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STATE OF CALIFORNIA—HEALTH AND WELFARE AGENCY GEORGE DEUKMEJIAN, Gowrwr <br /> DEPARTMENT OF HEALTH SERVICES ,i <br /> TOXIC SUBSTANCES CONTROL DIVISION Dnq ,a�tv , <br /> NORTHERN CALIFORNIA SECTION 4� ♦. <br /> 4250 POWER INN ROAD ,V <br /> SACRAMENTO,CA 95826 Marley Cooling Tower Company <br /> (916)739-3145 Surface Impoundment AUG 1 ly�b <br /> Closure and Post-ClOsure Plan Defeciencies <br /> ENVIROMENTAL HEALTH <br /> FEKAIT/SERVICES <br /> General Comments <br /> 1 . Correction of the existing ground-water contamination necessitates removal <br /> of existing contaminants from the surface impoundment. <br /> 2. Revise subject plans based on the following parameters: <br /> dment <br /> ree liquids <br /> on as <br /> a. wateret eatmenttthe unit srface installed(,ntestedfand approvedaforothe <br /> and use. <br /> b. Sample the residual sludge, pond bottom and pond walls to the extent <br /> necessary to establish an accurate profile of the contamination under <br /> and around the pond. <br /> c. Determine the total combined quantities of sludge and most highly <br /> contamin,ated soil that it is economic-111y feasible to remove. <br /> d. Remove and dispose of the sludge and highly contaminated soil in a Class <br /> I disposal site. <br /> ? y = y - MIA. <br /> e. Verify the seal of the old dry wells. <br /> f. Close the impoundment site in accordance i h th approv� osure plan. <br /> 3. Meet the requirements for landfill (see attached) : <br /> a. Notice to local land authority (40 CFR, 2065-119)- <br /> b. Notice in deed to property (40 CFR 265 .120)- <br /> 4. Revise cost estimates to reflect changes made. (Financial assurance and <br /> ability to meet liability requirements will be re-evaluated based on <br /> revised closure and post-closure costs.) <br /> 5. Upon review of the details of the procedures and proposed water treatment <br /> system, and verification of adequacy, the Department will: <br /> a. Consider approval of the water treatment system on a <br /> variancea basis, <br /> since the water treatment is adequately regulated <br /> cy <br /> (CVRIq CB) . <br /> b. Approve the drainage and treatment of the surface impoundment free <br /> liquids to allow this work to commence even prior to the final approval <br /> of the closure plan, if necessary. <br />