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z:\projects\sitelogiq\site characterization work plan\reg agency comments\lea comments_dec 2023\rtc attachment_121123.docx <br />3. Section 2.0 and Section 3.0 of the Work Plan presume the types of wastes that may <br />have been disposed of at the Site, however, it is unknown. The sample Health and <br />Safety Plan provided in Appendix C of the Work Plan identifies methane gas and volatile <br />organic compounds as a potential hazard. At a minimum, the Work Plan should include <br />monitoring for landfill gas (i.e., methane and volatile organic compounds) during the <br />site investigation as part of the Health and Safety Plan. The information collected from <br />this monitoring as well as the characterization of the disposal area may be used to <br />determine whether landfill gas monitoring compliant with CCR Title 27 Section <br />21160(b) is warranted. <br /> <br />RESPONSE: The potential for landfill gases from this site is negligible. However, <br />monitoring for landfill gases will be utilized with field instruments during excavations <br />and sampling (methane and/or OVA). Section 3.0 (page 4) has been revised to add <br />this information. <br /> <br />4. Section 4.0 of the Work Plan states that the LEA will be notified when excavation <br />activities occur. It is suggested to notify the LEA with a specified timeframe such as at <br />least one week or 5 days prior to ensure enough time is provided to accommodate <br />staff. <br /> <br />RESPONSE: Section 4.0 has been revised to reflect that the LEA will be notified at least <br />one week or 5 days prior to excavation activities occurring. <br /> <br />5. Section 4.0 states that any excavated material will be transported off-site to a <br />permitted solid waste facility and that clean soil will be used to backfill. The Work Plan <br />should include the procedures for selecting, testing, and documenting the fill material <br />to ensure it is clean. More information can be found on the Department of Toxic <br />Substances Control’s webpage under their “Advisory Clean Imported Fill Material Fact <br />Sheet,” here is the link: https://dtsc.ca.gov/information-advisory-clean-imported-fill- <br />material-fact-sheet. <br /> <br />RESPONSE: Procedures for verifying the adequacy of import soils will be consistent <br />with the Department of Toxic Substances Control (DTSC) webpage under their <br />“Advisory Clean Imported Fill Material Fact Sheet” (https://dtsc.ca.gov/information- <br />advisory-clean-imported-fill-material-fact-sheet). Section 4.0 has been updated to <br />reflect this information. <br /> <br /> <br />6. Section 4.0 states that although hazardous materials are not expected to be present, <br />a contingency protocol will be in place should such materials be identified. It is unclear <br />what the “following contingency protocol” is. The Work Plan should be revised to <br />include this information. <br /> <br />RESPONSE: A contingency plan for hazardous materials is included in Appendix B and <br />Section 4.0 of the Work Plan has been amended, as needed.