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Responses to <br /> San Joaquin County Environmental Health Department (EHD) <br /> Review Comments (August 2023) on the <br /> Draft Site Characterization Work Plan for Riverbank City Dump <br /> (dated July 2023) <br /> 1. The two key objectives of the Site Characterization investigations are to: determine the <br /> approximate horizontal and vertical extents of the disposal site and to characterize the <br /> content of the fill as Resource Conservation and Recovery Act (RCRA) hazardous, California <br /> Hazardous or non-hazardous waste. The Site Characterization Plan does not describe how the <br /> site will be characterized. The plan shall include a characterization of the site conditions to <br /> determine the horizontal and vertical extent of waste and the character of wastes present,the <br /> estimated volume of waste in place and the levels and extent of any soil contaminations. <br /> Response: Page 1 of the Work Plan has been updated to include "Objective", which includes <br /> language above. Section 3.0, Review of Records, does discuss site conditions based on the <br /> limited information available, as well as additional information provided in Appendix A. <br /> Section 3.0 and Appendix A were both used to update and further develop Section 4.0, Site <br /> Characterization Work Plan, to identify proposed intrusive field investigation activities to be <br /> conducted. <br /> 2. The Work Plan does not include information on frequency of soil sampling and analysis of <br /> the solid waste removed from the site. <br /> Response: Refer to changes in Section 4.0, Site Characterization Work Plan, which has been <br /> updated to address this comment (see page 4). <br /> 3. All excavated solid waste shall be transported to a permitted solid waste facility for proper <br /> disposal or recycling. Disposal records shall be provided for all waste removed from the site. <br /> Response: Refer to changes in Section 4.0, Site Characterization Work Plan, which has been <br /> updated to address this comment (see page 4). <br /> 4. The excavated soil cannot be used as fill material; only clean soil shall be used to backfill. <br /> Response: Refer to changes in Section 4.0, Site Characterization Work Plan, which has been <br /> updated to address this comment (see page 4). <br /> 5. The Health and Safety Plan should be submitted to the LEA for review and approval. <br /> Response: Refer to changes in Section 4.0, Site Characterization Work Plan, which has been <br /> updated to address this comment (see page 5). <br /> 6. Operator should obtain appropriate permits from the EHD to conduct site work. <br /> Response: Refer to changes in Section 4.0, Site Characterization Work Plan, which has been <br /> updated to address this comment (see page 5). <br /> z:\projects\sitelogiq\site characterization work plan\reg agency comments\resp to lea comm—sept 2023.docx <br />