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The Central Valley Regional Water Quality Control Board (CVRWQCB) has been consulted under the Health and Safety Code, in the development of the investigations of the site and provide[d]the approval of the previous investigation workplan to ensure water quality standards have been examined or determine their relevance. Comments: Please cite the Health and Safety Code and relevancy? Did the CVRWQCB approve a work plan related to evaluating groundwater? "SUMMARY OF PREVIOUS INVESTIGATION" This section is generally similar to what was previously presented in chronologically earlier reports and other documents and therefore these previous comments also apply to what is presented in the PCLUP. Comments: Please refer to earlier comments based on review of chronologically earlier reports/documents for more specific information and the General Comments section at the beginning of this document. Comment: Based on available information, it does not appear that the extent of wastes has been adequately characterized and delineated. "WASTE REMEDIATION"This section is generally similar to what was previously presented in earlier reports and other documents; therefore, previously presented comments apply also to what is presented in this section of the plan. Comments: In general, based on available information, there is an absence of adequate documentation and/or information to confirm that wastes were adequately removed. Please refer to earlier comments based on review of chronologically earlier reports/documents for more specific information and the General Comments section at the beginning of this document. During the investigation of the former glass handling areas currently covered soil, the majority of the trenches (T1 to T23) demonstrated minor amounts of residual glass present with a maximum thickness of 18 inches, surrounded by and within native soils. How can glass or waste be "within native soils" this is physically not possible. Glass debris can be mixed with fill and mixed with native soils; however, when native soils are mixed with wastes they are no longer native soils, they are wastes and soils. The waste strata over native soil ranged from 18 inches at trench T46 to 10 feet deep at trench T58 (south waste cell) and to 13 feet deep at trench T65 (north waste cell) areas. Comment: What evidence is there that native soils were encountered underlying and adjacent to wastes since trench logs in this area (e.g., no trench logs for T24 to T110)do not appear to be available and confirmation samples to confirm the adequacy of waste removal similarly do not appear to be available. It is not clear whether the term"cell' refers to a waste disposal method (e.g.,trench and fill method). During September 2015, excavations removed the waste from the waste cells and adequately defined the horizontal and vertical extent of the buried waste on the property to the western boundary. The excavation work was finalized with the lateral and vertical delineation of waste on-site; it produced a volume of over 2,200 cubic yards of waste. The total 3,567 tons of waste glass, minor garbage and cover soils were disposed at a regional landfill. Comments: Did all the excavated material go to the Forward, Class II landfill? An earlier document suggested excavated materials may have been segregated. A May 6, 1983 letter from Libbey-Owens-Ford Company (LOF Glass) to the CVRWQCB (prior to cessation of waste disposal at the site), indicated that at that time, the waste disposal area consisted of approximately 18 acres and that the volume of wastes disposed was estimated as 10,000 to 20,000 tons of material at that time and that the anticipated waste disposal volume was 5 to 20 tons per week. This volume of wastes is significantly higher than the estimated volume of wastes excavated. An estimated volume of wastes to the north in the "glass/dust waste disposal area" was not provided and it appears not all potential areas of waste disposal were evaluated; therefore, the total estimated volume of wastes at the WDS is not known. Most importantly, it is not known why wastes were excavated from these two areas since such excavation was not required to meet state minimum standards. It likely would have been best to have excavated wastes in the area of the proposed building footprint. Ninyo&Moore 1 500 E.Louise Avenue,Lathrop,San Joaquin County,California 1 104690095 1 August 11,2017 64