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Soil Cover Work Plan anteagroup Former Cullet Staging Area Pilkington North America, Inc. 500 East Louise Avenue Lathrop, California 1.0 INTRODUCTION Antea®Group is pleased to submit this Soil Cover Work Plan on behalf of Pilkington North America, Inc. (PNA) for the Former Cullet Staging Area located at 500 East Louise Boulevard in Lathrop, California (Figure 1). Cullet is broken glass and associated material that is generated during the glass manufacturing process that may or may not be recycled as part of the production process. The San Joaquin County Environmental Health Department (SJCEHD) has requested that a soil cover be placed over the former staging area. The former cullet staging area is shown on Figure 2. The purpose of this work plan is to identify and present a cost effective option that meets the SJCEHD's request for covering the area. Representatives from PNA, SJCEHD, and Antea Group met at the SJCEHD offices on Friday February 8, 2013 to discuss the site and to gain understanding of the request for soil coverage of the site. Although the site is within a fenced and secured property, there remains a limited area that has exposed cullet, metal, and plastic. Additionally, and to a lesser extent, concerns were expressed about the potential for surface ponding of water, erosion, and possible increased infiltration of surface water. It was agreed that PNA would coordinate with Antea Group to prepare a work plan that would address the concerns of the SJCEHD. During the meeting, County personnel presented a file that contained a letter from 1966 confirming that PNA had entered into an agreement with Brown Sand and Gravel to dispose of cullet within one of the permitted landfill facilities located at Brown Sand and Gravel. Based on the location of the former cullet staging area, it is presumed that the cullet was moved from the plant to the staging area until sufficient quantities had accumulated which were then transported to the permitted landfill for disposal. 2.0 SITE DESCRIPTION The site is part of the PNA glass manufacturing plant located at 500 East Louise Avenue in Lathrop, California (Figure 1). Structures at the PNA facility include a bus garage, glass manufacturing and packaging plant, offices, a paved lot, multiple cullet and recycled glass storage areas, two water towers and a diesel above ground storage tank. Approximately 14 acres of undeveloped and vacant land are present south of the plant. The PNA property is fenced and posted to secure the site from public access and is routinely patrolled by security personnel. 1 www.anteagroup.com