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Work Plans for Site Investigation and Remedial Action Plan for Waste Excavation at a <br /> Portion of the Waste Disposal Site <br /> • Available background information indicates that a work plan was not prepared and submitted for <br /> regulatory agency approval(s) prior to conducting the initial site investigations. The work plan <br /> typically includes: site identification and description; states the project objectives; descriptions of <br /> regional and/or site specific site geology and hydrogeology;a review and summary of background <br /> information; historical aerial photographs and summaries; information on regulatory <br /> requirements/notifications; references a site health and safety plan and as necessary, a <br /> community health and safety plan; describes in detail the planned scope of work (SOW) and <br /> methodologies and rationale for what is proposed; the analytical testing program and rationale; <br /> sample collection plan and methodologies; and reporting requirements. <br /> • Typically prior to waste excavation, a remedial action plan is prepared and submitted to the LEA <br /> and other regulatory agencies for their comments and approval(s). It appears that such a plan that <br /> includes an evaluation of remedial alternatives based on planned future site use was not prepared <br /> based on available documents provided for review. It is understood that there were time <br /> constraints. A brief 'Work plan" was submitted for planned waste excavation at a portion of the <br /> waste disposal site(please refer to the plan for specific comments included in Section 4.0). <br /> Ninyo&Moore 1 500 E.Louise Avenue,Lathrop,San Joaquin County,California 1 104690095 1 August 11,2017 g <br />