CORRESPONDENCE_2017 - Laserfiche WebLink

Home Browse Search

0 3 GENERAL SUMMARY The following are general comments related to review of available background information pertaining to the Pilkington NA WDS. The comments are organized by subject and are in reference to specific reports/documents, and/or the understanding of the described WDS characteristics. Comments pertain to data gaps, missing justification, inconsistent data, and/or defining industry standard expectations for documents. The reader should refer to the specific summaries of documents and comments related to individual documents included as Section 4.0 for more detailed information and to Appendix A for historical aerial photographs and Appendix B for documents, emails and other background information that was provided. Submittal of Information and Documents to Regulatory Agencies The review and summary of background information and documents, primarily beginning at the time of site investigation to present, was complicated for reasons indicated below. (The reader is referred to Section 4.0 for more specific information to support the following statements.) • Titles of some documents did not necessarily correspond to, or seem appropriate for what was contained in the document. • Documents that were submitted to regulatory agencies were often incomplete with respect to what is typically included in such reports or plans. Significant information was typically missing and often data was not presented and compiled into a format to facilitate review by regulatory agencies. • Typically, prior to conducting a waste disposal site investigation, the proposed SOW is summarized in a site investigation and/or LFG investigation work plan. Similarly, prior to conducting waste excavation, typically a remedial action plan is submitted; for review, comments, and approval prior to conducting the remedial action. Following completion of field work, receipt of analytical data, data compilation and analysis, the results should be summarized into a site investigation, LFG, or waste excavation etc. report. However, for this project, it appears that a significant amount of information was submitted to regulatory agencies incompletely. This resulted in multiple regulatory agency requests for additional information and subsequent numerous, submittals of what was requested. • It appears from review of background information and documents that the results of site investigations and waste excavation remedial action activities were often provided to the LEA(and other regulatory agencies) as draft documents. Typically regulatory agencies only review and provide comments to finalized plans and reports and not partial and/or draft documents because they simply do not have the time, and because a signed document typically requires the consultant to adequately compile, and succinctly and completely summarize the data. (Signatures of registered professionals were on some draft documents.) • Complicating the review and summary of information related to this project was the use of inconsistent terminology, atypical wording, and typographical errors in numerous documents and correspondences. More specifically, the wording in documents and correspondence was often difficult to understand. For example, the area of waste excavation remedial action at the western property boundary is referred to as "north cell/south cell, deep soil (not waste) excavation area, north waste cell/south waste cell" or"waste cells."The northern waste disposal area is referred to by numerous terms including "pile of waste glass, waste pile area, former pile area, former glass debris and dust' and "glass handling area." In the most recent draft PCLUP, it is referred to as the Ninyo&Moore 1 500 E.Louise Avenue,Lathrop,San Joaquin County,California 1 104690095 1 August 11,2017 4