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Waste Excavation Remedial Action • Wastes excavated at two locations near the western property boundary and south of the covered waste disposal area initially evaluated by trenches T1 to T23,were reportedly disposed of offsite at a "Class II" WDS (Forward Landfill), and although not known, likely because they were not acceptable for disposal to a local Class III WDS. Because no information has been provided to suggest different waste streams were generated at the glass manufacturing facility and therefore different types of wastes disposed of at the WDS, how can it be concluded that the site is not negatively impacted by historical usage?The fact that wastes were disposed of to a"Class II WDS suggest the site was the location of potentially hazardous/hazardous wastes. In addition, as previously mentioned, as far back as the early 1980's, documentation suggests that the wastes (baghouse dust/glass batch dust)generated at the facility must be removed from the property and properly disposed of at a Class I Landfill. • As previously indicated, trench logs for T24 to T110 are not available. Some of these 86 trenches were at the locations of waste excavation and without these logs, and summary of information onto appropriate figures, the lateral and vertical extent of wastes in this area with respect to waste excavation is not known. • Documentation to support the statement that waste removal was complete at two locations of the WDS was not provided. There did not appear to be a report indicating the lateral and vertical extent of wastes based on site investigation in this area. In fact, there does not appear to be a report summarizing trenches T24 to T110. Because of suspected time constraints, at a minimum, a figure could have been prepared at that time indicating whether wastes were present or absent and waste thickness, as applicable with an estimate of the area to be excavated based on this information. • There is an absence of documentation to confirm the adequacy of waste removal at the locations excavated. Daily field reports, confirmation sampling and analytical testing and a figure indicating the lateral and vertical extent of wastes prior to excavation and the extent of wastes excavated, with confirmation sample locations and analytical data needs to be provided. • It is not clear why waste excavation was only at two locations. Why were the two areas of wastes excavated and the waste area to the north (corresponding to the northwestern portion of the proposed warehouse building) not also excavated? Wastes were not required to be excavated at these two locations or anywhere else at the site. If wastes were planned to be excavated, then it seems that the preferred location would be underlying the northwestern most portion of the proposed building footprint. Correspondence and the titles of some document(including the most recent PCLUP), suggests the reason for the waste removal may have been to obtain a clean closure determination for the WDS. However, this would not be the case, since wastes remain at the site after the planned limited excavation was completed. In addition, at best, a partial clean closure could be requested; however, information to support partial clean closure would need to be provided. Perhaps the waste area to the north was not planned to be excavated since it had been covered. Because of how the Project documents were written, rationale for why waste was removed at the western property boundary and not to the north, was not provided. Other remedial alternatives such as covering the wastes instead of removal at locations outlying building structures or reconsolidation of wastes to other onsite locations are typically a less expensive remedial action. • Waste manifests and the total volume of wastes excavated and disposed of offsite needs to be provided to the regulatory agencies. Ninyo&Moore 1 500 E.Louise Avenue,Lathrop,San Joaquin County,California 1 104690095 1 August 11,2017 1