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R.S. Moreau <br /> Page 2 <br /> April 3, 1991 <br /> Following are our comments regarding the EE/CA. Primarily they <br /> identify items of California law that need to be addressed prior to <br /> finalizing the EE/CA. <br /> 1. Page 11 - The list of applicable or relevant and appropriate <br /> requirements does not include the California Environmental <br /> Quality Act (CEQA) . The Department is mandated to implement <br /> the requirements of CEQA. The implementation of CEQA must be <br /> incorporated into this project. v <br /> 2 . Page 10 - The following ziCatemant i3 con-fusing: <br /> "A site-specific health and safety plan (HSP) <br /> to the recommended removal action alternative <br /> at each site will be required. However, the <br /> preparation of the HSP is not under the <br /> current scope of work. " <br /> The site specific HSP needs to be developed. The scope of <br /> work and time frame for its development is to be submitted to <br /> the Department. <br /> 3 . Pages 13 and 14 - Contract laboratory procedures are discussed <br /> for sampling protocol. California certification is not <br /> discussed. California law requires that laboratories carrying <br /> out hazardous waste sampling must be certified by the <br /> Department. <br /> 4 . this document is labeled as a final EE/CA. It is the <br /> Department' s assertion that the EE/CA is not a final document <br /> until regulatory approval is granted. Please note this in <br /> future submittals. <br /> 5. Page 9 - The removal action schedule considers this a time <br /> critical action. Additional rationale needs to be presented <br /> to support this statement. <br /> Should you have any questions regarding these comments, please <br /> contact me at (916) 855-7874 . <br /> Sincerely, <br /> Jim Pinasco <br /> Waste Management Engineer <br /> Site Mitigation Branch <br /> cc: See next page. <br />