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El <br />I. Comments and Responses to Comments on the Report of Disposal <br />Site Information <br />Comment 1 <br />The presence of waste in contact with ground water is in <br />violation of section 17709 Title 14 CCR. PHS-EHD requests a <br />remediation plan be submitted as part of the RDSI. <br />Response to Comment 1 <br />Section 17709, Title 14 CCR allows waste in contact with ground <br />water under conditions approved by the Regional Water Quality <br />Control Board (RWQCB). The RWQCB is aware that auto shredder <br />waste (ASW) is in contact with ground water at the site, and has <br />indicated that a conceptual closure plan which would cover and <br />close the in-place ASW is appropriate. This was among the <br />results of a meeting which was attended by Cove Contractors, the <br />RWQCB, the PHS and Kleinfelder at Kleinfelder's offices in <br />Sacramento in February of 1990. <br />As a result of this meeting and a subsequent meeting with RWQCB <br />staff, a corrective action evaluation was included in a Report of <br />Waste Discharge (RWD) submitted to the RWQCB on January 10, 1991, <br />which was also included in the Periodic Site Review Report <br />(Appendix D) submitted to PHS in January 1991. Based on a <br />request by RWQCB staff, a cost estimate for removal of the waste, <br />or other remedial options, was included in the Corrective Action <br />Report. <br />The hydrogeologic and groundwater quality conditions at the site <br />are very complex. Groundwater beneath the site is influenced by <br />Walker Slough and variations in groundwater levels between 3 <br />hydrogeological zones. Kleinfelder has been performing' <br />groundwater monitoring at the site and most recently submitted a <br />groundwater monitoring report to the RWQCB in April 1991. Recent <br />results indicate the in-place ASW may not be affecting <br />groundwater at the site. In addition, groundwater modeling in <br />the RDSI indicates capping of the site will reduce infiltration <br />and thus potential to affect groundwater. Therefore, remediation <br />of potential impacts by capping is a viable alternative. <br />Comment 2 <br />California Regional Water Quality Control Board (CRWQCB) Waste <br />Discharge Requirement (WDR) 87-22 permits the disposal of Auto <br />Shredder Waste (ASW) to class III landfills under specific <br />conditions "as designated by the regional board." The resolution <br />also states that ". . . processed shredder waste may pose a <br />significant threat to water quality if discharged to an unlined <br />1 <br />