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SANJ 0 AQUIN <br />= <br />COUNTY— <br />Gr <br />OUNTY <br />� <br />l%rss {?fOs3°s i::'f N. <br />January 22, 2019 <br />R&B Louise LLC <br />Attention: Dana Parry <br />1200 Concord Avenue, Suite 200 <br />Concord, CA 94520 <br />Linda Turkatte, REHS, Director <br />Kasey Foley, REHS, Assistant Director <br />RE: Work Plan Addendum — Excavation and Material management Plan <br />For Parcel A (APN 198-120-08) of SWIS 39 -CR -0022 <br />Former Pilkington North America -Lathrop Facility <br />500 E Louise Avenue, Lathrop <br />PROGRAM COORDINATORS <br />Robert McClellon, REHS <br />Jeff Carruesco, REHS, RDI <br />Michael Kith, REHS <br />Willy Ng, REHS <br />Muniappa Naidu, REHS <br />The San Joaquin County Environmental Health Department (EHD) has reviewed the Work Plan <br />Addendum — Excavation and Material Management Plan for Parcel A (EMMP Workplan Addendum), <br />dated December 21, 2018, and prepared by Advanced GeoEnvironmental, Inc. (AGE). <br />The 'EHD comments relating to this EMMP Workplan Addendum are limited to the jurisdiction of the <br />Solid Waste Local Enforcement Agency (LEA) to enforce the California Code of Regulations, Title 27 <br />(Title 27) solid waste minimum standards and the jurisdiction of the EHD to oversee local voluntary <br />cleanups under California Health and Safety Code, Section 101480. These comments do not address <br />the implementation of the Title 27 regulatory standards promulgated by the State Water Resources <br />Control Board for the protection of water quality at solid waste disposal sites, or any other authority of <br />the Regional Water Quality Control Board under Division 7 of the Water Code. <br />This EMMP Workplan Addendum is being submitted as an addendum to the Excavation and Material <br />Management Plan (EMMP), dated March 9, 2018, prepared by Brusca Associates, Inc., that addressed <br />waste and soil removal activities for the portion of the disposal area identified as Waste Unit 1 (WU1) <br />located on Parcel B only (APN 198-120-09, 17000 Murphy Parkway, Lathrop, a portion of SWIS 39 -CR - <br />0022). The March 9, 2018 EMMP was subsequently amended by an addendum dated March 22, .2018, <br />prepared by Brusca Associates, Inc. The scope of work in the March 9, 2018 workplan and March 22, <br />2018 addendum was implemented in April 2018, at which time it was discovered that a portion of the <br />WU1 disposal area extended northward onto Parcel A (APN 198-120-08, 500 E. Louise Avenue, <br />Lathrop, a portion of SWIS 39 -CR -0022). The removal and reuse activities for Parcel B were completed <br />in June/July 2018 and the verification report for this scope of work was submitted in December 2018. . <br />Based on discussions with you and your representatives on December 17, 2018 and December 28, <br />2018,.the current scope of work in the EMMP Workplan Addendum is intended to provide a clean <br />closure for WU1 on Parcel A by removing the remaining waste glass and associated impacted soils to <br />target screening levels established for commercial/industrial uses. This work is being proposed so this <br />area can be used as a storm water detention basin to serve the industrial development project currently <br />being implemented for Parcel A. Also during our discussions, it was mutually agreed that there are two <br />known disposal areas on Parcel A- the area located in the southwest corner of the parcel and the area <br />located on the southern border of Parcel B where vvU1 has been identified. Although the general nature <br />and extent of the buried wastes in these areas are understood, the defined boundaries for both of these <br />areas have not been fully determined or documented at this time. It is understood that the scope of this <br />current EMMP Workplan Addendum -is to address -the waste -glass and associated ,soils .in the area of <br />1868 E. Hazelton Avenue I Stockton, California 95205 1 T 209 468-34201 F 209 464-0138 1 www.sjcehd.com <br />