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O�LIR OR NI• <br />Water Boards <br />Central Valley Regional Water Quality Control Board <br />15 March 2019 <br />Dana Parry <br />Reynolds and Brown <br />1200 Concord Ave, Suite 200 <br />Concord, CA 94520 <br />EDMUND G. BROWN JR. <br />•"eN Vis,' OOVERNOP <br />MATTHEW IIEZ <br />jiCNI, <br />1011 <br />SECPETARY FOR <br />ENVIRONMENTAL PROTECTION <br />CONDITIONAL CONCURRENCE FOR WU1 CLEAN CLOSURE PLAN AND <br />WORK PLAN ADDENDUM (EXCAVATION AND MATERIALS MANAGEMENT <br />PLAN), FORMER PILKINGTON NORTH AMERICA INC, 500 EAST LOUISE <br />AVENUE, LATHROP, PARCEL A (PARCEL APN 198-120-08), SAN JOAQUIN <br />COUNTY <br />Staff of the Central Valley Regional Water Quality Control Board.(Regional Water Board) have <br />reviewed the report dated 22 February 2019 WU1 Clean Closure and Work Plan Addendum <br />(Work Plan) for the Former Pilkington North America -Lathrop Facility located at 500 E Louise <br />Ave, Parcel A, APN 198-120-08 (Site), and submitted on your behalf by Advanced <br />GeoEnvironmental (AGE). The Workplan was requested during excavation and remediation <br />activities on the neighboring property Parcel B (APN 198-120-09), when it was readily <br />observable that landfilled waste material extended onto the Site (APN 198-120-08) along its <br />eastern property line. There are two suspected disposal areas on Parcel A: (1) an area located <br />on the southwestern corner of the parcel near trench T-29; and (2) the area located on the <br />southwestern border of the parcel where Waste Unit 1 (WU1) has been identified to extend onto <br />Parcel A. This Work Plan addresses only area (2) on Parcel A where WU1 has been identified. <br />While no investigations have yet been performed in WU1 on Parcel A, the same constituents of <br />concern (COCs) from Parcel B have been appropriately applied and include: volatile organic <br />compounds (VOCs), •dioxin/furans, polychlorinated biphenyls (PCBs), total petroleum <br />hydrocarbons (TPH), semi volatile organic compounds (SVOCs), polychlorinated aromatic <br />hydrocarbons (PAHs), and Title 22 metals. AGE estimates the remaining disposal area WU1 on <br />Parcel A to be approximately 0.14 to 0.28 acres, but the limits of WU1 on Parcel A will be <br />determined during excavation and removal activities. It is anticipated that the area of WU1 <br />waste beneath Parcel A is of similar character and composition to the waste found to the south <br />on Parcel B. As such, this Work Plan utilizes the Excavation and Materials Management Plan <br />(EMMP) dated 9 March 2018 prepared by Brusca Associates, Inc (BAI) for the portion of waste <br />located in WU1 on Parcel B that was characterized, remediated, and verified. <br />Proposed work will be conducted in accordance with the procedures outlined in Section 6 of the <br />EMMP. All excavated waste will be removed from the site and properly disposed. Verification <br />samples will be collected to confirm solid waste was removed to below acceptable screening <br />levels and the soil below the excavated waste is not impacted above acceptable screening <br />levels. AGE proposes to collect verification samples on a grid -pattern at 50 -foot intervals on <br />Parcel A totaling 7 samples. The Work Plan indicates that a storm drainpipe will be installed in <br />the location of WU1 on Parcel A. All excavated soil from the installation of the storm drainpipe <br />KARL E. LONGLEY SCD, P.E., CHAIR 1 PAMELA C. CREEDON P.E., BCEE, EXECUTIVE OFFICER <br />11020 Sun Center Orlve #200, Rancho Cordova, CA 95570 1 www.waterboarcis.ca.gov/centralvalley <br />HECYCLEU HAPEH <br />