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California r.e onal Water Quality Strol Board <br /> Central Valley Region <br /> Qa; Steven T.Butter,Chair 0 <br /> Winston H.Hickoz Gray Davis <br /> SecretaryJor Sacramento Main Office Governor <br /> Environmental Internet Address: htip://www.swrc.b.ca.gov/-rwgcb5 <br /> Protection 3443 Routicr Road,Suitc A,Sacramento,California 95827-3003 <br /> Phone(916)255-3000•FAX(916)255-3015 <br /> TO: File `FROM: Christopher M. Cochrane <br /> �. Associate Engineering Geologist <br /> DATE: 25 May 1999 SIGNATURE: <br /> SUBJECT: SOUTHWEST HIDE COMPANY (CASE# 2664) <br /> Staff has reviewed Southwest Hide's Waste Discharge Requirements Order No. 92-077 (WDRs), <br /> Cleanup and Abatement Order(C&A)No. 89-707,the case file, "Fourth Quarter 1998 Groundwater <br /> Monitoring,"the "Remedial Investigation/Feasibility Study..." dated September 1998, and "Addendum <br /> to Closure-Post Closure Maintenance Plan Surface Impoundments" dated August 1998. Staff has <br /> determined that"Southwest Hide is not in compliance with their WDRs, C&A No. 89-707 or Title 27 <br /> California Code of Regulations (Title 27). The purpose of this memorandum is three fold: 1)to <br /> document Southwest Hide's noncompliance with their WDRs, C&A No. 89-707 and Title 27; 2) to <br /> provide comments on Southwest Hide's "Remedial Investigation/Feasibility Study..." and <br /> "Addendum to Closure-Post Closure Maintenance Plan Surface Impoundments"; and 3)to provide <br /> comment on Southwest Hide's "Groundwater Monitoring Report, Fourth Quarter 1998." <br /> 1. COMPLIANCE REVIEW OF WASTE DISCHARGE REQUIREMENTS ORDER NO. 92- <br /> 077, CLEANUP AND ABATEMENT ORDER NO. 89-707 AND TITLE 27 CALIFORNIA <br /> CODE OF REGULATION <br /> a) Noncompliance with WDRs No. 92-077 <br /> Staff has determined that Southwest Hide is not in compliance with their WDRs. The Provisions <br /> that Southwest Hide has not complied with include but are not limited to are Provisions # 19 and # <br /> 13. The following Provisions 19 activities have not been complied with: <br /> "Complete on or before 1 May 1994, Board approved Surface Impoundment Closure of both <br /> surface impoundments. <br /> Complete on or before I May 1995, construction of Board approved solid waste remediation <br /> project. <br /> Activate on or before I March 1995, the Board approved ground water remediation facility (s). " <br /> Southwest Hide has not complied with financial assurance requirements as provided for in Provision# <br /> 13 of the WDRs. Provision# 13 requires in part: <br /> California Environmental Protection Agency <br /> �a Recycled Paper_ <br />