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oversight and also has requested the Regional Board approval or provide concurrence to start the <br /> backfill [of] the excavation. <br /> Comments: Analytical data was not included in the documents available for review; however, it is <br /> assumed that it pertains to the planned imported soil to backfill the waste excavation area. Based <br /> on available documents reviewed, it does not appear that there was a waste excavation report <br /> prepared and it appears that there was an absence of confirmation sampling and analytical testing <br /> to confirm the wastes were adequately removed. <br /> P . 1x ha �en �rflhy � <br /> i cdber <br /> This email from the Water Board to AGE appears to be a follow up to a phone conversation earlier <br /> that morning and states that the Water Board does not concur with the planned backfilling without <br /> adequate lead time and review of technical specifications or assurance of LEA review of technical <br /> specifications and oversight during backfilling activities. It was stated that it was the Water Boards <br /> understanding that the LEA is at a conference all week and that the Water Board has concerns <br /> over the excavation management activities observed over the past couple of weeks and has not <br /> received adequate response to concerns over soil management activities, such as soil mixing and <br /> prematurely backfilling of pits, that could negatively impact underlying groundwater. It was stated <br /> that a review of site trenching, excavation and backfill activities has also indicated the necessity <br /> for site coverage under the Construction General Permit Order 2009-0009-DWQ. This Order <br /> requires Best Management Practices for areas of 1-acre or more disturbed property (such as <br /> trenches and pits) for groundwater protection. Information was provided regarding the <br /> Construction General Permit. <br /> IRV Vo <br /> K. Ifftl W-14, <br /> r: <br /> The title of this document suggests it is a work plan; however, it appears to actually be a summary <br /> report of site investigation and waste excavation remedial action. <br /> Comments: This document appears to contain similar summaries of investigation information as <br /> was presented in the previous PSA documents. Metals analytical data is summarized onto tables. <br /> The document title suggests it is a work plan; however, it does not appear to be such a plan, <br /> rather it briefly summarizes previous soil borings and exploratory trench excavation information <br /> and provides only limited information related to waste excavation remedial action. The report is <br /> incomplete. For this summary document, Ninyo & Moore comments (blue font) are provided <br /> following AGE statements (black, italics). <br /> Soil borings (AB8–AB21 and AB26–AB28) were advanced within an area of the property were <br /> [where]former glass debris and dust waste streams were historically managed/treated and stored,- <br /> or <br /> tored,or advanced within an area of the property were [where] former glass debris and dust waste <br /> streams were not managed/stored on the surface. Comments: What is meant by "not <br /> managed/stored on the surface?" Does this mean at locations outlying suspected waste disposal <br /> areas?Why is it limited to "surface?" Please provide information about the term "dust' streams. <br /> Ninyo&Moore 1 500 E.Louise Avenue,Lathrop,San Joaquin County,California 1104690095 1 August 11,2017 45 <br />