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• s <br /> • Analytical data should be referenced by trench and boring logs and should be summarized in <br /> tables and compared to regulatory thresholds. A landfill gas monitoring program should be <br /> submitted and needs our approval. <br /> Comments: please refer to Ninyo& Moore comments related to the PCLUP. <br /> 4,006—w ,r ft <br /> This document consists of photographs documenting exploratory trenches at the southwest/west <br /> property area; at the location of subsequent waste excavation (clarification of the trench IDs and <br /> general location was subsequently requested and provided by AGE in email correspondence). <br /> Comments: Photographs that indicate subsurface conditions are very useful and adds significant <br /> information to the Project. The photographs are indicated as being from the "Waste Pit" however, <br /> this terminology has not been used in documents submitted and it was not entirely clear whether <br /> this term referred to the area where wastes were subsequently excavated. The photographs are <br /> described as being taken at the west and southwest property areas, assumed to be the location of <br /> subsequent waste excavation. It was later clarified by AGE that the photographs were at the <br /> property boundary with 17100 Murphy Parkway and of trenches T50 and T59 "inside the fencing" <br /> (photos 1-6) and T58, offsite with "deep waste" (photos 10-18), "marking the discovery of the <br /> southern waste cell." <br /> Photo 15 indicates several areas of what appear to be stockpiled wastes likely associated with <br /> exploratory trenching conducted at the site. Are these stockpiled wastes underlain by Visqueen <br /> plastic sheeting and were any BMPs implemented? It appears the stockpiles remained at the site for <br /> some time, so what methods were used to ensure that the excavated materials did not spread out or <br /> migrate or later were adequately removed and did not contaminate the locations that they were <br /> stockpiled? As previously indicated, the typical waste disposal site investigations consists of <br /> only temporarily stockpiling excavated materials and then immediately placing them back <br /> into the trench from which they were excavated. This method saves considerable money <br /> since wastes do not need to be, nor are required to be disposed of offsite. <br /> P -st Closure man s <br /> t _ _ Nun <br /> , _ _ y r <br /> There were several PCLUP reports available for review, all of which appear to be draft form and <br /> incomplete. Therefore, Ninyo & Moore requested from AGE, their latest version of the PCLUP. <br /> The latest plan was sent via email and consists of a DRAFT stamped document. AGE's email <br /> accompanying their latest PCLUP stated that the document is still a draft form and comments <br /> are acceptable, even though the report was signed and stamped. (Draft reports typically are not <br /> signed and stamped.) <br /> AGE provided some revisions to the figures. As requested, they provided information about the <br /> presence or absence of wastes and if present, waste thicknesses for exploratory trenches other <br /> than only trenches T1 to T23; and stated that waste excavation activities were overseen by one <br /> to two LEA staff. <br /> Ninyo&Moore 1 500 E.Louise Avenue,Lathrop,San Joaquin County,California 1 104690095 1 August 11,2017 62 <br />