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i s <br /> adequacy of waste removal such as confirmation sampling and analytical testing. LEA <br /> documentation of the waste removal activities was not available for review. <br /> I- <br /> =-T- A11111111.11 . vu A €�t 3z x'15 <br /> The CalRecycle email states that if AGE has determined that contact with native (undisturbed <br /> geology) has been established -then this should be noted in the trench logs as the bottom of waste <br /> and that generally - over-excavating about two feet past the bottom of waste to collect soil samples <br /> for analysis(to determine if any vertical contamination from the disposal fill area exists). <br /> =0rM � `C»1tk(T , C�►�r"�' c"JI� i�"��'„' ' L'��"� i°��� �E the <br /> 1 '�� fit?� �� 1�'i��[T�i� L.E"�,�11�� '�$� <br /> In this email correspondence, it is indicated that attached are the most recent "soil" samples <br /> collected from the western area stockpiles, analyzed for TTLC/STLC metals at the direction of <br /> the LEA. It was stated that "Now that a determination of the waste has been established, a <br /> removal action plan has been proposed, submitted to the LEA and should be implemented <br /> within the next two weeks. <br /> t ,G +�ene" im the '' ' '''' �� e� ward <br /> Oocs , r �� 011, <br /> The email correspondence to AGE states that the LEA are not sure whether AGE has defined <br /> the extent of the waste at the site. The LEA stated the following: <br /> "I was there yesterday and viewfed] the site with my staff. I have some concerns regarding the <br /> method of disposal. The site placed waste in an unorganized method using potholes. There <br /> could be waste potholes that exist near the waste mass you found during you p[re]vious <br /> trenching activity. The area north of the rail spur, where waste was found, should have had <br /> additional trenches to rule out other waste potholes. Did you sample the waste from that area? It <br /> should have elevated metals just looking at the waste found in the trench. Moving to the area <br /> north of the waste mass that you want to scoop and run. That area appears to have been <br /> subject to subsurface disposal. The surface ungulates with obvious surface debris. There [were] <br /> was no trenches in that area. I am concerned that that area may still[be] contain waste. Given <br /> the sporadic method of disposal used by the facility more investigation needs to be conducted. It <br /> appears that when the facility need[ed] soil for some activity they would dig a hole and then <br /> dispose of the waste to backfill the hole. I am not saying the whole site[was]subject[ed]to this, <br /> but the immediate area around where you found existing waste need more trenches. Your <br /> sample method for waste characterization is a little off. Generally, the waste is excavated and <br /> the physically analyzed for contaminates (odor, staining and discoloration). Then those areas <br /> are targeted for sampling. Your approach is kind of a shot in the dark. With that said, I know that <br /> Calrecycle as well as the EHD would like to see a report characterizing and quantifying the <br /> waste onsite. I know more than once the EHD staff have asked for a Post Closure Land Use <br /> Plan and as today there has been no such plan submitted. I understand you want to move <br /> quickly, but not at the shake of doing a thorough investigation of the site and conducting <br /> sampling in known acceptable methods. <br /> Ninyo&Moore 1 500 E.Louise Avenue,Lathrop,San Joaquin County,California 1 104690095 1 August 11,2017 39 <br />