CORRESPONDENCE_2025 - Laserfiche WebLink

Home Browse Search

Geo -Logic A S S O C I A T E S STOCKPILE SEGREGATION AND WASTE CHARACTERIZATION Because Clean Harbors accepted responsibility for the material as the generator, Clean Harbors developed and implemented a plan to identify the non -conforming material. This plan involved sampling and material segregation designed to identify locations in the stockpile where the non -conforming waste was placed. Clean Harbors segregated and screened the material to remove concrete and subdivided the stockpile into 19 separate stockpiles of approximately200 cubic yards each at the locations shown in Attachment 1. During this work, Clean Harbors visually identified non -conforming material (concrete) and loaded it into a roll off box during the screening process. Photographs of the concrete and the roll off container with the segregated concrete are in Attachment 1. Clean Harbors' representatives (Tetra Tech) collected five separate soil samples from each pile and composited them into a single sample that was submitted to California Laboratory Services for analysis. The California Laboratory Services reports and a summary of the results are included in Attachment 2. On behalf of Forward Landfill, GLA observed the sampling work and took splits of the composited samples and submitted them to Enthalpy Analytical Laboratoryfor confirmation analyses. The Enthal py Analytical Laboratory reports and a summary of the results are included in Attachment 3. As indicated by the characterization information in these attachments, Aroclor 1242 was not detected in any sample that was analyzed by either laboratory. Based on these observations and results, it was agreed during a February 26, 2025 meeting with Forward representatives and the CVRWQCBthat: 1. The roll off box containing the non -conforming material (concrete) has been sent off site to an appropriate disposal facility. This satisfies the requirement in the NOVthat ..."all hazardous waste (solid and liquid) must be removed forthwith and disposed of at an appropriatelypermitted facilityCi.e. Class/ Landfill) to comply with the WDRs': 2. The stockpiled soil with no detections of Aroclor 1242 will be disposed to the working face at Forward Landfill. 3. Confirmation samples beneath each stockpile will be collected and analyzed for Aroclor 1242 as final verification that all non -conforming material has been removed. NON -CONFORMING WASTE REMOVAL AND DISPOSAL The roll off bin containing the non -conforming waste was removed from the landfill on February27, 2025 for transportation to Clean Harbors Grassy Mountain facilityin Utah under Uniform Hazardous Waste Manifest 017165997. The material was received at the Grassy Mountain facility on February28, 2025 as shown in the signed manifest in Attachment 4.