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Soil Cover Work Plan, Former Cullet Staging Area 1 1 Pilkington North America, Inc. 500 East Louise Avenue, Lathrop, CA a ntea g ro u p Antea Group Project No. PILKCU3215 3.0 REGULATIONS In December 2012, the SJCEHD performed a quarterly inspection and informed PNA that to meet minimum state requirements, a one (1) foot thick layer of soil would need to be placed over the cullet staging area and graded to allow runoff and prevent ponding and erosion of the soil cover. Section 20820, Drainage and Erosion Control, of the California Code of Regulations (CCRs), Title 27, Division 2 (Solid Waste), Chapter 3, Subchapter 4 states disposal sites require a drainage and erosion control system that shall be designed and maintained to: (1) Ensure integrity of roads, structures, and gas monitoring and control systems; (2) Prevent safety hazards; and (3) Prevent exposure of waste. Item 1 is not applicable to the site since the site is essentially flat and there has been minimal erosion that would impact roads or structures. Additionally, gas monitoring and control systems are not present at the site since the inert cullet and other inert material does not generate gases through a decomposition process. Item 2 is applicable since the exposed cullet and inert material could present a potential safety hazard to trespassers who illegally enter the site. Item 3 is applicable since vegetative growth at the site is minimal with wind and rainfall continuing to erode soil from around debris, hence exposing the debris for potential human or environmental contact. Antea Group has researched and evaluated numerous options for covering the former cullet staging area that will satisfy the intent of the state requirements to minimize the exposure of the debris as a safety hazard. 4.0 COMBINATION ENGINEERED COVER The method identified by the SJCEHD personnel for the combined area to mitigate potential impacts from surface debris was to cover the site with one (1) foot of soil. Based on the general vegetative cover of the levee and the surrounding area, the existing on-site soil appears to be lacking in sufficient nutrients to ensure sufficient root development and sustain plant growth that would limit erosion from the elevated soil surface. Due to this limited ability to support plant life, the use of blended agricultural soil topped with a hydro -seed application consisting of native grasses and clover is proposed. The use of the blended agricultural soil would 3 www.anteagroup.com