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the potential foL ground water degradation was minimal, discharge <br />requirements were waived by CRWQCB. <br />In May, 1977, complaints were received from the Stockton Fire <br />Department of 6 separate fires occurring at the site. Learner <br />Company reponded to the Health District that the apparent reason <br />for the fires was the restricted water flow into the waste storage <br />containers during a time of water shortage. The water flow was <br />increased. <br />Extensive and recurrent open burning violations have been <br />documented in September and October, 1978. With the proper <br />operation and maintenance of the site according to the provisions <br />and specifications of solid waste facility permit 39 -AA -010, the <br />problems of fires at the site would be greatly minimized. This <br />fact is implied by the attorney for California Clay Products in <br />the Revised Operating Plan submitted to CR14QCB on June 29, 1973. <br />The current operation of this site does not comply with the State <br />Minimum Standards of Solid Waste Handling and Disposal. The <br />operator has not submitted a winterization plan as of this date <br />(deadline: August 10, 1978). Scavenging is occurring at this <br />site which is prohibited. Residential refuse and tires are being <br />deposited at the site which- incoming records of <br />weights and volumes have ted by August 1, 1978 as <br />required. All litter and loose materials are not being routinely <br />collected and properly disposed. Names, addresses, telephone <br />numbers, and other emergency information have not been provided. <br />Identification signs with this information have not been provided <br />at each point of access. Adequate barriers have not been provided <br />around the pit area. All existing loose refuse brought to the <br />final lift has not been covered with two feet of clean, compacted <br />cover material. No measures have been taken to minimize the <br />generation of fugitive dust. A safe area has not been set aside <br />for receiving burning wastes. A means for extinguishing these <br />wastes has not been provided. The operator has not submitted the <br />required site design identifying efforts to be taken to prevent <br />the creation of hazards or nuisances relative to the operation of <br />the site. <br />In the judgment of this writer, the continued operation of <br />disposal site 39 -AA -010 in multiple violation of the provisions <br />of the current solid waste facility permit can only lead to the <br />recommendation that the District, as designated local enforcement <br />agency for solid waste management, consider revocation of said <br />permit. <br />November 29, 1978 <br />