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OU 1003029
OU 1003030
Gun Powder Point Burnsite(AKA Paradise Marsh)
37-CR-0028
OU 1003031
TOPIC OVERVIEW
Local Enforcement Agency (LEA) regulations and inspection at Closed, Inactive and Abandoned (CIA) disposal sites
Current projects at Gun Powder Point Burnsite
What are the next steps
OU 1003032
LOCAL ENFORCEMENT AGENCY
In 1972 Senate Bill 5 created the California Integrated Waste Management Board who developed State Minimum Standards.
In 1976 Assemble Bill 2439 established LEA to enforce State Minimum Standards.
San Diego County was certified by CalRecycle (formally CIWMB) to become the LEA in August 1, 1992.
OU 1003033
OU 1003034
REGULATIONS FOR DISPOSAL SITES
California Code of Regulations (CCR)• Title 14• Title 27
Public Resources Code (PRC)
San Diego County Code of Regulatory Ordinance (SDCCRO)
http://www.calrecycle.ca.gov/Laws/Regulations/http://www.amlegal.com/sandiego_county_ca/
OU 1003035
CLOSED, INACTIVE AND ABANDONED
14 CCR 18083 – LEA Duties and Responsibilities for Inspections
27 CCR 20005 - Purpose, Scope and Applicability
27 CCR 21100 – Scope and Applicability
OU 1003036
CLOSED, INACTIVE AND ABANDONED
PRC 44100 – Authority to conduct inspection at CIA.
PRC 44106 – Enforcement of State Minimum Standards at CIA site
SDCCRO 65.107(m)(5) Miscellaneous Dept. Fees
OU 1003037
WRITTEN REPORTS
Inspection ReportsObservations, Areas of Concern and Violations
LEA Written CorrespondencePlan approval, Official Notice, Notice of Violation
Enforcement OrdersNotice and Orders – PRC 45011, 45023
http://www.calrecycle.ca.gov/SWFacilities/Directory/Search.aspx
OU 1003038
DEFINITIONS
Closed, Illegal or Abandoned (CIA) disposal sites
Closed Site - disposal site that has ceased accepting waste and was closed in accordance with applicable statutes, regulations, and local ordinances in effect at the time.
Illegal Site—A disposal site that is not permitted and not exempt from obtaining a permit and is not closed or excluded from the requirement to obtain a solid waste facilities permit.
Abandoned Site—A disposal site where there is no responsible party.
OU 1003039
CLOSED, ILLEGAL AND ABANDONED
February 25, 1993, CalRecycle approved a process called Site Identification Process (SIP).
Investigative procedure to classify sites with respect to public health, safety and environment.
A mechanism to identify sites that warrant no further action, elimination or reduction.
A technical basis to determine appropriate closure, remediation, corrective action and enforcement follow up.
OU 1003040
SITE INVESTIGATION PROCESS (SIP)
Site Identification Process
Site Assessment Data
Classification Code: A, B, C, D, U, X, 1, 2, 3 B - Release or suspected release with threat of nuisance or pollution and
inadequate cover of burn ash.
2 - Located within an environmentally sensitive area.
http://www.calrecycle.ca.gov/SWFacilities/cia/sip/SiteCharact.htm#ID
OU 1003041
CALRECYCLE (FORMALLY CIWMB)
Elimination or Reduction of inspection frequency
CalRecycle Remediation, Closure and Technical Service Branch:• Glenn Young, Senior Waste Mgt Engineer
• Abel Martinez Centeno, Waste Mgt. Engineer
http://www.calrecycle.ca.gov/StaffDirectory/Employee/Listing/
OU 1003042
GUN POWDER POINT
Quarterly Inspections Frequency
Property Owners:
United States Fish & Wildlife Service
San Diego Gas & Electric
California Dept of Transportation
San Diego & Arizona Eastern Railway Co./Metropolitan Transit System
Site is comprised of multiple parcels
OU 1003043
OU 1003044
STATE MINIMUM STANDARDS
27 CCR 20530 SITE SECURITYThe site shall be designed to discourageunauthorized access by persons and vehicles byusing perimeter barriers or topographicalconstraints.
OU 1003045
OU 1003046
OU 1003047
STATE MINIMUM STANDARDS
27 CCR 21140 FINAL COVERThe final cover shall function with minimalmaintenance and provide waste containment toprotect public health and safety.
OU 1003048
OU 1003049
STATE MINIMUM STANDARDS
27 CCR 20820 DRAINAGE & EROSION CONTROL
The drainage system shall be designed andmaintained to ensure the integrity of roads,prevent safety hazards and prevent exposure ofwaste.
OU 1003050
OU 1003051
STATE MINIMUM STANDARDS
27 CCR 20750 SITE MAINTENANCE Establish a maintenance and monitoring plan tomonitor and correct deteriorated and defectiveconditions.
OU 1003052
OU 1003053
STATE MINIMUM STANDARDS
27 CCR 21190 POST CLOSURE LANDUSEAll proposed post closure land uses on closed siteshall be submitted to the LEA for review andapproval if it involves structures within 1000’ ofburied waste, structures on top of waste,modification of final cover or irrigation overwaste.
OU 1003054
OU 1003055
EVALUATING BURN SITESPhase I Office Investigation2011 Ninyo & Moore
Phase II Field Investigation.Plan Objectives;
Sampling and Analysis Plan;
Documenting and Reporting; and
Community Health & Safety Plan
Phase III – Remedial Work Scopinghttp://www.calrecycle.ca.gov/SWFacilities/CIA/
OU 1003056
REMEDIATING BURN SITES The four scenarios that will typically be
encountered when remediating burn dumps are:
Minimal action required.
Leave burn ash in place and cap.
Consolidate burn ash on site or on another adjacent parcel that already contains burn ash and cap.
Clean closure of the burn dump site.
OU 1003057
CLEAN CLOSURE
Clean Closure: The removal of all waste residuals and contaminated soil below background levels or clean up levels established by regulatory agencies.
Who evaluates clean closure proposals: LEA, CalRecycle and RWQCB in some cases APCD and/or DTSC.
DEH – Site Assessment and Mitigation VAP.
OU 1003058
CLEAN CLOSURE PROCESS The steps may include, but are not limited to:
Work plan proposal;
Scope and estimate of repair cost for closure improvements ;
The actual clean closure; and
Verification and approval of the clean closure.
http://www.calrecycle.ca.gov/SWFacilities/CIA/Remedial/CleanClosure/default.htm
OU 1003059
SITE CHARACTERIZATION/REMEDIATION Former Landfill and Disposal Site Investigation
(CalRecycle 2010)
Protocol for Burn Dump Site Investigation and Characterization (DTSC 2003)
Test Methods for Evaluating Solid Waste, Physical/Chemical Methods (EPA 2007)
Tools and Services: forms, index, SWIS, links
LEA Advisory 56 & 16 – Clean Closure (CalRecycle)
San Diego County Site Assessment & Mitigation Manual 2004
http://www.calrecycle.ca.gov/SWFacilities/CIA/tools.htm
OU 1003060
SITE EVALUATIONS San Diego Gas & Electric
Sweetwater Marsh Burn Ash Removal Work Plan (OTIE Dec 2010)
Community Health & Safety Plan (OTIE Jan 2011)
Removal Report Sweetwater Marsh (OTIE June 2011)• Area A (178 tons Class I Landfill)
(Exceeded criteria for Cadmium, Copper, lead)
• Area B (8 tons Class III Landfill)
Final determination still pending 2010/11 Quarterly Reports for site visits to evaluate
site conditions and corrective action.
OU 1003061
SITE EVALUATIONSUSFWS
• 2010/11 Quarterly Reports for Post-Closure Maintenance –Outline action to be taken in 3, 6, 12 month intervals
• Sampling & Analysis Plan Ash Deposit 1 and Eroding Burn Ash Along Connector Marsh (Haley & Aldrich 2010)
• Sept 2011 - Sampling & Analysis Report for Ash Deposit 1 and Connector Marsh (Exceeded criteria for Cadmium, Copper, lead).
• FY11 Refuge Clean Up Proposal • Phase 1 - Identify ash deposits at Paradise, Connector, Sweetwater Marsh
and Marsima de Nacion Marsh (80 Acres).
• Phase 2 - Investigation to characterize the nature and extent of waste deposits, evaluate site remediation options or no further action.
OU 1003062
SITE EVALUATIONSMetropolitan Transit System
2011 Quarterly Reports for site security inspections
Preliminary Site Investigation and Characterization (SCS Engineer April 2011):
Burn ash deposits were encountered on both the west and east sides of the railroad tracks between bridges #1 and #3 above and below ground surface.
Sampling & analysis report exceeded criteria (Antimony, cadmium, copper, lead and zinc).
OU 1003063
SITE EVALUATIONSCalifornia Department of Transportation
Site Security
Maintenance Plan
Future Action Plan
OU 1003064
NEXT STEPS Submit all proposed projects to the LEA for review and
approval prior to implementation.
Investigative and final reports shall support conclusion that
all property was adequately evaluated and impacted soils
were removed to established levels.
Establish a written maintenance plan that addresses SMS.
A closed site inspection report has been developed for use to
document site inspections and includes the most common
SMS.
OU 1003065
CLOSED SITE INSPECTION FORM
OU 1003066
NEXT STEPS
Conditions that warrant corrective actions should be
outlined in the inspection reports. If necessary, short and
long-term objectives and time-lines should be identified.
Records for January, February, and March are due May 1,
records for April, May and June are due August 1, records
for July, August and September are due November 1, and
records for October, November and December are due
February 1.
Electronic receipt of LEA inspection reports.
OU 1003067
ELECTRONIC REPORT
OU 1003068
POINTS OF CONTACT
KariLyn Merlos, Supervisor LEA(858) 495-5799
Anthony Torres, Inspector LEA(858) 694-2608
Abel Martinez Centeno, CalRecyle(916) 341-6724
http://www.calrecycle.ca.gov/StaffDirectory/Employee/Listing/LastName/A/Name/ASC
OU 1003069
QUESTIONS
OU 1003070