COMPLIANCE INFO_1992 - Laserfiche WebLink

Home Browse Search

k" KLEINFELDER 6 CLOSURE PLAN Closure of landfills and surface impoundments at J-M Mfg, involves remediation of asbestos contamination in surface soil, capping WMUs and control of asbestos in surface water. This chapter presents a closure plan that encompasses these three tasks. 6.1 REMEDIATION OF SURFACE SOIL CONTAMINATION As discussed in Chapter 4, surface soil contamination was encountered in the form of asbestos fibers. The remediation proposed in this section is for the purpose of isolating areas with elevated levels of asbestos (>1%) from rainfall in order to decrease the amount of asbestos in runoff that may be discharged to surface water. 6.1.1 Areas Requiring Remediation Am In the 1991 soil investigation, a wide variation in asbestos fiber concentrations were found. A majority of the samples were either ND or <1% asbestos fibers. In some samples, asbestos concentrations in excess of 1% were encountered. - In order to establish the areas requiring remediation, a criteria had to be developed for selecting the areas to be remediated. In the United States Code of Federal Regulations (Title 40, Part 61, Subpart M, National Emission Standard for Asbestos) the primary standard mentioned is for air emissions of asbestos (no visible emissions are allowed). The Department of Toxic Substances Control (DTSQ has no cleanup standards for asbestos in soil (personal communication with Mr. Neil Navarro, of DTSC, on.December 17, 199 1) although soil with friable asbestos in excess of 1% would be classified as a hazardous waste. Without an established cleanup level, a rationale must be developed. Such a rationale should meet the remedial objective (which is to attenuate the migration of asbestos fibers to surface water via runoff) while at the same time not pose an undue economic burden to the discharger. At this point in time, the source of asbestos in the surface water is unknown. It could be due to runoff from the site containing asbestos, or it could be due to asbestos in the channel sediments that are stirred up from the bottom during storm events that cause the channel to flow. In light of this uncertainty, Kleinfelder proposes that the soil cleanup level be set at 1% CR14-92-12 Page 23 of 39 24-220109-1309 Copyright 1992 KLeinfeLder, Inc.