CORRESPONDENCE_1990-1993 - Laserfiche WebLink

Home Browse Search

Mr. Ron Valinoti RECEI V 6 Public Health Services JUN 1 TIS June June 18, 1990 IEENVIRONMENTAL HEALTH Page 3 PERMIT/SERVICES a) The standard Waste Characterization Form for the Landfill. This form contains a certification from the generator that all information provided to Forward on behalf of the generator is complete and accurate, and that the soils are not hazardous. b) A Chemical Waste Description Form for Waste Soils. Pertinent historical and analytical data will be summarized on this form. This form must be signed by a California Registered Geologist or Professional Engineer. c) Analytical test data sheets from State-certified laboratories, with proper chain of custody forms included. After the above information is submitted, Forward's Environmental Officer, Ms. Carrie Cummings, will evaluate it for completeness, and will request additional information as needed to verify that the soils meet regulatory requirements applicable to the Landfill. Dr. Marshack of the RWQCB suggested that there be restrictions on the age of data. Dr. Igbene will incorporate criteria regarding the age of data in the Chemical Waste Description Form. Soils will be rejected if they do not meet regulatory requirements and any additional requirements imposed by Forward. If the soils meet such requirements and can be accepted at the Landfill, verification sampling, of the type contemplated by Item 2(B) of PHS' April 28 letter, will not be performed. At the meeting, it was confirmed that existing regulation of the Landfill encompasses both the acute effects and the chronic effects of waste accepted at the Landfill. In light of this, it is our understanding that PHS felt that the proposed soils acceptance program would be acceptable to PHS, provided that copies of the completed information packets be maintained in Forward's records, and Forward's acceptance of contaminated soils complies with applicable Waste Board requirements. For petroleum-contaminated soils that require treatment, Forward will adhere to a custom-designed treatment protocol that is consistent with the WDR and is spelled out in the form of an internal soils treatment guidance document. The guidance document will describe pre-treatment and post-treatment sampling and analysis methods, as well as landfilling criteria for treated soils. Dr. Igbene is in the process of preparing that guidance. Contaminated soils that may properly be stored at the Landfill will be stored in Waste Management Unit G. Soil piles shall be covered except during the treatment process or as otherwise allowed. Identification of all soil jobs shall be posted at the storage area. A copy of any required Air Pollution permit for aeration will be timely provided to PHS and the RWQCB. Forward will provide copies of all bioremediation workplan to PHS and the RWQCB prior to commencement of any bioremediation treatment. f-W=\pravano\1ac\W1tr 061590