SITE INFORMATION AND CORRESPONDENCE

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• i -2- 3 . The Facility shall submit to DHS a Groundwater Assessment Report and a Soil Assessment Report within 90 days after the respective completion of the last laboratory report. 4 . Groundwater beneath the facility has not been fully characterized. There is groundwater contamination. The Facility shall submit a Groundwater Remediation Plan within 60 days after submittal of the Groundwater Assessment Report. 5. DHS will determine whether or not the Risk Assessment Report shall incorporate either separately or together the Soil Assessment Report and the Groundwater Assessment Report. The Facility shall submit a Risk Assessment Report within 60 days of site characterization to DHS for review and approval. 6. If the facility closes Ponds 1 (and Dry Well) and 2 and leaves wastes in place, the facility must identify designated wastes as defined in Subchapter 15 of Title 23 , and take appropriate closure measures. This information will be required for the RWQCB to write Waste Discharge Requirements (WDRs) for the facility. 7 . Reference Appendix E. If wastes are left in place, 22CCR 67288 (f) (16) becomes applicable. This requires that "the owner or operator shall provide in the closure plan predictions of the magnitude of the drops in elevation that will occur at various portions of the top surface of the final cover as a result of settling and subsidence. The prediction shall account for compression of material underlying the liner (or underlying the waste if there is no liner) and compression of the liner, waste, fill and cover. The prediction of the drop in elevation due to compression shall account for immediate settlement, primary consolidation, secondary consolidation and creep, liquefaction and dynamic consolidation due to earthquake loads. " 8 . None of the alternatives specifically addresses the Dry Well adjacent to and part of Pond 1. Closure of the Dry Well adjacent to Pond 1 shall be addressed in the Closure Plan. 9 . The facility must clearly demonstrate whether or not Land Disposal Restrictions apply to all of the alternatives. 10. If the facility selects Alternative 3 , the facility shall identify and implement all Minimum Technical Requirements in the design of the liner, cap, and vadose and groundwater monitoring systems, and any other segment of the waste repository described as Alternative 3 . The facility must obtain all necessary RCRA operating permits prior to construction of the repository.