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the potential foground water degradationl0as minimal , discharge <br /> requirements were waived by CRWQCB. <br /> In May , 1977 , complaints were received from the Stockton Fire <br /> Department of 6 separate fires occurring at the site . Learner <br /> Company reponded to the Health District that the apparent reason <br /> for the fires was the restricted water flow into the waste storage <br /> containers during a time of water shortage. The water flow was <br /> increased. <br /> Extensive and recurrent open burning violations have been <br /> documented in September and October , 1978 . With the proper <br /> operation and maintenance of the site according to the provisions <br /> and specifications of solid waste facility permit 39-AA-010 , the <br /> problems of fires at the site would be greatly minimized. This <br /> fact is implied by the attorney for California Clay Products in <br /> the Revised Operating Plan submitted to CRWQCB on June 29 , 1973 . <br /> The current operation of this site does not comply with the State <br /> Minimum Standards of Solid Waste Handling and Disposal. The <br /> operator has not submitted a winterization plan as of this date <br /> (deadline : August 10 , 1978) . Scavenging is occurring at this <br /> site which is prohibited. Residential refuse and tires are being <br /> deposited at the site which �is prohibited. incoming records of <br /> weights and volumes have not been--instituted by August 1 , 1978 as <br /> required. All litter and loose materials are not being routinely <br /> collected and properly disposed. Names , addresses , telephone <br /> numbers , and other emergency information have not been provided. <br /> Identification signs with this information have not been provided <br /> at each point of access . Adequate barriers have not been provided <br /> around the pit area. All existing loose refuse brought to the <br /> final lift has not been covered with two feet of clean , compacted <br /> cover material . No measures have been taken to minimize the <br /> generation of fugitive dust . A safe area has not been set aside <br /> for receiving burning wastes . A means for extinguishing these <br /> wastes has not been provided. The operator has not submitted the <br /> required site design identifying efforts to be taken to prevent <br /> the creation of hazards or nuisances relative to the operation of <br /> the site. <br /> In the judgment of this writer, the continued operation of <br /> disposal site 39-AA-010 in multiple violation of the provisions <br /> of the current solid waste facility permit can only lead to the <br /> recommendation that the District , as designated local enforcement <br /> agency for solid waste management , consider revocation of said <br /> permit. <br /> November 29 , 1978 <br /> -2- <br />