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Angelica Sandoval Marin [EH] <br /> From: Angelica Sandoval Marin [EH] <br /> Sent: Wednesday, September 24, 2014 1:31 PM <br /> To: 'William Little' <br /> Subject: RE: 135 E. Miner Street <br /> William, <br /> Thank you for planning to disposing the waste and it is unnecessary for you to resample the drums. <br /> Thanks <br /> Angelica <br /> Angelica Sandoval Marin, Senior REHS <br /> San Joaquin County, Environmental Health Department <br /> 1868 E. Hazelton, CA 95205 <br /> (209)468-2807 desk <br /> (209)468-0341 fax <br /> Email: amarin@sjcehd.com <br /> From: William Little [mailto:wlittle@advgeoenv.com] <br /> Sent: Wednesday, September 24, 2014 11:20 AM <br /> To: Angelica Sandoval Marin [EH] <br /> Subject: RE: 135 E. Miner Street <br /> Ms. Sandoval Marin: <br /> AGE will dispose of the waste within the next two weeks. Be aware the water from the wells has been <br /> comingled within the two drums and therefore, an average waste concentration is acceptable for the <br /> disposal characterization or would you request a resample of the drums?. <br /> Waste media generated from UST investigation also has some typically used tools to evaluate and <br /> dispose of the waste, FYI is some language for the practice. <br /> Petroleum contaminated media and debris is excluded from the definition of hazardous waste when <br /> the media or debris, such as soil and groundwater, is generated from petroleum UST corrective <br /> action activities and fails the toxicity characteristic for hazardous waste codes D018 through D043 <br /> (§261.4(b)(10)). At the time of promulgation of the final Toxicity Characteristic (TC) rule, EPA made a <br /> determination to temporarily defer applicability of the TC rule to media and debris contaminated with <br /> petroleum from USTs subject to the corrective action requirements of Subtitle I of RCRA. EPA had <br /> little information regarding the full impact of the TC rule on UST cleanups; however a preliminary <br /> assessment indicated that the number of UST cleanup sites and the amount of media and debris at <br /> each site that would exhibit the toxicity characteristic would be extremely high. EPA reasoned that <br /> subjecting all, or even a portion, of these sites to Subtitle C requirements could overwhelm the <br /> hazardous waste permitting program and the capacity of existing hazardous waste treatment, <br /> storage, and disposal facilities. In addition, imposition of the requirements could delay UST cleanups <br /> significantly (58 FR 8504, 8504; February 12, 1993). <br /> Thank you in advance for your help in this matter. Please call me if you have any questions. <br /> I <br />