(2)AR 081908 Appeal - Pacific Rail Industries

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The staff report is very skimpy on information and leads one to believe that the applicant will have all the answers when the fluff starts spewing out of the shredder. I believe that this conclusion has no merit. I base this statement on the fact that Mr. Siroonian has never publicly stated that he has operated a car shredder. Therefore, he is zero in car shredding experience. I believe that he has no hazardous materials transporting experience. I believe that Pacific Rail Industries has no registered drivers or is certified to haul hazardous waste_ Is there a need for specialized trucks to haul the toxic waste? I see no requirements placed on the transporter trucks for certification, cleanliness, debris tracking, spillage, leakage, or routing. It just talks about using impervious tarps and hauling the fluff to Arizona. I found no drivers licensing requirements. It is very important to know that the state of California considers auto shredder fluff a hazardous waste requiring special disposal. The staff report does not make mention of PRI paying any hazardous materials generation fees for the fluff. The staff report does not clearly call out the California Department of Toxic Substances Control (DTSC) authority for PRI to treat auto shredder fluff. No written, detailed agreements with the waste receiving entity (it is mentioned that the disposal site will be Arizona) or longevity of the agreement is found in the staff report. The project description and "in-line" treatment as described in the staff report are only topical and add no clarity to the required treatments mentioned in the EIR. All detail in treatments and management is left to the applicant's "discretion." The staff report should be exact and detailed so their is no misunderstanding as to who does what and which state and federal regulations are applicable. The treatment, management, storage, and disposal of this toxic waste must be clearly stated in the staff report so there will be no mistakes made in protecting the community. The city will have to get this right the first time out when the shredder starts working. The newly built fluff storage building is a 3 walled affair and not an enclosed structure. The staff report indicates an allowed 2 to 3 weeks storage of fluff produced by the shredder. This calculates to 5,250 tons of shredder waste stored in the structure if Mr. Siroonian decides to treat and store the fluff.