remained at a distance. The entrant confirmed that the bung cap was only loose and was able to open it with little difficulty confirming the lack of pressurized contents. Several gallons of liquid contents were confirmed within the drum. A PID was utilized to confirm that the contents emitted volatile organic vapors. An aliquot of the contents was collected using a coliwasa sampler. The entrant then conducted a 5-step field hazardous categorization including tests for:

• pH

• reactivity

• miscibility

• flammability

• oxidizer

The results indicated a near neutral pH, non-reactive, non-miscible, non-flammable, non-oxidizing liquid.

Based upon field categorization and visual inspection it was determined that the liquid was diesel.

5.3 TRANSPORTATION AND DISPOSAL

5.3.1 PACMs

Eight (8) bags of PACM were recorded on non-hazardous waste manifest #0000 as Soil & Ash-Tile (possible ACM) and transported by AES to the Butte County Neal Road Landfill where it was accepted on January 12, 2021. A copy of the non-hazardous waste manifest used to transport PACM is included in Appendix D.

5.3.2 Hazardous Wastes

One (1) 10-gallon metal drum containing eight (8) fluorescent light ballasts was recorded on uniform hazardous waste manifest #021465981 JJK as UN 3432, polychlorinated biphenyls, solid, 9, PG II, (PCB containing ballasts) and transported off site by AES/Cal, Inc. on February 26, 2021. The drum was manifested to Lighting Resources Inc in Phoenix, Arizona. The original manifest was lost in transit and re-manifested under uniform hazardous waste manifest #021465995 JJK. A copy of manifest #021465995 JJK with an attached voided copy of original manifest #021465981 is included in Appendix D.

One (1) 55-gallon metal drum containing 183 pints of tree marking paint was recorded on uniform hazardous waste manifest 021465978 JJK as non-RCRA hazardous liquid and transported off-Site by AES/CalHaz Inc. on February 26, 2021. The drum was transported to Crosby & Overton Inc. in Long Beach, California and accepted on March 12, 2021. A copy of the facility signed manifest is included in Appendix D.

5.3.3 Non- Hazardous Wastes

One (1) 20-gallon metal drum containing 20-gallons of diesel was recorded on non-hazardous waste manifest 2020B and removed from the Site. The drum was transported to Humphrey’s Farm and Equipment Inc. in Chico California for recycling. A copy of the non-hazardous waste manifest is included in Appendix D.

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5.3.3.1 Large Propane Tanks

Three (3) large propane tanks were transported under non-hazardous waste manifest (no number assigned) to Chico Scrap Metal in Chico, CA. The tanks were accepted on January 24, 2021. A copy of the non-hazardous waste manifest is included in Appendix D.

5.4 Sampling

Broadbent collected soil and ash samples to be subjected to select physical and chemical analyses as designated by Plumas National Forest and as listed in the Table 1. A sample from the spilled drum contents is also included in Table 1.

5.4.1 Ash Samples

Ash samples were collected as composites. Per Plumas National Forest direction, representative subsamples of ash were collected from multiple locations around designated footprints shown in Table

1. Ash from each footprint was consolidated in a clean one (1)-gallon plastic bag used only for that footprint. The contents of the bag were homogenized in the field and representative sample collected from within it. Ash samples were collected from the footprints of Buildings 2140, 1044, 2340, 2040, 2640, 1040/1500, 1316, and the extra connexes.

5.4.1.1 Sampling Methods

Broadbent personnel manually collected ash and placed it into the bag wearing nitril gloves. A clean pair of nitrile gloves were donned before the collection of each composite.

5.4.2 Soil Samples

Soil samples were collected as discrete samples. A random accessible location was chosen in the field and a hole was advanced to approximately 6-inches in depth using a shovel. A single soil sample was collected from each of the footprints indicated in Table 1. Soil was consolidated in a clean one (1)-gallon plastic bag used only for that footprint. The contents of the bag were transported to a central location on-Site where appropriate sample containers were filled according to the required analyses. Soil samples were collected from the footprints of Buildings 2140, 1044, 2340, 2040, 1316, and the extra connexes.

5.4.2.1 Sampling Methods

Broadbent personnel collected soil samples using a pre-cleaned shovel. The shovel was decontaminated with an Alconox detergent solution and triple rinsed between uses. A clean pair of nitrile gloves were donned before the collection of each sample.

5.4.3 Spilled Drum - Unknown Contents

A sample was collected from the apparent contents of a heavily corroded and breached 55-gallon metal found north of the Site in the general vicinity of the facility well.

5.4.4 Sample Preparation

Soil and ash samples were hand packed into laboratory cleaned glass jars. Subsamples intended for VOA analyses were collected from the same soil and consisted of two (2) Terra Core® sampling plugs placed in methanol preserved volatile organic analysis (VOA) vials. Subsamples of ash and soil were collected from samples designated for asbestos analysis and placed into a clean Ziploc plastic bags and sealed.

Each sample container was labelled with a project unique identifier and recorded on a sample chain of

Page No. 8 custody. Samples for chemical analyses were placed into an insulated cooler on top of ice and transported via overnight delivery to the accepting laboratory. Samples for asbestos analysis were placed into a box and shipped to the accepting laboratory.

5.4.5 Laboratories and Analytical Methods

Sample containers to be submitted for bulk asbestos analysis were shipped to EMC Labs in Phoenix, Arizona (EMC). EMC is accredited through NVLAP to perform the required PLM analytical procedure:

• 600/R-93/116

Remaining sample containers were shipped to Pace Analytical in Mt. Joliet, Tennessee (Pace). Pace is accredited under the ELAP to perform the following procedures:

• Dioxins & Furans by EPA Method 8290

• CAM-17 Metals by EPA Method 6010B

• Mercury by EPA Method 7471A

• Volatile Organic Compounds (VOCs) by EPA Method 8260B

• Semi-volatile Organic Compounds (SVOCs) by EPA Method 8270-SIM

• PCBs by EPA Method 8082

• Pesticides by EPA Method 8081

5.5 Analytical Results

The results of analyses are contained in the attached tables. Results are listed below by Table:

• Bulk Asbestos-Table 2

• Dioxins/Furans- Table 3

• Heavy Metals- Table 4

• VOCs- Table 5

• SVOCs- Table 6

• PCBs- Table 7

• Pesticides- Table 8

Copies of certified laboratory analytical reports are included in Appendix E.

5.5.1 Comparison of Regulatory Screening Levels

Laboratory analytical results of ash and soils samples, summarized in Tables 3 through 8, were compared to California Department of Toxic Substances Controls (DTSC) screening levels (DTSC-SLs) Table 1 for Residential Soils (Cancer Endpoint derived at a target risk level of 1x106 (one in one million)).

DTSC-SLs do not provide screening levels for every compound. Where no published DTSC-SL was found the USEPA Regional Screening Levels (EPA RSLs) for that compound was employed. Comparison of ash and soil analytical concentrations to the DTSC-SLs assist with determining potential risks to human health at the Site. Asbestos was not included in the comparison analysis as it is statutorily defined.

Figure 3 shows the locations of soil samples and of the spilled drum contents sample with analytes exceeding screening levels. Figure 4 similarly displays screening level exceedances for Ash samples.

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5.5.1.1 Asbestos

ACMs are defined by OSHA under 40CFR 1910.1001(b) as any material containing 1% or more of asbestos.

5.5.1.2 Dioxins & Furans

DTSC-SLs and EPA RSLs are only published for the below listed compounds and groups of compounds.

Comparisons of dioxins and furans (Table 3) are limited to the following:

• 2,4,7,8 Tetrachlorodibenzo-p-dioxin (2,4,7,8 TCDD)

• Hexachlorodibenzo-p-dioxin (HxCDD mix)

• Dibenzofuran

5.5.1.3 Heavy Metals, VOCs, SVOCs, PCBs, and Pesticides

DTSC-SLs and/or EPA RSLs were employed for comparison to sample results for heavy metals (Table 4), VOCs (Table 5), SVOCs (Table 6), PCBs (Table 7), and Pesticides (Table 8).

5.6 Estimated Soil and Ash Volumes

Estimates of soil and ash volumes are based upon conditions observed in the field at the time of the work. Depths of soil are included for structures with and without concrete slab foundations. Volume estimates for each building or area of concern are provided in Table 9.

6.0 DISCUSSION

Phase I wildfire assessment activities were conducted during the period between January 10 through January 12, 2021. General assessment activities included a cursory screening of each burned structure footprint or area of concern with field instruments, removal of easily removable and identifiable PACM, and collection of soil and ash samples for laboratory analysis.

Each of the twelve (12) burned structure footprints (including the Fuel Container Pile) was first screened for volatile organic vapors, ionizing radiation, and airborne particulates using a PID, Ludlum, and PDR, respectively. No positive results were detected from the assessed footprints using portable field equipment.

Inspections resulted in the collection and removal of eight (8) bags of readily accessible PACM weighing approximately 100-pounds in total. Limited accessibility created by overlying debris severely limited complete of removal of those PACMs identified, tagged for removal, and transported under non-hazardous waste manifest 0000 to the Butte County Neal Road landfill in Chico, Butte County, California.

The wastes were accepted at the landfill on January 12, 2021.

The valves from each retrieved pressurized cylinder were successfully removed rendering them non-hazardous. De-valved cylinders were left on-Site as scrap metal to be removed during future cleanup.

Empty aerosols and containers with solidified contents were left on-Site. A full inventory of regulated wastes removed from the Site includes:

• Eight (8) fluorescent light ballasts

• 183 Pints of Tree Marking Paint

• 20-gallons Diesel

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Ballasts were manifested to Lighting Resources in Phoenix, AZ (EPA ID# AZ0983476680) under uniform hazardous was manifest #021465981 JJK which was lost in transit. The wastes were subsequently re-manifested under uniform hazardous waste manifest #021465995 JJK and a Letter of Correction was submitted to the California Department of Toxic Substances Control (DTSC) by Transporter #2 (Cal Inc) on May 11, 2021. The facility signed manifest has not yet been received. A copy of the facility signed manifest will be provided to Plumas National Forest upon receipt in a revised or addendum report.

Tree marking paint was transported to the Recology Hay Road Landfill in Vacaville, California under non- RCRA hazardous waste manifest #021465978 JJK. The waste was accepted on March 12, 2021.

A bulging 55-gallon drum labeled “Lubricant” located in the storage yard at the east of the Site referred to as the boneyard was determined not to be under pressure and was successfully opened. The results of field hazardous categorization tests performed on the contents resulted in a determination that the product was diesel fuel. Approximately 20-gallons of diesel fuel were removed from the Site and transported to Humphrey’s Farm and Equipment under non-hazardous waste manifest 2020B for recycling. The diesel was accepted on March 12, 2021.

Three (3) large commercial sized propane tanks were transported under bill of lading to Chico Scrap Metal in Chico, California. Tanks were accepted on January 24, 2021.

Soil and ash sampling were conducted as indicated on Table 1. The following summarizes laboratory analytical results:

Asbestos: A total of four (4) ash samples (2140 Ash, 1044 Ash, 2040 Ash, and 1040/1500 Ash) and three

(3) soil samples (2140 Soil, 1044 Soil, and 2040 Soil) were analyzed for asbestos. None of the submitted samples were found to contain asbestos at concentrations exceeding the ACM definition of 1 % asbestos.

Dioxins: A total of five (5) ash samples (2140 Ash, 1044 Ash, 2640 Ash, 2040 Ash, and 1040/1500 Ash) and three (3) soil samples (2140 Soil, 1044 Soil, and 2040 Soil) were analyzed for dioxins. Screening levels are only published by DTSC and EPA for three of the compounds (2,4,7,8 TCDD, HxCDD mix, and Dibenzofuran) included in the EPA Method 8290 analysis used on the samples. It is noted that the reported total concentrations for each compound included all isomers. Of the samples analyzed the following exceeded screening levels as noted below.

• 2140 Ash: Exceeded both the DTSC-SL and EPA RSL for residential soil.

• 2140 Soil: Exceeded both the DTSC-SL and EPA RSL for residential soil.

CAM-17 Metals: A total of seven (7) ash samples and seven (7) soil samples were analyzed for CAM-17 metals. Screening levels were exceeded for eight (8) individual metals which are discussed in more detail below.

• Antimony (Sb): The EPA RSL of 31 mg/kg for residential soil was exceeded in five (5) of the analyzed samples (2140 Ash, 2340 Ash, 2040 Ash, Extra Connexes Soil, and Extra Connexes Ash).

DTSC does not publish a screening level for antimony.

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• Arsenic (As): The DTSC-SL of 0.11 mg/kg is the lower of the screening levels used. The DTSC-SL for residential soil was exceeded in eleven (11) of the analyzed samples (2140 Soil, 2140 Ash, 1044 Soil, 1044 Ash, 2340 Conex, 2340 Tank, 2340 Ash, 2040 Soil, 2040 Ash, 1040/1500 Ash, Extra Conexes Soil).

• Cobalt (Co): The EPA RSL of 23 mg/kg for residential soil was exceeded only in sample Extra Connexes Ash. DTSC does not publish a screening level for cobalt.

• Copper (Cu): The EPA RSL of 3,100 mg/kg for residential soil was exceeded only in sample 1040/1500 Ash. DTSC does not publish a screening level for this copper.

• Lead: The DTSC-SL of 80 mg/kg is the lower of the screening levels used. The DTSC-SL of 80 mg/kg for residential soil was exceeded in samples 2140 Soil, 2140 Ash, 2340 Ash, 2040 Soil, 2040 Ash, 1040/1500 Ash, and Extra Conexes Ash.

• Nickel (Ni): The EPA RSL of 0.76 is the lower of the screening levels used. Fourteen (14) analyzed samples (2140 Soil, 2140 Ash, 1044 Soil, 1044 Ash, 2340 Conex, 2340 Tank, 2340 Ash, 2640 Ash, 2040 Soil, 2040 Ash, 1040/1500 Ash, Extra Conexes Soil, Extra Conexes Ash, and Fuel Container Pile) were found to exceed the EPA RSL of 0.76 mg/kg for residential soil. None of the analyzed samples were found to exceed the DTSC-SL of 820 mg/kg.

• Thallium (Tl): The EPA RSL of 0.78 mg/kg for residential soil was exceeded only in sample 2640 Ash. DTSC does not publish a screening level for thallium.

• Zinc (Zn): The EPA RSL of 23,000 mg/kg for residential soil was exceeded only in sample Extra Connexes Ash. DTSC does not publish a screening level for zinc.

VOCs: A total of seven (7) ash samples (2140 Ash, 1044 Ash, 2340 Ash, 2640 Ash, 2040 Ash, 1040/1500 Ash, and Fuel Container Pile), five (5) soil samples (2140 soil, 1044 Soil, 2040 Soil, 1316 Soil, and Fuel Container Pile), and spilled drum product were analyzed for VOCs. Samples 2140 Ash and 2640 Ash were found to exceed the DTSC-SL of 0.44 mg/kg for residential soil for benzene. No screening level exceedances were reported for the remaining list of VOC compounds.

SVOCs: A total of seven (7) ash samples (2140 Ash, 1044 Ash, 2340 Ash, 2640 Ash, 2040 Ash, 1040/1500 Ash, and Fuel Container Pile), five (5) soil samples (2140 soil, 1044 Soil, 2040 Soil, 1316 Soil, and Fuel Container Pile), and spilled drum product were analyzed for SVOCs. Only sample Spilled Drum Contents was found to contain SVOCs in excess of residential soil screening levels. The sample exceeded the EPA RSL of 0.11 mg/kg for Benzo(a)Pyrene, the DTSC-SL of 0.28 mg/kg for Dibenzo(a,h)anthracene, and the DTSC-SL of 2 mg/kg for Naphthalene.

PCBs: Three (3) ash samples (2340 Ash, 2640 Ash, and 2040 Ash) and one (1) soil sample (2040 Soil) were analyzed for PCBs. None of the analyzed samples exceeded the DTSC-SLs published for Aroclor 1016 and Aroclor 1254. Sample 2640 Ash was found to exceed the EPA RSL for residential soil of 0.12 mg/kg for the compound Aroclor 1254.

Pesticides: Only sample 2140 Ash was analyzed for Pesticides, and none of the analytes were found to exceed DTSC-SLs or EPA RSLs.

7.0 RECOMENDATIONS

Concentrations of contaminants exceeding DTSC and/or EPA screening levels are confirmed as present in both ash and soil associated with select burned structure footprints and other areas of concern (AOC) at the Brush Creek Work Center. A general summary of constituents that exceed screening levels has

Page No. 12 been provided in tabular format below for ash and soil. With that stated, Broadbent has prepared the following recommendations under the assumption that remedial action will be implemented to properly remove and dispose of burned ash, debris, and underlying soil by appropriately trained and equipped personnel.

Locations of Ash Constituents in Exceedance of DTSC and/or EPA Screening Levels Dioxins Metals VOCs PCBs

Bldg./

AOC

2,4,7,8 TCDD HxCDD Sb As Co Cu Pb Ni Tl Zn Benzene Aroclor

2140 x1,2 x1,2 x2 x1,2 x1,2 x1,2 x1,2 1044 x1,2 x1,2 2040 x2 x1,2 x1,2 x1,2 2340 x2 x1,2 x1,2 x1,2 2640 x1,2 x2 x1,2 x2 1040/ 1500 x1,2 x2 x1,2 x1,2

Extra

Conexes x2 x2 x1,2 x1,2 x2

1 Exceeds CA DTSC SL 2 Exceeds EPA RSL

Laboratory analysis of composite ash samples indicate exceedances of metals Antimony (Sb), Arsenic (As), Cobalt (Co), Copper (Cu), Lead (Pb), Nickel (Ni), Thallium (Tl), and Zinc (Zn). Many of the metal concentrations reported for ash may require additional testing for soluble threshold limit concentration (STLC) and/or toxicity characteristic leaching procedure (TCLP) to accurately classify them as hazardous or non-hazardous wastes for transportation and disposal. Waste disposal facility acceptance requires submission of a generator signed profile application.

Page No. 13

Locations of Soil Constituents in Exceedance of DTSC and/or EPA Screening Levels Dioxins Metals

Bldg./

AOC

2,4,7,8 TCDD HxCDD Sb As Pb Ni

2140 x1,2 x1,2 x1,2 x1,2 x1,2 1044 x1,2 x1,2 2040 x1,2 x1,2 x1,2

Conex x1,2 x1,2

Tank x1,2 x1,2

Extra Conexes x2 x1,2 x1,2

Fuel Container

Pile x1,2

1 Exceeds CA DTSC SL 2 Exceeds EPA RSL

The seven (7) soil samples analyzed for metals exceeded the soil screening levels for Arsenic (As) and Nickel (Ni). One (1) soil sample exceeded the Antimony (Sb) screening level and another soil sample exceeded the Lead (Pb) screening level.

It is recommended that background soil sampling be performed to evaluate naturally occurring background levels of these metals prior to future soil excavation. The analytical results generated during the reported work should be compared to observed background levels to determine if they exceedances are present. Appropriate actions should be developed to address background level exceedances, if observed.

Dioxins slightly exceeded screening levels in the footprint of Building 2140 where the overlying ash was found to have significantly exceeded screening levels. It is recommended that six (6) to nine (9) inches of soil be excavated from the footprint of Building 2140 following ash and debris removal with confirmation soil samples collected from the final depth to confirm the success of removal.

If further soil sampling is not performed, additional investigation of the extent of soil impact at the footprint of Building 2140 by dioxins, specifically 2,3,7,8 TCDD and Total HxCDD, may provide further insight into the potential for adverse health impacts on future occupants.

Where metals concentrations reportedly exceed observed background levels it is recommended that at least nine (9) inches of soil be removed from these locations following ash and debris removal.

Additional soil sampling from the final depth should be performed to document residual levels of contaminants.

Page No. 14

Disposal options for excavated soil require submission of generator signed profile applications for each landfill approached. It is likely that further soil characterization will be necessary before profiling based upon the initial results described within this Report. Many of the sample results generated initial concentrations that require further testing to determine the STLC to enable classification as a hazardous or non-hazardous waste for disposal. It may ultimately require additional testing to determine the TCLP of the waste if the STLC exceeds the hazardous waste threshold. A hazardous waste determined by STLC may still be classified as a non-hazardous waste if the TCLP is below the stated threshold for that constituent.

It is recommended that characterization be performed by composite sampling collected from stockpiled soil generated through excavation. When properly conducted composite sampling can provide a more accurate representation of the average concentrations of chemical constituents in the waste.

The spilled drum contents should be profiled for disposal and should be accepted as a non-hazardous or non-RCRA hazardous waste. Remedial action associated with the spill drum will be easier with heavy equipment on-Site due to the location of the drum from the work center.

These constituent concentrations indicate that there is a potential exposure risk to workers and residents at the Brush Creek Work Center. The concentrations of these constituents of concern have only been compared to DTSC and/or EPA screening levels as an initial step in evaluating the potential risk at the Site, and this is not to be considered a formal risk assessment. It is Broadbent’s understanding that Plumas National Forest anticipates implementation of appropriate remedial action to remove fire ash and debris associated with the Site to prevent potential exposure to workers and residents. If remedial actions are not conducted, then it is recommended that Plumas National Forest conduct a comprehensive health risk assessment to develop measures designed to provide appropriate protection and prevent worker and resident exposure to burned ash, debris and soil located at the Site.

8.0 LIMITATIONS

This document has been prepared for the exclusive use of Plumas National Forest. The findings presented in this report are based upon observations of Broadbent & Associates, Inc. and Pace Analytical and EMC Labs and were performed in accordance with the generally accepted standards of practice at the time this report was written. No warranty, expressed or implied, is intended. Field activities were limited to visual inspection of burned debris for the presence of readily accessible asbestos containing materials and other potentially hazardous waste. Additional tasks include the collect of ash and soil samples to assist with the initial profile of burned debris media as well as asbestos sampling of other residual debris. Readily accessible hazardous materials were transported off-Site for disposal.

9.0 REFERENCES

Broadbent & Associates, Inc., 2021. Phase I Wildfire Cleanup Work Plan, Brush Creek Work Center, Plumas National Forest, Butte County, California. January 29.

California Department of Toxic Substances Control, 2020. Human Health Risk Assessment Note Number

3, DTSC-modified Screening Levels. Updated June.

Page No. 15

U.S. EPA, 2020. Regional Screening Levels. Pacific Southwest Region 9.

http://www.epa.gov/region9/superfund/prg/ Updated November.

http://www.epa.gov/region9/superfund/prg/

FIGURES

Drawing

0 600 1,200

APPROXIMATE SCALE (ft)

Site Location Map Brush Creek Work Center

12815 Oroville Quincy Highway Berry Creek, California

SITE

SITE

N

IMAGE SOURCE: Google Earth

1370 Ridgewood Dr., Suite 5 Chico, California 95973

Project No.: 20-08-158 Date: 1/29/2021

SC

AL

E (ft

Si te M ap

R id ge w oo d Dr

Su ite

Ch ic o, C al ifo rn ia

Pr oj ec t N o.

: 2 0-

-1

D at e:

/2 9/

Fi gu re

N

Drawing from USFS Plumas County

Br us h Cr ee k

W or k Ce nt er

O ro vi lle Q ui nc y Hi gh w ay Be rr y

Cr ee k, C al ifo rn ia

PORTABLE

HAZMAT

LOCKER

EXTRA

CONEXES

10402369

FUEL

ISLAND

WASH

RACK

BOOSTER

PUMP 2702

1044 SOIL RESULTS UNITS

Arsenic 2.13 mg/kg Nickel 29.4 mg/kg

2340 CONEX RESULTS UNITS

Arsenic 4.74 mg/kg Nickel 46.6 mg/kg

2340 TANK RESULTS UNITS

Arenic 1.57 mg/kg Nickel 23.9 mg/kg

2140 SOIL RESULTS UNITS

2,3,7,8 TCDD 6.0 ng/kg Total HxCDD 110 ng/kg

Arsenic 0.925 mg/kg Lead 121 mg/kg

Nickel 35 mg/kg

2040 SOIL RESULTS UNITS

Arsenic 1.06 mg/kg

Lead 180 mg/kg Nickel 42.1 mg/kg

AP

PR

O X.

-F

EE

T

SPILLED DRUM RESULTS UNITS

Benzo(a)pyrene 0.916 mg/kg

Dibenzo(a,h)anthracene 0.567 mg/kg Naphthalene 4.89 mg/kg

EXTRA CONEXES SOIL RESULTS UNITS

Antimony 32.9 mg/kg

Arsenic 18.1 mg/kg Nickel 16.6 mg/kg

FUEL CONTAINER PILE RESULTS UNITS

Nickel 43.3 mg/kg

APPROX. 750-FEET

AP

PR

O

XI

M

AT

E

SC

AL

E

(ft

So il an d

Dr um

S am pl e

Re su lts in

Ex ce ss o f S cr ee ni ng L ev el s

R id ge w oo d Dr

Su ite

Ch ic o, C al ifo rn ia

Pr oj ec t N o.

: 2 0-e:

/2 8/

Fi gu re

N

Based on a Drawing from USFS Plumas County

Br us h Cr ee k

W or k Ce nt er

O ro vi lle Q ui nc y Hi gh w ay Be rr y

Cr ee k, C al ifo rn ia

Legend

Sample Location

Note:

Reported Values Exceed CA DTSC-SL and/or EPA RSL

PORTABLE

HAZMAT

LOCKER

CONNEX

2340 TANK

10402369

FUEL ISLAND

WASH

RACK

BOOSTER

PUMP 2702

2140 ASH RESULTS UNITS

2,3,7,8 TCDD 550 ng/kg Total HxCDD 43,000 ng/kg

Antimony 363 mg/kg Arsenic 44.6 mg/kg

Lead 623 mg/kg Nickel 87 mg/kg

Benzene 2.39 mg/kg

1044 ASH RESULTS UNITS

Arsenic 4.04 mg/kg Nickel 11.9 mg/kg

2340 ASH RESULTS UNITS

Antimony 244 mg/kg

Arsenic 2.94 mg/kg Lead 177 mg/kg

Nickel 3.5 mg/kg

2640 ASH RESULTS UNITS

Nickel 47.6 mg/kg

Thallium 2.74 mg/kg Benzene 0.559 mg/kg

Aroclor 1254 0.437 mg/kg

2040 ASH RESULTS UNITS

Antimony 48.5 mg/kg

Arsenic 2.15 mg/kg Lead 765 mg/kg

Nickel 34.7 mg/kg

1040/1500 ASH RESULTS UNITS

Arsenic 1.68 mg/kg Copper 4,620 mg/kg

Lead 412 mg/kg Nickel 26.1 mg/kg

EXTRA CONEXES ASH RESULTS UNITS

Antimony 46.6 mg/kg

Cobalt 103 mg/kg Lead 1,180 mg/kg

Nickel 14.5 mg/kg Zinc 24,000 mg/kg

AP

PR

O

XI

M

AT

E

SC

AL

E

(ft

As h

Co m po sit e Sa m pl e Re su lts in Ex ce ss o f S cr ee ni ng

L ev el s

R id ge w oo d

Dr

Su ite

Ch ic o, C al ifo rn ia

Pr oj ec t N o.

: 2

0-e:

/2

8/

Fi gu re

N

Based on a Drawing from USFS Plumas County

Br us h Cr ee k

W or k Ce nt er

O ro vi lle Q ui nc y Hi gh w ay Be rr y

Cr ee k, C al ifo rn ia

Note:

Reported Values Exceed CA DTSC-SL and/or EPA RSL

TABLES

2140 Soil 1 1 1 1 0 1 0 2140 Ash 1 1 1 1 0 1 1 1044 Soil 1 1 1 1 0 1 0 1044 Ash 1 1 1 1 0 1 0 2340 Ash 1 1 1 1 1 0 0

2340 Conex Soil 0 1 0 0 0 0 0 2340 Tank Soil 0 1 0 0 0 0 0

2040 Soil 1 1 1 1 1 1 0 2040 Ash 1 1 1 1 1 1 0 2640 Ash 0 1 1 1 1 1 0

1040/1500 Ash 1 1 1 1 0 1 0 1316 Soil 0 0 1 1 0 0 0 1316 Ash 0 0 1 1 0 0 0

Fuel Container Pile Soil 0 1 1 1 0 0 0 Extra Conexes Soil 0 1 0 0 0 0 0 Extra Conexes Ash 0 1 0 0 0 0 0 Spilled Drum Contents 0 0 1 1 0 0 0

NOTES:

CAM-17 =

VOCs = SVOCs = Semi-volatile organic chemicals

PCBs = Polychlorinated biphenyls

Volatile organic chemicals

SVOCs PCBs Dioxins Pesticides

Antimony (Sb), Arsenic (As), Barium (Ba), Berrylium (Be), Cadmium (Cd), Chromium (Cr), Cobalt (Co), Copper (Cu), Lead (Pb), Molybdenum (Mo), Nickel (Ni), Selenium (Se), Silver (Ag), Thallium (Tl), Vanadium (V), Zinc (Zn)

Table 1. Sampling Locations and Analyses

Brush Creek Work Center 12815 Oro Quincy Highway, Berry Creek, California

Building/Site ID Media Asbestos CAM-17 VOCs

2140 Soil 2/11/2021 None 2140 Ash 2/11/2021 None 1044 Soil 2/11/2021 None 1044 Ash 2/11/2021 None 2040 Soil 2/11/2021 None 2040 Ash 2/11/2021 None

1040/1500 Ash 2/11/2021 None

Sample ID Sampling

Date Asbestos Detected

Table 2. Sampling Laboratory Analytical Data Bulk Asbestos by PLM Method 600/R-93-116

2140 Soil 2/11/2021 18 6.0 8.5 110 5.0 J 140 110 99 760 180 2900 547 2140 Ash 2/11/2021 6,600 E 550 11,000 E 3,900 15,000 9,200 43,000 E 11,000 E 52, 000 E 6,000 76, 000 E 36,700 1044 Soil 2/11/2021 <1.0 <1.0 <1.0 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 <10 <10 <10 1044 Ash 2/11/2021 6.6 <1.0 2.7 <5.0 <5.0 <5.0 <5.0 <5.0 17 <10 22 6.6 2640 Ash 2/11/2021 96 <1.0 12 33 6.3 J 7.7 J 40 7.8 J 82 <10 100 144.5 2040 Soil 2/11/2021 <1.0 <1.0 <1.0 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 <10 <10 <10 2040 Ash 2/11/2021 16 <1.0 2.1 <5.0 <5.0 <5.0 <5.0 <5.0 14 <10 19 16

1040/1500 Ash 2/11/2021 31 <1.0 9.6 <5.0 <5.0 <5.0 <5.0 <5.0 20 <10 36 31

--- 4.8 ng/kg --- --- --- --- 100 ng/kg --- --- --- --- 66,000,000 ng/kg

--- 4.8 ng/kg --- --- --- --- 100 ng/kg --- --- --- --- 78,000,000 ng/kg

NOTES:

Detections of target analytes at or above laboratory reporting limits are in bold TCDF = tetrachlorodibenzofuran Concentration of target analyte at or above one or more screening level TCDD = tetrachlorodibenzo-p-dioxin

PeCDF = pentachlorodibenzofuran --- = Not sampled, not analyzed, or not established PeCDD = pentachlorodibenzo-p-dioxin

* = Value is total of all reported dibenzofuran isomer concentrations HxCDF = hexachlorodibenzofuran ng/kg= nanograms per killigram HxCDD = hexachlorodibenzo-p-dioxin

CA DTSC-SL = California Department of Toxic Substances Control Screening Level - Cancer Endpoint HpCDF = heptachlorodibenzofuran EPA RSL = Regional Screening Levels (USEPA, November 2020) HpCDD = heptachlorodibenzo-p-dioxin

J = The idenitification of the analyte is acceptable; the reported value is an estimate OCDF = octachlorodibenzofuran E = Exceeds calibration range OCDD = octachlorodibenzo-p-dioxin

Table 3. Sampling Laboratory Analytical Data Dioxins by EPA Method 8290

Brush Creek Work Center 12815 Oro Quincy Highway, Berry Creek, California

Dibenzofuran* ng/kg

CA DTSC-SL: Residential Soil

Total PeCDF ng/kg

Total PeCDD ng/kg

Total HxCDF ng/kg

Total HxCDD ng/kg

Total HpCDF ng/kg

Total HpCDD ng/kg

Sample ID Sampling

Date Total TCDF ng/kg Total TCDD ng/kg

2,3,7,8 TCDD

ng/kg

OCDF

ng/kg

OCDD

ng/kg

EPA RSL: Residential Soil

2140 Soil 2/11/2021 <2.53 0.925 J 116 0.263 1.14 80.6 12.5 44.9 121 <0.632 35 <2.53 <1.26 <2.53 219 328 2140 Ash 2/11/2021 363 44.6 1,150 <1.59 0.959 J 167 15.7 20,700 623 <0.865 87 <15.9 <7.93 <15.9 35.4 4,690 1044 Soil 2/11/2021 <2.72 2.13 J 111 0.381 0.214 J 72.5 6.84 43.3 7.43 0.289 J 29.4 <2.72 <1.36 0.717 J 216 52.2 1044 Ash 2/11/2021 7.85 4.04 120 0.0651 J 1.16 11.1 2.61 175 36.7 0.831 11.9 1.62 J <1.36 <2.72 12.1 1,530

2340 Conex 2/11/2021 <2.32 4.74 170 0.205 J 0.391 J 54.9 12.2 30.9 50 0.218 J 46.6 <2.32 <1.16 <2.32 148 140 2340 Tank 2/11/2021 <2.65 1.57 J 81.5 0.31 0.234 J 58.6 8.04 93.3 18.4 <0.663 23.9 <2.65 <1.33 0.540 J 203 94.5 2340 Ash 2/11/2021 244 2.94 58.4 <0.282 16.4 6.47 1.11 J 346 177 3.57 3.5 1.57 J <1.41 <2.82 6.36 315 2640 Ash 2/11/2021 <3.27 <3.27 111 0.0819 J 1.04 50.5 3.07 2,600 52.2 2.21 47.6 <3.27 <1.63 2.74 J 103 608 2040 Soil 2/11/2021 6.7 1.06 J 109 0.499 0.664 75.7 11 53.8 180 1.39 42.1 4.28 <1.23 <2.46 241 224 2040 Ash 2/11/2021 48.5 2.15 J 382 0.345 0.212 J 45.8 8.55 2,030 765 1.11 34.7 1.35 J <1.20 <2.40 95.3 5,400

1040/1500 Ash 2/11/2021 10.5 1.68 J 917 0.0744 J 0.426 J 13.2 3.56 4,620 412 1.01 26.1 <3.26 0.225 J <3.26 8.95 933 Extra Conexes Soil 2/11/2021 32.9 18.1 805 0.311 3.23 27.5 8.46 759 34.6 3.43 16.6 1.20 J 0.149 J <2.30 36.6 507 Extra Conexes Ash 2/11/2021 46.6 <3.31 299 0.489 13.1 132 103 1,150 1,180 35.1 14.5 <3.31 0.358 J <3.31 16.7 24,000 Fuel Container Pile 2/11/2021 7.65 <2.63 67.5 0.502 0.278 J 73.9 14.4 62.6 1.75 5.42 43.3 5.31 <1.32 <2.63 304 54.2

--- 0.11 --- 16 71 --- --- --- 80 --- 820 --- --- --- --- ---

31 0.68 15,000 160 --- --- 23 3,100 400 390 0.76 390 390 0.78 390 23,000

NOTES:

Detections of target analytes at or above laboratory reporting limits are in bold Concentration of target analyte at or above one or more screening level mg/kg=

J = CA DTSC-SL = California Department of Toxic Substances Control Screening Level - Cancer Endpoint

EPA RSL = Regional Screening Levels (USEPA, November 2020)

EPA RSL: Residential Soil

Chromium mg/kg

Cobalt mg/kg

Copper mg/kg

Lead mg/kg

Sample ID Sampling Date

Antimony mg/kg

Arsenic mg/kg

Barium mg/kg

Table 4. Sampling Laboratory Analytical Data CAM-17 Metals by EPA Method 6010B

Brush Creek Work Center 12815 Oro Quincy Highway, Berry Creek, California

Not sampled, not analyzed, or not established milligrams per killigram The identification of the analyte is acceptable; the result is an estimate.

Zinc mg/kg

CA DTSC SL: Residential Soil

Molybdenum mg/kg

Nickel mg/kg

Selenium mg/kg

Silver mg/kg

Thallium mg/kg

Vanadium mg/kg

Beryllium mg/kg

Cadmium mg/kg

2140 Soil…