Laserfiche WebLink
CEIVED� <br /> opy <br /> _JAN 0 8 1992 -- <br /> ENVIRONMENTAL HEALTH - <br /> PERM IT/SERV 1(1S <br /> December 27, 1991 <br /> Mr. Robert Evans <br /> Water Resources Control Engineer <br /> Calif. RWQCB Central Valley Region <br /> 3443 Routier Road <br /> Suite A <br /> Sacramento, CA 95827-3098 <br /> RESPONSE TO NOVEMBER 5, 1991, REGIONAL WATER QUALITY <br /> CONTROL BOARD (t"1;WQC B) LET'T'ER TO C I T Y OF S T(iCK-1 ON <br /> This letter responds to your November 5, 1991, letter regarding the Austin Road Landfill. Your <br /> letter presents additional concerns about the corrective action plan (EMCON Associates <br /> [EMCON], October 199 1)and the city of Stockton's September 30, 1991, letter to the RWQCB. <br /> In your letter, you state that electrical conductivity (EC), total dissolved solids (TDS), and pH <br /> are reasonable constituents of concern (COC) at the landfill. We acknowledge the regulatory <br /> definition of COC in Article 10 of Chapter 15, Title 23, of the California Code of Regulations, <br /> which states that "'constituents of concern' means any waste constituents, reaction products, and <br /> hazardous constituents that are reasonably expected to be in or derived from waste contained in <br /> a waste management unit." Our original intended use of the term COC focused on parameters <br /> that presented the most immediate potential health threat, i.e., volatile organic compounds. In <br /> light of the broader definition of COC in Chapter 15, however, we agree that EC, TDS, and pH <br /> should be added to the list of COC for the site. <br /> Your letter also states that "the elevated levels of EC and TDS in well MW-3 and trace levels <br /> of VOCs in well MW-5 indicate a release of waste from the waste management unit must be <br /> investigated further to verify the release." A revised monitoring program for the landfill is <br /> being prepared. Consistent with Article 5 of Chapter 15, the new monitoring program will have <br /> a statistical mechanism to identify and verify constituents the landfill may be releasing. <br /> Your November 5, 1991, letter presents concerns regarding treatability of the condensate return <br /> from Pacific Energy. Please be advised that the condensate return will not be treated using the <br />