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ty 20711 The Site Identification Form (SIP) indicates the LEA conducted a field visit on March 18, 2011. The site was identified as an open dump and background information on the form indicated the WDS closed in 1986. The comments/recommendations section stated that Libbey-Owens Ford Company (site) had changed ownership and that the new owner was Pilkington North America, Inc. and that the SWIS database should be updated to reflect this change. It was also recommended that the inspection frequency at the site be increased to quarterly. t mm � -1, rend The SWIS data entry form documents the change in property ownership to Pilkington North America, Inc. based on the previous June 11, 2011, Site Identification Form (SIP). mil Cave A >w At o x 00 EW t �Ouise Avenue, Lat Antea Group prepared a Soil Cover Work Plan on behalf of Pilkington North America, Inc. (PNA)for submittal to the SJCEHD (LEA) for the "former cullet staging area." Cullet was defined as broken glass and associated material that is generated during the glass manufacturing process that may or may not be recycled as part of the production process. According to the work plan, the LEA requested a soil cover be placed over the former staging area. The work plan stated the following: Representatives from Pilkington NA, LEA and Antea Group met February 8, 2013 to discuss the site and gain understanding of the request for soil coverage of the site. Although the site is within a fenced and secured property, there remains a limited area that has exposed cullet, metal, and plastic. Additionally, and to a lesser extent, concerns were expressed about the potential for surface ponding of water, erosion, and possible increased infiltration of surface water. It was agreed that Pilkington NA would coordinate with Antea Group to prepare a work plan that would address LEA concerns. During the meeting, LEA staff presented a file that contained a letter from 1955 confirming that PNA had entered into an agreement with Brown Sand and Gravel to dispose of cullet within one of the permitted landfill facilities located at Brown Sand and Gravel. Based on the location of the former cullet staging area, it was presumed that the cullet was moved from the plant to the staging area until sufficient quantities had accumulated which were then transported to the permitted landfill for disposal. Comment: This appears to indicate that cullet was initially disposed of offsite (There is a Brown Sand operating in Lathrop; however, it apparently only began operations in 1970). Historical aerial photographs review appeared to indicate that cullet was first placed `on the storage area"sometime between 1963 and 1974. Between 1974 and 1982, soil was excavated from east of and likely south of the staging area. A depression exists to the east of the staging area and evidence of a former ponding area appears south of the staging area. It is likely the excavated areas were used to obtain soil for the construction of an earthen berm/levee on the south side of the railroad tracks between the plant and the staging area. The earthen berm/levee was either constructed with the access road passing through it to the plant or to provide access to the former cullet staging area. Because of the access road passing through the berm, the berm or levee would be ineffective in the event of flooding from the Calaveras River which is located approximately 1.3 miles west-southwest of the site. The cullet was Ninyo&Moore 1 500 E. Louise Avenue,Lathrop,San Joaquin County,California 1 104690095 1 August 11,2017 17