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Local Enforcement Agency (LEA) Central Task 6, Step 2 Comments-California State Association of Counties (CSAC) |
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To Richard Castle: Thank you for the opportunity to review and comment on the Draft Risk Factors on behalf of CSAC. The comments are based upon review by the CEAC Solid Waste Policy Committee. For factors such as Amount of Waste in Place, Hydrogeology, Rainfall and Proximity to Sensitive Habitat it is necessary to quantify the Parameters with the Potential Impact. It would be important to hear from the consultant how many in-place tons will be considered "large" vs "small", what depth to groundwater will be used for the "high" vs "low" risk category, what quantity and intensity will be considered "high" vs "low" risk as it relates to rainfall, and what actual distance will be used for proximity to sensitive habitat, and will different distances be applied to different types habitats. Without these things being addressed we cannot comment as to the appropriateness of the risk factors analysis. The Compliance Status factor is of concern as it is vaguely defined, will it be based solely on LEA inspection reports, or will it include input from all permitting authorities, Regional Water Quality Control Board (RWQCB), Air Districts, Certified Unified Program Agency (CUPA), etc. If LEA inspections are used, areas of concern should not be included in any count. For notices of violation certain categories should not be counted, such as; signing, lighting, dust control, bird control, litter and recordkeeping, these have little bearing on long term post-closure or corrective action risks. Again, thank you for the opportunity to comment. We will look forward to more information to quantify some of the parameters from your consultant. Susan R. Klassen, Deputy Director |
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Last updated: April 18, 2008 LEA Support Services http://www.ciwmb.ca.gov/LEACentral/ Donnaye Palmer: donnayep@ciwmb.ca.gov (916) 341-6321 |