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LFR Levine-Fricke and filters shall be properly disposed of. All PPE waste shall be transported to an appropriate disposal facility. Piping and diversion dams may be used to prevent potential run-on during a rain event. Each loading area will be reviewed and any surface-water control measures will then be implemented on an "as-needed" basis. 7.2.3 Removal Activities The Site consists of 34 distinct burn-pile areas. The burn-pile areas have been grouped into three separate units for phased excavation(Units 1 through 3). Unit 1 is the northernmost unit and consists of burn-pile areas 1 through 5. Unit 2 is located adjacent to Unit 1 to the south and consists of burn-pile areas 6 through 12. Unit 3 is located adjacent to Unit 2 to the south and east, and consists of burn-pile areas 13 through 34 (Figure 5). Removal of ash, burned material, and visibly affected soil will proceed in phases. The initial phase will consist of excavation within Unit 1. Visibly affected soil in Unit 1 is anticipated to exist to a depth of approximately 24 inches in each of the burn pile areas. Visibly affected soil from Unit 1 will be considered Class I non-RCRA hazardous waste(based on the preliminary RI/FS data)and will be transported to a State- permitted Class I disposal facility. Table 2 provides a summary of the waste characterization reference concentrations for classification of Class I non-RCRA waste and Class I RCRA waste. Based on the data collected during the preliminary RI/FS, it is not anticipated that waste would be characterized as Class I RCRA waste at this Site, but the criteria are listed in Table 2 for reference. Soil samples that contain concentrations lower than the specified action levels for Class I non-RCRA waste will be evaluated for potential classification as Class II designated waste or Class III non-hazardous soil. The Class II designated waste description will be dependent upon the requirements of individual landfills which will be solicited for a disposal quote. Each Class II landfill(permitted for storing Class II designated waste)has unique permit requirements based on the landfill's operating permit. Likewise, if the concentrations of potential contaminants qualify for a Class III sanitary landfill, the decision will be made based on analytical results, appearance of the soil, and direction from the CIWMB project manager/engineer, to transport the soil off-site or maintain the soil on site. The initial excavation phase will be followed by confirmation sampling to verify that the Class I non-RCRA hazardous waste has been removed from the area. Confirmation sampling will proceed according to the Sampling and Analysis Plan for the project (Section 7.4). Meanwhile, ash, burned material, and visibly affected soil will simultaneously be excavated from another burn pile. If confirmation sampling indicates the presence of Class I non-RCRA hazardous waste soil remains in the Unit, additional excavation shall be performed as indicated by the analysis results. Additional confirmation sampling shall follow any additional excavation, and the sequence Page 22 Final_RAP_Tracy_9.18.03(final).doc