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Security Violation <br />17658 - Site Security: <br />The onsite equipment and building are listed as being in violation of this section and <br />removal of the equipment and repair of the building are the stated actions that will remedy <br />the violation. Section 17658 states: <br />The site shall have a perimeter barrier or topographic constraints designed to <br />discourage unauthorized entry by persons or vehicles. Areas within the site where <br />open storage or pending of hazardous materials occurs shall be separately fenced <br />and properly identified to create an adequate level of security, unless the daily <br />deposition of wastes is conducted under adequate supervision during the site <br />operating hours and provided said waste are covered by the end of the daily site <br />operations. <br />The onsite equipment is from an earlier metals recycling operation. It is presently stored <br />onsite for ultimate use as scrap metal. The building is currently unoccupied and unused. <br />We are not aware of a definition in Title 14 that designates either buildings or scrap steel <br />as a hazardous material. Consequently, we do not see how this particular section applies <br />to either the equipment or the building. Relative to security, the site is fully fenced and the <br />entry gate is locked. In our opinion, this satisfies the security requirements of Section <br />17658 and no violation appears to exist. <br />SSI pes/Cuts/Grading Violations <br />17678 - Slopes and Cuts: <br />Since the inspection, the intermediate grading plan has been implemented at the site. <br />Exposed waste has been covered with a one foot soil cap and waste slopes have been cut <br />back to 2:1 (approximately 27). The inspection report notes that the steep soil wall at the <br />northern side of the site is in violation because the maximum grade (30) specified in <br />17678. The 30° grade requirement is a reasonable maximum for slopes upon which waste <br />is compacted but is not reasonable as a blanket restriction for sideslopes of excavations. <br />The stability of a steep side slope is dependent upon the strength and types of soils in the <br />side slope. With the right combination of conditions and soils, even a vertical soil wall can <br />be stable for an extended period of time. The soil wall in question has been standing for <br />probably 15 to 20 years. Eventhough this is a good indication of stability, Cove <br />Contractors authorized Kleinfelder in December of 1993 to conduct a geotechnical <br />investigation of the steep soil wall on the north side of the site. Cove Contractors is <br />attempting to obtain permission from the adjacent landowner to allow Kleinfelder access <br />to their property for the purpose of advancing a geotechnical boring directly behind the <br />soil wall. Once this permission is obtained, the work will begin immediately. Results of <br />the investigation will be transmitted the San Joaquin County Environmental Health. Thus, <br />no violation appears to exist. <br />17710 - Grading of Fill Surfaces: <br />As stated earlier, the intermediate grading work has been completed at the landfill and the <br />one foot thick soil intermediate cover has been installed. This work corrects past grading <br />and drainage problems. Thus, no violation appears to exist. <br />24-215600-H00/CL4-13 (1994) Page 2 of 6 April 29, 1994 <br />KLEINFELDER 2240 Northpoint Parkway, Santa Rosa, CA 95407 (707) 571-1883 <br />