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Dana Parry - 5 - 27 June 2019 <br />Table of SMP -Related Site Reports <br />Waste Units <br />Location <br />SMP -related Site Reports <br />North Waste <br />17100 and 17200 <br />Summary of SWIS Site Investigation Waste <br />Unit (NWC) <br />Murphy Parkway <br />Characterization/Disposal, 15 June 2015, AGE <br />South Waste <br />17100 and 17200 <br />Summary of SWIS Site Investigation Waste <br />Unit (SWC) <br />Murphy Parkway <br />Characterization/Disposal, 15 June 2015, AGE <br />Excavation and Materials Management Plan <br />(EMMP), 9 March 2018, Brusca Associates <br />Addendum to EMMP, 22 March 2018, Brusca <br />Associates <br />17100 Murphy <br />Waste Unit 1 <br />Parkway portion <br />Revised Excavation and Materials Reuse Workplan, <br />(WU1) <br />(Parcel B) <br />23 May 2018, Brusca Associates <br />WU1 Clean Closure Plan and Work Plan Addendum <br />Waste Unit 1 <br />500 E Louise Ave <br />(Excavation and Materials Management Plan), 22 <br />(WU1) <br />(Parcel A) portion <br />February 2019, AGE <br />5. Overall, the various site-specific scenarios provided in the Subsurface Construction <br />Management Protocols sections of the SMP would be significantly easier to follow and <br />implement with flow diagrams. Developing flow diagrams and incorporating the <br />information referenced from separate reports in attachments to the SMP and then <br />referencing the appropriate SMP attachment in the flow diagram will clarify the steps to <br />handle each scenario indicated. <br />6. Section 1.1 for Site background states that the facility currently contains active <br />transformers. Although, staff was not allowed on the western portion of the site during <br />the site visit on 30 April 2019, this is one of the areas of concern on the western portion <br />of the site that needs to be included in the SMP for it to cover sitewide, as noted in <br />Comment 1. Other areas include potential waste present beneath the new asphalt <br />parking lot and rail spur in the western portion of the site. <br />7. The SMP refers to onsite material reuse over waste disposal offsite. Please refer to the <br />Revised Waste Materials Reuse Workplan, Waste Unit 1 Materials dated 23 May 2018 <br />by Brusca Associates for procedures and protocols for materials reuse. In addition, <br />Regional Water Board staff must be provided with appropriate analytical testing showing <br />the material meets reuse screening levels prior to implementation. <br />8. The Previous Environmental Investigation and Remediation section 1.1.3 for WU1 <br />indicates that extensive analyses of materials from WU1 demonstrated that the landfilled <br />material was not hazardous, and the excavated material was utilized in the foundation of <br />the building constructed on Parcel B. The summary for WU1 needs to be clarified to <br />indicate that landfilled material from WU1 exceeded some screening levels which <br />resulted in its remediation with a process called fixation in the concrete foundation of the <br />warehouse structure on Parcel B. Fixation is a soil remediation process that involved <br />stabilizing contaminated material by mixing it with other earthen material in a binding <br />process that prevent- vv"ate, exposure and contaminant migration fro�'ii tr�at�d excavated <br />material. The fixation work was implemented under an approved work plan with Regional <br />Water Board oversight to address the material exceeding screening levels. Fixation <br />