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0 <br /> Draft Soils FS Memorandum -7- 14 September 1993 <br /> DDRW, Sharpe <br /> comprehensive with regards to nonfuel USTs and SWMUs. The November 1990 RI only <br /> addressed 31 of 127 identified sites and therefore cannot be considered comprehensive. It <br /> should also be noted that the requirements if Article 5 of Division 3, Chapter 15 of Title 23 of <br /> the California Code of Regulations (CCR) were not adopted until July 1991, subsequent to the <br /> RI. Therefore, the RI was not reviewed with Board consideration of the requirements of <br /> Article 5. <br /> The available information is either inadequate or is not presented to support NFA decisions. <br /> Therefore, it appears premature to proceed with a comprehensive site-wide ROD. A <br /> document addressing the 110 NFA sites must be prepared. The Draft Soils FS addresses the <br /> 17 contaminated sites and an Operable Unit ROD can be prepared so that remediation of these <br /> sites can proceed. Preparation of a NFA document should not interfere with the progress <br /> being made on remediation of these 17 sites. <br /> 3. Landfills and Burn Pits: Landfills and burn pits (S#18, S#28, S#30, S#33, S#36) are all <br /> documented as having received waste on a regular basis in the South Balloon Area and have <br /> been identified as major sources for solvent contamination. The Soils FS report only <br /> addresses these units as possible source areas for solvent contamination, and proposes <br /> remediation for the areas with high solvent concentrations. The Soils FS does not address the <br /> waste that will be left in place and the possible long term threat to ground water quality. <br /> Additional evaluation is needed to determine how the waste left in-place in these landfill units <br /> will comply with Division 3, Chapter 15 of Title 23 of the CCR. The Soils FS does not <br /> evaluate the appropriateness of capping the landfill areas in the South Balloon Area in order to <br /> protect the ground water from future degradation from waste left in place in these landfills. <br /> The Regional Board reconfirms its position that Chapter 15 is an applicable requirement. <br /> Article 5 requires monitoring and corrective action for waste management units, which are <br /> defined as "an area of land, or a portion of a waste management facility, at which waste is <br /> discharged." 23 CCR § 2601. The post-closure monitoring requirements of Article 5 must <br /> also recognized as ARARs in the Draft Soils FS. <br /> Because the landfills at DDRW, Sharpe ceased accepting wastes before 1984, the landfills are <br /> considered to be "closed, abandoned or inactive" landfills and are subject to Section 2510(g) <br /> of Chapter 15. These units are identified as source areas for VOC contamination of ground <br /> water. Therefore, Section 2510(g) requires that DDRW, Sharpe develop and implement a <br /> corrective action program pursuant to Article 5 of Chapter 15, which is clearly an applicable <br /> State requirement. <br /> The Corrective Action Program in Section 2550.10 of Chapter 15 provides the detailed <br /> requirements for development and implementation of a program that includes corrective action <br /> measures which will ensure that there is no further impairment of water quality from <br /> constituents at the landfill and source control to prevent future releases (i.e., a vapor <br /> extraction system for VOCs). Although the closure and post-closure maintenance <br /> requirements of Article 8 of Chapter 15 are not specifically applicable to inactive sites, they <br />