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• MEMORANDUM * 'CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD - CENTRAL VALLEY REGION 3443 Routier Road Phone: (916) 361-5600 Sacramento, CA 95827-3098 ATSS Phone: 8-495-5600 TO: Greg Vaughn FROM: Camilla Williams Senior WRC Engineer Engineering Geologist DATE: 28 June 1989 SIGNATURE: YN/ �,4 � yN�91 SUBJECT: HARGIS AND ASSOCIATES' CLOSURE PLAN, KEARNEY-KPF, SAN JOAQUIN COUNTY I have reviewed the 30 May 1989 Closure Plan for Kearney-KPF submitted by Hargis and Associates. The Closure Plan contains a summary of previous soil sampling, plans for additional soil investigation, a risk assessment, four closure alternatives and post closure procedures. Because the Closure Plan calls for additional soil sampling and analysis on which the risk assessment will be based and on which the closure alternative will be chosen, it would be premature to approve this Plan. In general the report is well organized and is comprehensive, but lacks detail for closure . The soil assessment plan is adequate. My review contains major and minor comments which should be considered by Hargis for the soil assessment and for preparation of the final closure alternative. My comments can be found in the attachment. Regardless of the chosen alternative, if wastes are to be left in-place, Kearney- KPF must file a Report of Waste Discharge (RWD) , an application and the appropriate filing fee. The original RWD, dated 8 March 1988, was proposed for treatment of waste waters at a Treatment, Storage and Disposal facility, for recycling of waste materials and for irrigation of the property using treated water. This application was accompanied by a $500 filing fee. Kearney-KPF is no longer proposing the same waste disposal to land and therefore, a RWD must be resubmitted. The new RWD should address all residual wastes resulting from past and present waste disposal practices to any waste management units. The application and filing fee is to permit closure of all waste management units. The required filing fee is $10,000 (because Kearney-KPF submaitted a Hydrogeologic Assessment. Report, the $20,000 fee is reduced by 50 percent) . The $500 paid by Kearney-KPF in March 1988 will be applied toward this fee. It is imperative that Kearney-KPF submit the RWD, application and $9,500 filing fee as these requirements must be met prior to receiving their revised closure waste discharge requirements from the Regional Board. The required components of a complete RWD are found in Sections 2590, and 2594 through 2597 of Subchapter 15 of Title 23 of the California Code of Regulations. Copy