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SAN�,J0A0UIN COUNTY Environmental Health Department W.U1:onParcel A;only. This plan is not intended to address the wastes located in the southwest corner of Parcel A at this time, but may be addressed at a later date under a separate plan. As the intent of the work is to clean close the portion of WU1 on Parcel A to prepare the area for the proposed stormwater detention basin, the documentation and activities need to be consistent with the solid waste requirements for clean closure as provided in Title 27, Section 21810 and CalRecycle's LEA Advisory #16 for Clean Closure. To that end, the following recommendations/revisions are being requested at this time: The EMMP Workplan Addendum title and content should be amended to reflect that the document is proposing a plan for the clean closure of WU1, in addition to the plan for the excavation and materials management activities. Alternatively, a stand-alone Clean Closure Plan may be submitted to supplement the EMMP Workplan Addendum. An amended Clean Closure PlanlEMMP Workplan Addendum should include the applicable minimum components for clean closure pursuant to the two references noted above, including: o Clean Closure Plan Purpose — the current EMMP. Workplan Addendum addresses the method for closure activities (excavation and materials management) but does not provide a discussion that the activities are intended for the clean closure of WU1. A discussion should be provided to document that the removal of wastes and associated contaminated soils will be conducted for a clean closure of the unit to protect public health and safety, to eliminate the need for postclosure maintenance, and to prepare the site for the proposed postclosure land use (stormwater detention basin). The revised Clean Closure PlanlEMMP Workplan Addendum should clarify that the scope of work is limited to the disposal area of WU1 on Parcel A only and is not intended to address the waste located in the southwest corner of Parcel A. o Postclosure Land Use — a description of the postclosure land use for the area of WU1 should be included in the Clean Closure PlanlEMMP Workplan Addendum. o Certification — each submittal shall be certified by a registered civil engineer or.a certified engineering geologist. Page 3 of the current EMMP Workplan Addendum already contains the signature of a certified engineering geologist. Any amended or subsequent submittal should also include this certification. o Site Characterization — the characterization of WU1 is already addressed on page 2 of the current EMMP Workplan Addendum, including a statement that the extent is estimated at this time and the full extent will be determined at the time of removal. Please be advised there is some risk associated with removal activities conducted prior to full characterization that may result in unplanned or unanticipated outcomes. The characterization of the wastes located in the southwestern corner of Parcel A do not have to be addressed here if the scope of the activities was adequately discussed in the purpose section of the revised Clean Closure Plan/EMMP Workplan Addendum document. o Excavation and Materials Management — the current EMMP Workplan Addendum addresses the excavation and materials management activities for WU1 and proposes to remove waste materials and associated contaminated soils to target industrial screening levels. However, depending on the full depth of the proposed stormwater detention basin, additional soil beyond that required to meet industrial screening levels may need to be removed from the WU1 area to construct the stormwater detention basin. Depending on the s:,�l rl...,,+., of +hie nrirlifinnall" excavated soil the use of industrial screening III al disposition/location v� uuv u�wu y vi � levels may not be appropriate. Please provide additional discussion to address the use of industrial screening levels and the potential further removal of impacted soil during the 2of3