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There are significant requirements that need to be met to obtain a clean closure or partial clean closure determination in accordance with applicable sections of CCR Title 27. Because wastes remain at the site, it is likely that only a partial clean closure would be granted and such a clean closure can only be granted by State Water Boards and the DISC and not the LEA or CalRecycle. Significant information is absent to grant a partial clean closure determination including the apparent absence of adequate waste delineation in the area of waste removal; apparent absence of field documentation of waste excavation procedures, management of excavated wastes (e.g., were Best Management Practices utilized?) and waste manifests (may be available, but were not provided); apparent absence of confirmation sampling and analytical testing to confirm the adequacy of waste removal; apparent absence of adequate field documentation and information provided regarding waste excavation; and absence of required statements to support clean closure including a statement that the WDS does not pose a threat to water quality and there is no apparent potential threat to human health and the environment. It is recommended that clean closure requirements as indicated in applicable sections of CCR Title 27 Sections§20950 and §21090 be reviewed and required information, if available be provided. The soil and waste management relocation strategy will[be]evaluated during the migration[?]of the section to final burial re-location areas, thus allowing for sufficient cover over the waste. Comments this statement needs to be clarified. What is meant by "during the migration of the section to final burial re-location areas?" The title of this document includes "Request for Clean Closure." Is onsite reconsolidation of some wastes part of the PCLUP? If so, then it needs to be stated and the area of planned waste removal(s), location(s) of planned onsite reconsolidation identified and accompanied by how this will be accomplished, including collection of confirmation samples and adequate documentation to confirm wastes were adequately removed and reconsolidated at the specific area(s). Reconsolidation on site will need to take into account the relatively shallow depth to groundwater and likely the depth of waste reconsolidation will be restricted. Waste placed under soil cover is present on the parcel west of the site and the waste material is estimated to be over ten (10) feet in thickness. Comment: Why is offsite wastes discussed in the section of Waste Remediation?And what is such a statement based on? Such information does not appear to belong in this section of the plan. Two waste cells of approximately 2,000 square feet of area each (30 to 35 feet north-south and 65-70 feet east-west) had demonstrated some waste glass and debris, with a variable thickness. The southern cell was approximately eight feet deep and the northern cell was approximately thirteen feet deep with variable soil cover. Comments: Clarification needs to be provided regarding the term "waste cell', north waste cell, south waste cell. Does this mean that based on observed subsurface conditions during excavation that there was clearly an area of waste disposal confined to a "cell' (e.g., wastes were disposed of by the trench and fill method)? Figure 3 - We suggest using consistent terminology "Deep Soil Excavation" should use the same terminology as in the plan. Similarly, the report text refers to the area of waste excavation as "waste handling area,"why are these called handling as opposed to waste disposal areas? It is recommended that a consistent terminology be established in the beginning of the PCLUP and that it be used throughout the plan and on figures. The PCLUP should probably not refer to the waste disposal area as a "glass management area" since there was no information or evidence that glass waste was "managed" in this or any other waste disposal area(s) associated with the WDS. Ninyo&Moore 1 500 E.Louise Avenue,Lathrop,San Joaquin County,California 1 104690095 1 August 11,2017 65