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Dana Parry - 7 - 27 June 2019 <br />pond. The date on Figure 1-2 needs to be corrected. In addition, include another Figure <br />that shows the current site and vicinity features. <br />17. The SMP is not paginated. The SMP would be easier to review and access information if <br />page numbers were included on each page in the document. <br />18. The SMP needs to include protocols for handling and managing soil stockpiles and <br />identify the conditions that require plastic sheeting, or other mitigation to prevent dust <br />from leaving the Site. <br />19. The SMP needs to contain a statement defining Inspection and Entry for Regional Water <br />Board staff to enter the Site. Staff .request that Regional Water Board be allowed entry <br />upon the 500 E Louise Ave property premises at reasonable times to inspect the site, <br />including any offsite staging areas or material storage areas, and engineering controls. <br />Staff also request the Inspection and Entry statement include allowing RWB staff to <br />sample, monitor, or access and copy any records at reasonable times for the purpose of <br />ensuring SMP compliance while allowed entry onto the site premises. <br />20. The visual determination of similarity to known wastes from WU1, NWC, and SWC <br />would be facilitated by inclusion of waste photos in color for SMP users to compare <br />potential waste material to documented waste from the NWC, SWC, and WU1. <br />21. The former smokestack brick material is generally considered inert and appropriate for <br />construction material re -uses. However, burn residue on the brick presents a potential <br />exposure to contaminants above screening levels that may negatively impact human <br />health and the environment. Constituents of concern for the demolition brick material <br />from the former Pilkington North America smokestack that dispersed flue gas from the <br />former glass manufacturing incinerator/furnace for over 50 years of operation include <br />dioxins/furans, polychlorinated biphenyls, total petroleum hydrocarbons, asbestos, and <br />products of incomplete combustion. The smokestack brick material will need to undergo <br />testing and analysis to determine if contaminants are present above screening levels. <br />Regional Water Board Conclusion <br />Staff of the Regional Water Board generally support this SMP proposal; however, the Regional <br />Water Board found several deficiencies and areas that need clarification that are discussed in <br />the above -stated comments. Please address the above -stated comments and resubmit the <br />revised SMP for Regional Water Board review and concurrence. If you have any questions <br />regarding this letter or project, you may contact me at (916)464-4825 or by email at <br />ann.palmer@waterboards.ca.gov . <br />Sincerely, <br />�A J,, Lt- A. <br />Ann M. Palmer <br />Water Resource Control Engineer <br />Site Cleanup Section <br />cc: Earl James, EKi Environment &'vvater (email) <br />Robert McClellon, San Joaquin County Environmental Health Department (email) <br />