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500 E Louise Ave <br />Lathrop, San Joaquin County - 4 - 12 April 2019 <br />nature of the subsurface conditions. While staff have reviewed and approved <br />numerous work plans and reports for the site, the Berlogar Stevens & Associates <br />geotechnical report does not appear to have been included in documents <br />submitted to the Site Cleanup Section overseeing the remediation and <br />redevelopment of the site since early 2015. Several other geotechnical <br />investigations have been conducted at the site since 2015 that provide the Site <br />history of waste management practices that have the potential to negatively <br />impact human health and the environment as well as regulatory expectations <br />regarding handling, characterization, and disposal of unpermitted waste material <br />illegally landfilled at the site. Staffs of the Central Valley Water Board and <br />SJCEHD have approved an extensive Site Assessment Report and Clean <br />Closure Plan for other sections of the site that is not referenced in the SWPPP. in <br />addition, the Excavation and Materials Management Plan (9 March 2018, Brusca <br />Associates) was developed and implemented at the Site for WU1 that extended <br />across part of Parcel B and the Site. <br />h. Open trenching along the length of the large building located on the northeastern <br />part of the Site contained 10 -inch diameter blue vinyl piping (Figure 17 of <br />Attachment 3). The northeastern most side of the open trench had a strong odor <br />emanating from it and staining was also observed in the soil profile as shown in <br />Figures 15 and 16 of Attachment 3. The trenching placement is in the vicinity of <br />the diesel spill site and may have disturbed material from that historical spill and <br />ongoing cleanup. <br />i. There was significant onsite storage of materials located in the area of earthwork <br />as shown in Figures 19 and 20 of Attachment 3. Dates written in black marker on <br />the plastic wrap varied from February 2019 through March 2019. <br />j. Glass manufacturing waste material is present on the surface across the eastern <br />portion of the site combined with the observed new waste pile indicate that the <br />remainder of the Site must be investigated for the presence of waste pits and the <br />potentially negative impacts to water quality (Figures 21 and 22). <br />k. A Ione pouch style container without labeling was present along a fence situated <br />on the Parcel B side of Parcel A as shown in Figure 23 of Attachment 3. The <br />container appeared to be empty with no staining visible on the ground through <br />the surrounding foliage. <br />6. The Discharger's failure to submit a work plan for approval with or notify Central Valley <br />Water_ Board staff that glass manufacturing waste were found during construction <br />earthmoving activities has resulted in the issuance of this Request for Information <br />pursuant to Water Code section 13267, which authorizes the Executive Officer of the <br />Central Valley Water Board to issue orders requiring submittal of technical reports for the <br />suspected release of pollution. <br />7. In order to ensure protection of human health and the environment at the subject property, <br />Central Valley Water Board staff have concluded that information is necessary regarding <br />operations conducted on the property, including locations and extents of waste pits in <br />which the observed waste material in Attachment 3 was obtained from, characterization of <br />the excavated waste, soil sampling from beneath the waste pits, handling procedures, <br />