California Department of Resources Recycling and Recovery (CalRecycle) 

Enforcement Advisory Council

Department of Toxic Substances Control Response Regarding Technical Advisory Group on Burn Dump Sites in California

July 10, 2002

Mr. Michael L. Schmaeling, Chair, EAC
Solid Waste Local Enforcement Agency
Santa Barbara County Environmental Health Services
2125 S. Centerpointe Parkway, Room 333
Santa Maria, California 93455

Dear Mr. Schmaeling:

I am inviting you or your representatives to participate in a technical advisory group that will assist the Department of Toxic Substances Control (DTSC) in developing guidance to address burn dump sites in California. As I am sure you and your members have discussed, the ability of the State of California (State) to provide effective and consistent guidance on burn dump site remediation is compromised by the number and diversity of environmental regulatory agencies with jurisdiction over both the content and impacts of these sites.

Based upon information provided by the California Integrated Waste Management Board (CIWMB), the number of reported burn dump sites in the State approaches 550. The number of unreported sites is unknown but is likely very significant. Numerous State agencies have an interest in ensuring that these sites are handled properly. The CIWMB, as the lead agency for non-hazardous solid waste, is on the front lines with the Local Enforcement Agencies (LEA) in identifying and managing burn dump sites. Most of the sites likely contain hazardous substances due to historical management practices.  DTSC’s primary concern is that the risk caused by public exposure to these substances be addressed properly. It is very important that members of the public, exposed to hazardous substances at burn dump sites, receive similar protection as exposures from other sources.  In addition to DTSC’s concerns, the State Water Resources Control Board (SWRCB) and its Regional Water Quality Control Boards (RWQCBs) are concerned with any potential degradation to the waters of the State that may occur at burn dump sites based upon site-specific characteristics.

DTSC has taken the lead to develop a guidance document, which could be used by any State or local agency because the likely presence of hazardous substances and addressing the potential for public exposure is the overriding concern at these sites. DTSC is committed to an approach that takes advantage of the information and expertise that each environmental regulatory agency has to offer. We are especially interested in gaining your participation in our technical advisory group because as local agencies, you have the greatest involvement with and interest in these sites.

Our goal is to develop a working guidance document by the end of June 2003.  We will be convening the technical advisory group in September of this year to discuss the scope and content of the guidance document. The group will meet a minimum of monthly, and possibly more frequently, based upon agreements reached at that time. Mr. Stewart black, Supervising Hazardous Substances Engineer Geologist, Northern California Geological Services Section, will be project leader for the development of the guidance document. Please contact either myself at (916) 255-3657, or Mr. Stewart Black at (916) 255-3665 to discuss you participation in the technical advisory group and answer and questions that you might have. We would like to transmit a listing of workgroup members to each participant by the beginning of August along with potential meeting dates. We would appreciate hearing from you by July 22, 2002.


Original signed by

Caren Trgovcich, Chief

Emergency Response and Statewide Operations Division 

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Last updated: February 8, 2005
Enforcement Advisory Council (EAC)
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