In the days leading up to this weeks arrests of employees and top executives at Santa Clara Waste Water (SCWW) , also known as Green Compass in Santa Paula, the company was dealing with a determination by the Environmental Health division of the County of Ventura that certain waste storage tanks on their Santa Paula property required further analysis and do not qualify for the "hazardous waste exclusion" allowed in the Code of Federal Regulations.
"Additional analytical testing is required to complete the hazardous waste determination for the following reasons," stated Melinda Talent, Ventura County Environmental Health Division in the August 5, 2015 letter to Brian Baca of Ventura County Planning. The reasons listed were as follows:
The letter informed SCWW they needed to complete a "hazardous waste determination by conducting the required testing to verify barium, lead and benzene do not exceed federal and/or state limits." These determinations were required prior to removing any of the waste from those tanks.
According to the letter one of the tanks SCWW reported was as not having any hazardous waste characteristics in fact was found to have a barium concentration of "2,000 mg/kg, exceeding 10X the Soluble Threshold Limit Concentration (in California). The waste is a potential California hazardous waste and must be removed from this category and added to the list of tanks that require further testing."
Following receiving that letter, Baca sent a copy of it, along with the email text below to Rob Dal Farra and John Hecht of Sespe Consulting, a Ventura based environmental and land use/planning firm. Sespe has represented SCWW in the past. (read the full letter also attached below)
At least 24 hours prior to fluid disposal or tank removal, EHD and Planning Division staff (Craig Cooper 805-654-2127; Brian R. Baca, 805-654-5192) must be notified of the specific actions to be taken. EHD or Planning staff may monitor the removal activities. These removal activities are hereby authorized pursuant to the April 20, 2015 Emergency Use Authorization issued by the County Planning Division.
SCWW has been in hot water since later last year when an explosion rocked the Santa Paula location, requiring hazardous material clean up.