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California kqe,4 onal Water Quality ontrol Board <br /> Terry Tamminen Central Valley Region 9 <br /> Secretaryfor Arnold Sehwarrenegger <br /> Environmental Robert Schneider,Chair Governor <br /> Protection <br /> 11020 Sun Center Drivc#200 Rancho Cordova,CA 95670-6114 <br /> (916)464-3291 •Fax(916)464-4775 <br /> http://www.swrcb.ca.gov/rwgcbS <br /> 1 December 2004 <br /> Mr. Peter Palomino ,1M ID bic 0 7' " <br /> 6420 7t1' Street — - - <br /> Riverbank, CA 95367 <br /> WORKPLAN FOR SITE MITIGATION, 23023 S. SANTA FE ROAD, RIVERBANK, SAN <br /> JOAQUIN COUNTY <br /> Central Valley Regional Water Quality Control Board staff(staff) has reviewed the Summary of Soil <br /> Boring Investigation and Workplan for Site Mitigation, 23023 S. Santa Fe Road Riverbank(Workplan) <br /> submitted on your behalf by Ground Zero Analysis Inc. Staff has the following comments: <br /> 1. The 23023 Santa Fe Road site is part of the former Snyder Sanitary Dump site and the site is a <br /> Closed, Illegal, and Abandoned landfill. Responding to an investigation by the CIWMB in <br /> September 2003, staff concluded that waste piles at the Snyder site are designated waste due to <br /> lead concentrations and should either be clean closed or closed as landfill (covered). <br /> 2. The workplan reports the results of a soil and groundwater investigation that was limited to <br /> 23023 S. Santa Fe Road, a part of the Snyder site. The investigation found groundwater at 25 <br /> to 40 feet below ground surface; soils are composed of intercalated sand, silt and clay; and <br /> downgradient groundwater does not have detectable concentrations of VOCs or soluble lead. <br /> Soil samples collected at 5 and 10 feet below ground surface did not detect soluble lead. It is <br /> reasonable to conclude from these results that for the area covered by this investigation, the <br /> waste as it is currently situated is not a threat to groundwater. <br /> 3. Staff understands that you plan on mitigating the waste piles and redeveloping the 23023 S. <br /> Santa Fe Road site. The San Joaquin County Environmental Health Department is the lead <br /> agency for this work. The Snyder site waste is still designated waste and if not handled <br /> properly has the potential to degrade surface water or groundwater. Staff is concerned that re- <br /> development should not inadvertently release waste constituents to surface water or <br /> groundwater. Based on CIWMB'S previous site investigation the threat to water quality comes <br /> from bum dump ash and municipal solid waste. Construction debris found on site are unlikely <br /> to be a threat to water quality. Ash and municipal solid waste that is exposed by redevelopment <br /> should be discharged to an appropriate landfill. Also,any ash that remains on site should be <br /> protected with a complete cover that prevents erosion of the ash into surface water drainages <br /> and water from ponding on the ash,which should prevent the percolation of water through the <br /> waste. With as little disturbance as possible, areas where ash will be left should be graded to <br /> drain and covered with asphalt or other impermeable material. <br /> California Environmental Protection Agency Environmental Protection Agency <br />