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at locations underlying the building footprint and/or moving the building footprint since wastes reportedly are only present at the northwestern most area, or has on site reconsolidation been considered (removing wastes in the area of the building footprint and placing the wastes onsite at a specific location to be pre-approved by the LEA and the Water Board (based on the relatively shallow depth to groundwater at the site). Waste Management Plan • Because wastes will be encountered during the planned construction of the warehouse and other related activities (e.g., subsurface utilities, landscaping), any activities that could result in the potential to encounter wastes, (or if there is a potential for LFG), would require such work be conducted in accordance with a regulatory agency approved Waste Management Plan. Such a plan would describe the activities to be conducted and methods to be used when wastes are encountered and identify the responsible parties and required oversight and management of the wastes when encountered. 4 SUMMARY OF AVAILABLE BACKGROUND DOCUMENTS The following is a generally chronological summary of available documents reviewed for the Pilkington NA WDS. Some documents are out of order because the document was undated or only included the month and year, or because various versions of the dated document (e.g., figure and/or tables) were initially dated and then used multiple times and subsequent to the date on the figure). S004 Wase Disp6ail In the LOF Glass letter to the State Department of Health Services, it was stated that LOF operates a flat glass manufacturing plant in Lathrop and that they dispose of certain waste raw materials and stated that "Under applicable EPA RCRA guidelines, analytical and threshold, these materials are not hazardous and the Lathrop facility has not be required to obtain federal waste permits." The letter stated that under California definition for hazardous waste, the raw materials that they had been disposing of at the Lathrop plant site could be categorized as hazardous due to trace amounts of selenium and cobalt as well as soda ash contained in the materials. They stated that based on the concentrations of selenium and cobalt that the waste materials were not hazardous and proposed to conduct analytical testing. The analytical report indicated the customer as LOF Company and that the samples were received two months earlier in March 1982. The sample was identified as "Batch Dust Collection." Selenium was detected at a concentration of 1,500 mg/kg, cobalt at a concentration of 230 mg/kg and the pH of the sample was 11.5. Cobalt was also analyzed by the WET procedure. Ninyo&Moore 1 500 E.Louise Avenue,Lathrop,San Joaquin County,California 1 104690095 1 August 11,2017 12