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Mr. Bruce C. Baracco -2- March 31, 1988 <br /> Answer to Question 4 <br /> Offsite commercial storage and treatment operations involving <br /> multiple cleanups regardless of the level of contamination are <br /> considered at this time to require full permits. <br /> Answer to Question 5 <br /> There is no way for Terra Genesis to qualify for an exemption. <br /> At the present time, Terra Genesis will not qualify for a <br /> variance. DHS has not generally required variances for cleanup <br /> activities supervised by either a RWQCB or County agency r <br /> involving soil contaminated with less than 1000 ppm (TPH) . <br /> Moreover, DHS routinely issues variances for one-time only onsite <br /> or offsite cleanup activities involving soil contaminated with <br /> more than 1000 ppm (TPH) where those activities are already being <br /> supervised by either a RWQCB or county agency. (See attached <br /> memo from Charles A. White to Caroline Cabias dated March 8 , <br /> 1988) These variances are issued under the authority of Section <br /> 66310 (a) (2) of Title 22 , (CCR) which allows DHS to issue <br /> variances when hazardous waste is: <br /> " . . .handled, stored or disposed of pursuant to regulations <br /> of another governmental agency in a manner which is <br /> consistent with the hazardous waste management provisions of <br /> this chapter and which will not result in a hazard to human <br /> health and safety, livestock or wildlife. " <br /> However, as noted by Charles A. White in his 3/8/88 memo, this <br /> type of variance has been restricted to one-time onsite or <br /> one-time offsite operations. <br /> Answer to QueSrlon 6 <br /> The Department recommends for sampling, testing and reporting <br /> contaminant levels the measures that are used in the Leaking <br /> Underground Fuel Tank Manual. A copy cf this manual can be <br />