Closed, Illegal and Abandoned (CIA) Disposal Sites

Inspection Frequency

Elimination

Sites suitable for elimination from the required quarterly inspection frequency and the workload analysis portion of the LEA's Enforcement Program Plan (EPP) are sites that:

• Cannot be located even after a thorough documented search (These sites can either be Category U or X depending upon the documentation.).
• Have been certified as clean closed by the LEA/RWQCB/CIWMB with supporting documentation (for example, clean-closure plan and certification of closure).
• Are not solid waste disposal sites (Category X).
• Are Category "D" (no threat).

To request the elimination of required inspections, the LEA should submit the request along with the supporting documentation to the Board's Remediation, Closure, and Technical Services Branch (RCTS). Upon concurrence by RCTS staff, no further inspection of the subject sites would be required and RCTS staff would inform LEA Support Services staff that the sites could be eliminated from the EPP workload analysis. 

However, sites eliminated from the required inspection schedule will still be listed on the LEA’s EPP. Generally, only Category “X” and clean-closed Category “D” sites will be placed on an archive list maintained by the Board.

Reduction

Reduction of inspection frequency for category "A," "B," or "C" sites may be appropriate when it can be established that the site will not pose a significant threat to the public health and safety and the environment if inspected at less than a quarterly frequency.

LEAs may request a reduction in CIA site inspection frequency by submitting a request to the Board's Remediation, Closure, and Technical Services staff for concurrence.  The submittal should include the following:

1. SIP forms (or other appropriate forms) for the site.
2. Documentation that closure, remediation, or corrective action requirements have been met for the site. Documentation may include final office and field investigation reports, as-built plans and specifications for the remedy, and construction completion or clean-closure reports.
3. Documentation demonstrating adequacy of the proposed inspection frequency to ensure the protection of public health and safety and the environment.
4. Tracking system which will ensure notification of the LEA prior to changes in the site's land use that may jeopardize the integrity of previously closed sites or pose a potential threat to public health and safety and the environment.

A suggested method for tracking CIA site land-use or zoning changes or proposed construction on CIA sites is to establish a memorandum of agreement between the LEA and the local land use planning authority (city or county planning departments), building department (which approves construction and grading permits), and/or public works agency to provide notification of any proposed changes to disposal site conditions. A clearly marked map depicting the location of known CIA site locations (for example, those inspected and listed on the LEA’s EPP) should be provided to the agency with specific affected addresses and parcels. A short list of processes and permits that could flag a postclosure land use of a CIA site would be:

• Real estate transaction transferring property title or deed (city or county Assessor’s Office).
• Land-use zoning change in general plan (city or county planning department).
• Building, construction, or grading permit (city or county building department).
• CEQA document and public notification for proposed project (city or county planning department).

The inspection frequency for sites other than category "C" should generally not be less than once a year.  However, for category "C" sites, one inspection every two years may be appropriate.

If you have questions regarding EPP amendments for reduction of inspection frequencies, please contact your Board LEA Branch staff liaison.

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Last updated: April 18, 2008