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Enclosure 1 Kearney-KPF Facility Closure Plan Deficiencies (EPA ID No CA0981429715) INTRODUCTION The response to the comments on the Kearney-KPF (referred to hereafter as "the facility") Closure Plan should be in the form of revised pages that can be integrated with the original Closure Plan, or an addendum to the Closure Plan, or a totally revised Closure Plan. If revised pages are submitted, each page submitted should indicate whether it is a revision to a page in the original plan or a new page. not contained in the original plan. The revision date should be noted on the revision submittal. Also, identify on a copy of this deficiency letter the page in the revised plan that addresses each comment. If an addendum is submitted, it should be bound in similar fashion to the Closure Plan. Paragraphs or sections that are changed should be reproduced in totality utilizing graphical highlighting of specific changes of that section. Both documents together will constitute the Closure Plan and will be made available to the public during the Public Notice period. The following elements shall also be incorporated into the Closure Plan in accordance with applicable sections of 40 CFR 264 and 265, and Titles 22 and 23 of the California Code of Regulations. GENERAL COMMENTS The following comments are general in nature. 1. Regardless of the Closure Alternative selected, the facility shall prepare a Post Closure Plan in accordance with 40 CFR 265. 11 because of groundwater contamination beneath the facility. The facility shall submit a Post Closure permit application within 60 days after submission of the Closure Plan. 2 . The Facility shall submit a work plan for all major phases of Closure which will contain schedules for all tasks, associated reports and completion dates. The work schedule/plan will address, as a minimum, the following required reports: Groundwater Assessment Plan, Groundwater Assessment Report, Groundwater Health Based Risk Analysis Report, Groundwater Remediation Plan, Soil Assessment Plan, Soil Assessment Report, Soil Assessment Health Based Risk Analysis, Alternative Feasibility Study, Design and Specification Report, Construction Quality Assurance Plan, Health and Safety Plan, Post Closure Permit Application, Post Closure Plan, Letter of Closure Certification, and Closure Certification Report.