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Analytical tables indicate that samples designated as ABSP1 A, B, C and ABSP2A, B, C are identified as "Shallow Pond Sampling, 07/22/15, (depth of 18 inches)." The report does not mention pond(s) and there is no information on the rationale for the 18 inch bgs sampling depth at all locations? Sampling depths should be based on field conditions observed at the time. In fact the report text does not even mention the samples. The analytical tables indicate the samples are soil samples? Does this mean that waste samples or soil and waste samples were tested?There is no information about the types of samples collected, rationale for what was sampled and analyzed and it is unclear why samples were collected at specific depths indicated. Additional General Comments: Boring and trench logs were not included with the document. Field documentation and photographs were not included. A summary of background information including historical aerial photographs indicating the suspected waste extent with respect to how the investigation was conducted was not provided. Analytical data needs to be more completely summarized in the report text. It is not clear what types of samples (soil, wastes mixed with soils or wastes only)were analyzed, how many of each type of sample were analyzed for what COPCs. Rationale for sampling depths was not provided and at some locations, does not appear to have taken into consideration field observations/conditions(e.g., samples were only collected/analyzed at 5 feet bgs in trenches T1-T23). The lateral and vertical extent of the waste disposal areas needs to be presented/provided. There should be a figure indicating boring/trench locations, whether wastes were encountered/waste thickness and then the lateral extent of wastes drawn on the site map based on this information (as well as historical data such as aerial photographs and a geophysical survey). An estimated in place waste volume should be provided. It is not clear where the wastes are located based on the investigations and whether the wastes were adequately characterized (see above comment) and delineated based on the information provided in the report. Figure 2 shows two blue outlined areas designated as "Estimated Pond Area (Historical)." This needs to be discussed in the report text. Are these areas of suspected waste disposal or areas of earlier excavation related to something else? Information presented on a figure needs to be discussed in the report text. Prior to conducting remedial action activities such as the removal of wastes such as was done for this project, a RAP needs to be prepared and approved by appropriate regulatory agencies, at a minimum the LEA. For this project, as early as 1986, it was indicated that removal of wastes would require preparation of a RAP. Remedial action activities are not supposed to be conducted without a RAP or equivalent, regulatory-approved plan. Similar to the previous comment to the earlier AGE PSA report, it appears that remediation/waste excavation was conducted without a RAP. Prior to conducting remedial action, the locations of planned waste excavation need to be delineated laterally and vertically (on the property/site) and documentation indicating this delineation was accomplished at the site does not appear to have been provided to the LEA. The summary document is incomplete and also contains typographical errors and inconsistent wording making some statements difficult to understand. Ninyo&Moore 1 500 E.Louise Avenue,Lathrop,San Joaquin County,California 1 104690095 1 August 11,2017 48