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LFR Levine-Fricke Response: Mr. Holson of Pacific Legacy Inc., concluded that a survey for historic resources would not result in the identification of any resources for several reasons. First, the entire project area has been significantly excavated(to depths exceeding 50 feet below original grade in most areas). Second, no subsurface ground disturbance will occur in areas outside of the project area. Third, the potential existence of the Tesla Branch of the Western Pacific Railroad (if it exists)would exist outside the project area. Based on this information, remnants of any surface or subsurface features would have been previously removed or obliterated many years ago when the site was mined as a gravel quarry. 4. Comment: Page 25, Section 5, Cultural Resources, Subsection(d),paragraph 1: It seems that a "Less than significant impact" finding is more appropriate considering that an archaeological survey was not conducted. Response: Disturbance of cultural and human remains is extremely unlikely due to the fact that the project site was heavily excavated to a depth approaching 50 feet over many years. An archaeological survey was not considered to be necessary by the expert, Mr. Holson of Pacific Legacy, Inc for the three reasons stated in response to comment 3. First, the entire project area has been significantly excavated(to depths exceeding 50 feet below original grade in most areas). Second, no subsurface ground disturbance will occur in areas outside of the project area. Third, the potential existence of the Tesla Branch of the Western Pacific Railroad(if it exists)would exist outside the project area. Comments from and Responses to the San Joaquin Valley Air Pollution Control District (SJVAPCD): 5. Comment: Soil excavation on a site greater than 40 acres may require a Dust Control Plan per Air quality Rule 8021. The Tracy Tire Fire Site is approximately 50 acres: Response: On September 11, 2003, Chris Sherman of DTSC contacted the SJVAPCD Compliance Section Chief, Tony Scott(209-557-6400)to obtain guidance regarding the excavation of soil and ash on the Tracy Tire Fire Site. Mr. Scott explained that Air Quality Rule 8021 specified that work involving an area of excavation greater than 40 acres or the removal of greater than 2,500 cubic yards of material per day would require a formal Dust Control Plan. Work for the project will involve the excavation of approximately 13.4 acres and less than 2,500 cubic yards of material per day. Therefore, it was agreed that a formal Dust Control Plan would not be required. Dust control measures will be undertaken during the removal project and are detailed in the RAP and will be included in the Tracy Tire Fire Remediation Work Plan. Page H-2 Final_RAP_Tracy_9.18.03(final).doaLFR