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Relocation of soil cover within the former waste handling area will include removal of some soil cover, disruption of debris and replacement of debris, with native or imported soil cover and backfilling for compaction. Comment: This statement is unclear. It appears to be stating that wastes (the term debris does not encompass all wastes since some wastes could be "dust and/or soils and not just debris) will be excavated and replaced, which is not clean closure. What is the point of doing this? If it is for geotechnical requirements then please clarify and provide information on exactly what is proposed to be done. The site investigations, including sampling and analytical testing do not appear to have adequately characterized and delineated wastes, therefore, it is not known if these materials to be reused or hazardous. The objectives of this plan are as follows: Identify all regulatory requirements and appropriate measures necessary to obtain a clean closure of the remaining site; to develop a post closure land use plan that will allow for the former glass handling area to be developed for commercial/ industrial purposes; to prepare for the former glass handling/management area to be disrupted for construction processes;provide a detailed plan for post-closure monitoring, inspections, and maintenance at the site to be implemented during the extent of any post-closure maintenance period; evaluate long-term effectiveness of site remediation efforts, including maintenance of cover; and enable regulatory agencies to readily assess whether or not specified post-closure monitoring and maintenance activities are being conducted in accordance with the approved plan. Comments: This plan did not provide information on regulatory requirements related to clean closure. What is meant by the term "remaining site." If clean closure is accomplished, post closure maintenance is not required since the wastes are no longer present. Regulatory Requirements Based on Title 27 requirements, on-going monitoring is only required for the site for possible stormwater discharge. Previous sampling for landfill gases, produced detections which were lower than the standard values (less than 1-5% methane), which would trigger monitoring requirements. The former glass management area (landfill) did not contain decomposable materials nor produce methane. Comments: This section is too incomplete to provide comments. Documentation was not available regarding LFG monitoring; therefore, comments can not be provided. In addition, it is not clear what remedial action(s) will be conducted with respect to the wastes. If wastes or some wastes are proposed to remain in place, then a post closure maintenance program needs to be described in accordance with applicable regulatory requirements. Why is only stormwater discharge discussed? The LEA indicated LFG monitoring should be conducted at the western property boundary and it is not known whether a groundwater monitoring program is required. Groundwater Monitoring and Sampling Program The groundwater monitoring and remediation wells at the site have also been installed for the investigation on the parcel to the east at Occidental Chemical Corporation and J.R. Simplot. The current well locations are shown in Figure 2. Comments: Available background information indicates that there does not appear to be any groundwater monitoring and reporting program conducted or required at this time specific to the WDS. The discussion included in this section appears to be related to an offsite property to the adjacent east and not the WDS. This section should be revised to include information related to groundwater monitoring and reporting (if any) specific to the WDS. If there is no groundwater monitoring and reporting program specific to the WDS, that needs to be stated and then groundwater wells related to offsite contamination can be discussed. Ninyo&Moore 1 500 E.Louise Avenue,Lathrop,San Joaquin County,California 1 104690095 1 August 11,2017 66