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Snyders Sanitary Garbage Disposal Site Page 2 SWIS No. 39-CR-0031 the Work Plan. This trenching will be used to determine if buried waste is present and to visually determine the nature and thickness of existing cover. No samples are proposed to be collected and the excavated material will be returned to its place of origin and compacted with the excavator's bucket. On March 20, 2024, the LEA requested assistance from CalRecycle to review the technical aspects of the document. The following comments are for your consideration: 1. Figure 4 shows the proposed exploratory trench locations which are based on information from a limited field investigation conducted in October 2002 (October 2002 Study) by Ninyo & Moore (provided as Attachment B in the Work Plan). It appears that the locations of the trenches somewhat align with the estimated extent of debris and/or refuse provided in Figure 1 of Attachment I with the following exceptions: a. Area between Trench Location 1 and the northern property boundary. b. Area along the southwestern corner near Trench Locations 26 and "ASH 1." The Work Plan should include trenching in these areas to fully delineate the extent of the waste shown in Attachment I. 2. The Work Plan states that trenching will be used to determine if buried waste is present but is unclear of how they will confirm the lateral and vertical limit of waste. Trenching should be used to find these limits of the waste by digging both laterally and vertically until native is discovered. It is our understanding that Figure 1 in Attachment I represent an "estimated" extent based on interpolations of the data only. The October 2002 Study did not fully delineate the waste extent. As such, the Work Plan should be revised to describe how trenching will continue until native soil is encountered both laterally and vertically on the property so a more accurate figure can be produced. 3. The Work Plan does not propose collecting any samples for laboratory analysis. Since the trenches are in different areas from the October 2002 Study, we suggest that the waste discovered be sampled for the following chemicals that were found in the October 2002 Study using the same methods: a. CAM 17 Metals b. Soluble Threshold Limit Concentration (STLC) and STLC Deionized Water (STLC DI-WET) for specific Title 22 metals that exceeded 10 times their respective thresholds in accordance with federal and state hazardous waste criteria. c. Toxicity Characteristic Leaching Procedure (TCLP) by USEPA Method 6010/7471A for those samples containing the highest metal 1001 I Street, Sacramento, CA 95814 1 P.O. Box 4025, Sacramento, CA 95812 www.CaIRecycle.ca.gov 1 (916) 322-4027