COMPLIANCE INFO_2019 - Laserfiche WebLink

Home Browse Search

Ms.Kathleen Ledbetter LBA Logistics Center III August 29,2019 14800 W. Schulte Road,Tracy,CA Page 2 The residual product waste removed from onsite storage tanks,transformers,and heavy equipment(red- diesel fuel and non-PCB transformer oil)was recycled at an offsite recycling facility and recycling documentation was also completed on a standard BOL.All waste and product chemicals,liquids and solids were transported from the project site on July 12,2019.Copies of the disposal documentation for the waste chemicals,cylinders,ammonium hydroxide and BOLs for the red-diesel and non-PCB transformer oil are included in Attachment A—Waste Disposal Documentation. During the course of the chemical consolidation,any container that was emptied of its contents or empty containers staged around the property and as tagged in the NOV,were high pressure washed by AIS crew members and the generated wash-water(based on waste type)was consolidated,contained and manifested appropriately. Once the subject container,drum,or vessel was cleaned,it was demarcated with red-spray paint and considered general construction debris for eventual off-site disposal.Plastic and/or poly containers were cut up into manageable pieces and transported to a local Class III landfill for disposal.Any metallic items(drums or small tanks),were flattened and transported off-site for eventual destruction at a local metal recycling facility.AIS returned to the site on July 16,2019 to coordinate the loading and export of all cleaned empty containers and/or vessels(both plastic and metal).This task was completed on July 17,2017.Copies of the disposal documentation for the cleaned waste drums,totes,and tanks(plastic& metal)are included in Attachment B—Cleaned Container Disposal Documentation. The following day,July 18,2019,AIS field Superintendent,Joe Sepulveda met with SJCEHD representatives to conduct a site inspection of the work that had been completed per the NOV listing.The inspection results indicated that the items flagged in the initial NOV listing had been taken care of but there were a few additional items that the County Inspectors noted that needed to be removed.The items in question were as follows: one(1)propane cylinder(in Warehouse); several backup batteries(seven to be exact in the Fire Pump Building);two(2)product silos(Hydrated Lime and Sodium Bicarbonate);and an onsite oil/water separator that contained some residual rain-water. AIS personnel returned to the site on August 21,2019 to remove the flagged propane tank and backup batteries from the facility.Both items were documented on BOLs,destined for recycling.Copies of the BOL documentation for the propane tank and batteries are included in Attachment C. The two product silos in question were further inspected by onsite personnel and it was determined that neither product silo contained any residual product or particulate matter prior to demolition.A second inspection was conducted which confirmed no product had become dislodged during the demolition effort and the two silos were demolished and exported to an offsite metal recycling facility with other metal from the site demolition activities. Shortly after the July 18,2019 inspection,AIS returned to the site to acquire a sample of the Separator water and have it analyzed for general chemistry components,of which it was determined that the water was clean and not impacted from former operations.As of the time of drafting this letter,the water is currently evaporating within the separator unit until such time the water is discharged onsite(via Notice of Intent to Discharge Permit);allowed to evaporate(taking advantage of site schedule and summertime temperatures);or transported offsite as a non-hazardous waste liquid to a local recycling/disposal facility.