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Request for Clean Closure and Proposed Post Closure Land Use, Post Closure Land Use(Plan) Three draft PCLUPs were available for review, and only the latest was reviewed. Because this is only a draft document, only a few general comments are provided below. For more specific comments, the reader is referred to Section 4.0 of this document. • The title of this currently working draft document includes "Request for Clean Closure."There are significant requirements that need to be met to obtain a clean closure or partial clean closure determination in accordance with applicable sections of CCR Title 27. Because wastes remain at the WDS, only a partial clean closure would likely be considered/granted and such a clean closure can only be granted by State Water Boards and the DTSC and not the LEA or CalRecycle. (It may be possible to request a clean closure of a property based on complete removal of wastes on that land parcel; however, there are inconsistencies in the regulatory community as to whether this would be considered a partial clean closure or a clean closure.) Significant information is absent to grant a partial clean closure determination including the apparent absence of adequate waste delineation in the area of waste removal; apparent absence of field documentation of waste excavation procedures, management of excavated wastes (e.g., were Best Management Practices utilized?) and waste manifests (may be available, but were not provided); apparent absence of confirmation sampling and analytical testing to confirm the adequacy of waste removal; apparent absence of adequate field documentation and information provided regarding waste excavation procedures; and absence of required statements to support clean closure including a statement that the WDS no longer/does not pose a threat to water quality and there is no apparent potential threat to human health and the environment. It is recommended that clean closure requirements as indicated in applicable sections of CCR Title 27 Sections§20950 and §21090 be reviewed and required information, if available be provided, as applicable. • According to the draft plan, earthwork activities will involve the disturbance, redistribution, and grading of soils and wastes throughout the 48-acre parcel. The following was stated in the PCLUP: The project specifications call for the "complete"excavation of loose soils/fill materials ("including remnant buried glass waste') to expose underlying firm, native undisturbed soils. In some areas, the depth of required excavation to remove fills/wastes could be several feet or more. The excavated soils (and mixed-in glass materials) will be moisture conditioned as necessary, and placed and compacted as engineered fill within various project areas (potentially including areas outside of the current landfill footprint). These proposed activities suggest that the removal and reuse of wastes is based on geotechnical requirements for constructing the building and that wastes are planned to be excavated, made suitable for geotechnical requirements, and placed back into the ground, including at locations of the proposed building footprint, other on site locations, and possibly also offsite. This type of "remedial action" could be referred to as partial reconsolidation of wastes. If this is what is planned, then the locations where wastes are planned to be removed and where they are planned to be reconsolidated needs to be clearly indicated on an appropriate figure and described in the text of the plan. A figure indicating what areas are planned to be excavated, capped and/or locations of proposed reconsolidation needs to be provided. As previously indicated, based on available information, it appears that analytical testing in the area of the proposed warehouse building was restricted to soils and not wastes; therefore, it appears the wastes have not been characterized with respect to their potentially hazardous nature. Additionally, some background documents from the 1980's suggest the wastes were classified as hazardous. The proposed scope of work indicated in the plan (reburying wastes) is not consistent with clean closure. It may be that the PCLUP is only referring to the removal of wastes conducted in 2015; however, such waste removal activities may constitute a partial clean closure of the WDS, if adequate documentation and information is provided. Because the wastes are reportedly relatively shallow and may be laterally confined to a relatively narrow zone, has a cost analysis been conducted to evaluate offsite disposal of these wastes Ninyo&Moore 1 500 E.Louise Avenue,Lathrop,San Joaquin County,California 1 104690095 1 August 11,2017 11