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N&O (draft) : California clay Landfill, 39-AA-0010 Page 2 <br /> 2 . Under the Violations of California Code of Racmlations <br /> section of the draft N&O, Section 17709 is cited singly <br /> yet is coupled with Section 17629 within the SPECIFIED <br /> ACTION section of the draft N&O. To avoid possible <br /> confusion, staff suggest that either Section 17629 be <br /> cited along with Section 17709 under Violations or that <br /> Section 17629 be dropped within the ACTIONS section. <br /> 3 . Under the SPECIFIED ACTION portion of the draft N&O, the <br /> inclusion of Sections 18263 and 18266 of 14 CCR is <br /> inappropriate at this time. <br /> 4 . Under the SPECIFIED ACTION portion of the draft N&O <br /> regarding Sections 17629 and 17709 of 14 CCR, a statement <br /> more in line with a description of a violation was <br /> provided. Staff suggest that this statement be moved and <br /> included with the violation statement regarding Section <br /> 17709 in the Violations section of the draft N&O. <br /> Staff further suggest that the order to " . . .characterize <br /> the existing waste material within the landfill", found <br /> within the ORDER section, be included as a part of the <br /> SPECIFIED ACTION section regarding 14 CCR 17709. As <br /> detailed within Board staff's March 10, 1992 "Site <br /> Assessment Report" for this site, ". . .part of the <br /> characterization must be to sample the untreated ASW and <br /> run the Waste Extraction Test (WET test) on the waste to <br /> determine the actual mobility of the metals in the waste <br /> and to determine if other hazardous constituents exist at <br /> the site. " (Note: Since the draft N&O contains a <br /> specified time frame pursuant to 14 CCR 18304 (d) (2) for <br /> implementing "specified action" for violations of <br /> Sections 17684 and 17682 of 14 CCR, the inclusion of a <br /> "specified date" to report the results of any required <br /> characterization test results would be consistent. ) <br /> As always, this office is available to assist you. If you have <br /> questions regarding staff comments please call me at 916-255-2459, <br /> or Brad Williams, your compliance North contact at 916-255-2471. <br /> Sincerely, <br /> 94A� <br /> H. Thomas Unsell, Supervisor <br /> Compliance North, Section B <br /> Permitting and Compliance Division <br /> HTU:BPW <br /> cc: Ed Padilla, San Joaquin County Health Services <br />