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Caiifornsa integrated Waste Management Board -- ".� . . Dan Eaton, Chairman ; ■;;;® t $8001,Cif tenter Drive • Sacramento California 95826 •(916)255-2200 www.ciwm .ca.gov Winston H. Hickox Gray Davis Secretaryfor Governor Environmental Protection July 19, 1999 Mr:Ron Wilmouth Brooks Products 1850 Parco Avenue Ontario, CA 91761 SUBJECT: Brooks Concrete Products,Facility No. 39-CR-0019 Dear Mr. Wilmouth: California Integrated Waste Management Board(Board)staff are writing this letter to clarify the Board's requirements with regard to the subject site. On July 1, 1999, Board staff transmitted correspondence to you indicating that the construction of any new on-site structures within 1,000 feet of the disposal area would be required to meet Title 27,California Code of Regulations(CCR), section 21190(g), unless an exemption from the requirement is obtained. On July 14, 1999, Board staff(Jeff Hackett and Tim Crist)met with Ray Jones of Brooks Products and a backhoe operator from Mountain Cascaid, Inc.,to further assess the nature of waste and potential landfill gas migration from the disposal site. Two trenches were excavated in the fill. Excavation of the trenches revealed that the site is covered with two to four feet of cover material and the composition of the waste is burn dump material (i.e., burn ash, metal,and glass). Since the site was previously used as a burn dump, there is no significant potential for the generation and subsequent migration of landfill gas. Therefore, the design and construction of Brooks Products' new office building, as depicted on San Joaquin Design Group's Site Plan(just west of the existing office building), is not required to meet 27 CCR 21190(g). Board staff are aware that Brooks Products is required by the local fire district to maintain the vegetation on the fill area to minimize potential fire hazards. Brooks Products has implemented the process of tilling the soil twice a year to meet the fire districts requirements. However,Board staff requests that you work with the fire district to minimize the tilling of the cover on the disposal site(e.g., would mowing the vegetation rather than tilling be acceptable to the fire district?). Tilling the cover material jeopardizes the integrity of the cover material and may lead to future grading and drainage problems and possible exposure of burn ash. The Board is currently serving as the solid waste enforcement agency(EA) for the City of Stockton and is required to inspect the subject disposal site. As a result of the July 14, 1999 site assessment, Board staff will inspect the subject site annually. In those jurisdictions where the Board is serving as the EA, the Board has implemented a cost recovery mechanism based on an hourly-billing rate. The billing rate is currentk 585.37 per hoar. The Board recovers costs for time spent on duties such as inspections. pena�its. closure plan technical rev iew. etc. A billing statement «ill be prepared for each.hiscai ear quarter and forwarded to Brooks Products. California En%iro!-m—_ntal Protection :N enev