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development, the vast majority of the property will be "capped" with a large warehouse building and pavements." Comments: This information indicates that the plan includes compacting some of the wastes at some locations. The potential problem is that the wastes have not been adequately characterized (and delineated) and therefore their potentially hazardous nature is not known. Wastes that were excavated and disposed of offsite went to a Class II landfill, suggesting they were not acceptable at a Class III landfill. In addition any development of the property will need to be conducted in accordance with a Waste Management Plan. The email from the LEA indicated that AGE needs to include a landfill boundary map that will be used by the developer to present development plans (to show w[h]ere buildings and improvements will be located with respect to [waste] disposal areas). It was stated that the landfill boundary map should include the location of investigation trenches and borings and appropriate labeling. The report should also include trench and boring field logs that support the sample location and waste extents map. It was further stated that analytical data should be referenced by trench and boring logs and should be summarized in tables and compared to regulatory thresholds. The email stated that a landfill gas monitoring program should be submitted and needs LEA approval. 0--O�F�il a.�01m, This email from the LEA to CalRecycle indicated that the proposed plan is to construct a "very large warehouse"for the area that contains the "old" [waste] disposal area It was stated that"they" (AGE/client [?]) are willing to take another [LFG] sample for CH4 [methane] and do some additional trenches in the easement. The LEA stated that the warehouse was proposed and that they have not seen any plans, but wanted to let CalRecycle know that the LEA met with them and what was discussed. The LEA stated that they directed AGE/client (?) to contact the RWQCB, APCD and local planning and that they wanted a closure letter. The LEA stated that they could not provide that due to the fact that the neighboring property still contained waste. Comments: Request for a closure letter as indicated in this email and draft documents prepared subsequent to this email related to the proposed post closure land use include in their title "Request for Clean Closure." The LEA can not provide a clean closure letter for a waste disposal site. The only regulatory agencies that can provide a clean closure determination are the DTSC and State Water Boards (e.g., the CVRWQCB) can provide such a letter). Based on available information for review, such a determination would likely only be a partial clean closure based on the removal of only some wastes since wastes still exist on and offsite. In addition, based on available information, reports/documents reviewed, adequate documentation to support a clean closure determination does not appear to have been provided (e.g., absence of a waste excavation report, absence of confirmation sampling and analytical testing, and absence of requirements as indicated in applicable sections of CCR Title 27 which generally states that the goal of clean closure is to physically remove all waste and contaminated materials from the waste disposal site and from its underlying and surrounding environs, such that the wastes do not pose a threat to water quality. Ninyo&Moore 1 500 E.Louise Avenue,Lathrop,San Joaquin County,California 1 104690095 1 August 11,2017 57