Laserfiche WebLink
December 27, 1991 <br />Mr. Robert Evans <br />Water Resources Control Engineer <br />Calif. RWQCB Central Valley Region <br />3443 Routier Road <br />Suite A <br />Sacramento, CA 95827-3098 <br />13 <br />RECEIVED <br />JAN 0 8 1992 Can <br />ENVIRONMENTAL HEALTH <br />PERMIT/SERVECES <br />RESPONSE TO NOVEMBER 5, 1991, REGIONAL WATER QUALITY <br />CONTROL BQARD t"RWQCM LETTER TO C111311' Or S-0CKTO <br />This letter responds to your November 5, 1991, letter regarding the Austin Road Landfill. Your <br />letter presents additional concerns about the corrective action plan (ECON Associates <br />[EMCON], October 199 1) and the city of Stockton's September 30, 1991, letter to the RWQCB. <br />In your letter, you state that electrical conductivity (EC), total dissolved solids (TDS), and pH <br />are 'reasonable constituents of concern (COC) at the landfill. We acknowledge the regulatory <br />definition of COC in Article 10 of Chapter 15, Title 23, of the California Code of Regulations, <br />which states that "'constituents of concern' means any waste constituents, reaction products, and <br />hazardous constituents that are reasonably expected to be in or derived from waste contained in <br />a waste management unit." Our original intended use of the terra COC focused on parameters <br />that presented the most immediate potential health threat, i.e., volatile organic compounds. In <br />light of the broader definition of COC in Chapter 15, however, we agree that EC, TDS, and pH <br />should be added to the list of COC for the site. <br />Your letter also states that "the elevated levels of EC and TDS in well MW -3 and trace levels <br />of VOCs in well MW -5 indicate a release of waste from the waste management unit must be <br />investigated further to verify the release." A revised monitoring program for the landfill is <br />being prepared. Consistent with Article 5 of Chapter 15, the new monitoring program will have <br />a statistical mechanism to identify and verify constituents the landfill may be releasing. <br />Your November 5, 1991, letter presents concerns regarding treatability of the condensate return <br />from Pacific Energy. Please be advised that the condensate return will not be treated using the <br />