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A r , <br /> ST'TE OF CALIFORNIA GEORGE DEUKMEJIAN,Governor <br /> CALIFORNIA REGIONAL WAT QUALITY CONTROL BOARD— <br /> CENTRAL VALLEY REGION <br /> 3443 ROUTIER ROAD r <br /> SACRAMENTO,CA 95827-3098 <br /> a �,^ny <br /> xl + '� ib11 <br /> 28 April 1989 I1IAY 1 1909 <br /> CtJVPEOMITISE VICESL7R <br /> Mr. Kenneth Smith <br /> Delta Truck Sales <br /> P.O. Box 8068 <br /> Stockton, CA 95208 <br /> SOIL ASSESSMENT WORK PLAN FOR SURFACE IMPOUNDMENT AT DELTA TRUCK SALES, SAN <br /> JOAQUIN COUNTY <br /> We received a work plan from Kleinfelder Associates on 26 April 1989 which <br /> outlines a plan to sample and analyze waste from the surface impoundment on <br /> your property. The stated objective of this work plan is " . . .to assess if the <br /> SI has been correctly characterized as containing "hazardous waste", . . . " <br /> The results of the sampling and analysis proposed in the work plan will not be <br /> sufficient to prove that the waste in the surface impoundment is not <br /> hazardous. Extracts from two samples of waste taken from the impoundment on <br /> 15 July 1987 were found to contain lead at concentrations of 27 and 28 mg/L. <br /> Even if each of the five samples taken from the waste in the buried <br /> impoundment in this sampling event were found to contain no soluble lead, the <br /> average lead content of the seven waste samples would be greater than 5 mg/L <br /> (the hazardous level for soluble lead) , and the waste would still be <br /> classified as hazardous. <br /> In my conversation with you on 27 April 1989 you said the samples taken on 15 <br /> July 1987 may have been taken from fill and not waste. We believe the samples <br /> taken from the impoundment on 15 July 1987 represented the waste placed in the <br /> impoundment before it was buried. If the point of the proposed work is to <br /> prove that the 15 July 1987 samples were representative of fill material <br /> placed in the impoundment, and not the original waste, the proposal should <br /> clearly show how this will be accomplished. The investigation will have to <br /> short that either the previous two samples were not oily waste, or that oily <br /> "hazardous waste" was brought to the property to fill in the surface <br /> impoundment. We are not aware of any information which would support these <br /> scenarios. <br /> This proposal will accomplish far less than the amended work plan approved by <br /> Board staff on 19 May 1988, and does not sufficiently address the Notice of <br /> Violation sent to you on 3 January 1989. The Notice of Violation required a <br /> technical report be submitted by 15 March 1989. This report has not been <br /> received. In a letter dated 25 January 1989 you asked for an extension so <br /> that excavation and site investigation measures could start in April , 1989. <br /> No work has been started at this time. <br />