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ow <br />CALIFORNIA <br />Water Boards <br />27 June 2019 <br />Dana Parry <br />Reynolds and Brown <br />1200 Concord Ave, Suite 200 <br />Concord, CA 94520 <br />04 <br />GAVIN NEWSOM <br />GOVEflNOR <br />.TARED BLUMENFELD <br />SECRETARY FOR <br />ENVIRONMENTAL PROTECTION <br />COMMENTS FOR SOIL MANAGEMENT PLAN, FORMER PILKINGTON NORTH <br />AMERICA INC, 500 EAST LOUISE AVENUE, LATHROP, APN 198-120-08 AND <br />198-140-16, SAN JOAQUIN COUNTY <br />Staff of the Central Valley Regional Water Quality Control Board (Regional Water Board) have <br />reviewed the report dated 14 May 2019 Soil Management Plan (SMP) for the Former Pilkington <br />North America (PNA) Facility located at 500 E Louise Ave (Site), and submitted on your behalf <br />by EKI Environment & Water (EKI). As discussed during a meeting on 24 April 2019 between <br />Regional Water Board staff and Earl James from EKI and Robert Doty of Cox, Castle, and <br />Nicholson LLP, the SMP was prepared to comply with Regional Water Board issued Water <br />Code Section 13267 Order No. R5-2019-0886 dated 12 April 2019 by providing waste and soil <br />management protocols and procedures for the entire site to be implemented when encountering <br />previously unknown waste pits and areas of obvious soil impacts (such as discoloration, <br />staining, odors). While soil management plans have previously been developed and <br />implemented for discrete waste pit locations at the site, it was agreed by all parties present in <br />the 24 April 2019 meeting that a comprehensive SMP covering the entire site would be <br />appropriate to address potential waste discovered during the remaining future site <br />redevelopment activities. <br />Site Background <br />The Former PNA Site consists of a large rectangular parcel (APN 198-120-08) and an second <br />irregularly-shaped parcel to the northeast (APN 198-140-16) totaling approximately 133 acres. <br />The Former PNA glass manufacturing facility with associated air pollution control system <br />operated for approximately 50 years and included a large structure formerly used for safety and <br />security glass manufacturing and distribution, two smaller stand-alone metal warehouse <br />buildings, sanitation plant, stormwater reservoir, spray fields and asphalt parking areas. Several <br />manufacturing components have been demolished pursuant to permits from the City of Lathrop <br />inrli Aim the furnace, furnace stack conveyance machinerxi abode nrnl Ind stnrana tank and <br />other facilities associated with the manufacturing process. Past investigations have revealed <br />KARL E. LONGLEY SCD, P.E., CHAIR I PATRICK PULUPA, ESO., EXECUTIVE OFFICER <br />11020 Sun Center Drive #200, Rancho Cordova, CA 95670 I www.waterboards.ca.gov/centralvalley <br />Q RECYCLED PAPER <br />