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Q1 e. STATE OF CALIFORNIA-Environmental ProtecAbgency PETE WILSON, Governor CALIFORNIA REGIONAL WATER QUALM CONTROL BOARD CENTRAL VALLEY REGION � +�rF� 3443 Routier Road, Suite A Ir i F L HEAL TN Sacramento, CA 95827-3098 f7��ts'f �f PHONE: (916) 255-3000 ICE FAX: (916)255-3015 93 jUpi PH 1. 5 16 June 1993 Mr. Doug Ohland Southwest Hide Company P. 0. Box 2083 Manteca, CA 95336 FINAL CLOSURE PLAN, CLASS II SURFACE IMPOUNDMENTS, SOUTHWEST HIDE COMPANY, MANTECA, SAN JOAQUIN COUNTY (CASE# 2664) The Final Closure Plan proposes to close the two Class II surface impoundments pursuant to Section 2582(b) (1) of California Code of Regulations, Title 23, Division 3, Chapter 15 (Chapter 15) . Section 2582(b) (1) allows the surface impoundments to be closed by removing all wastes and liner materials for discharge at an approved waste management unit. The closure of the two surface impoundments pursuant to Section 2582(b) (1) is acceptable and Southwest Hide may proceed with the removal of all wastes and liner materials for discharge at Forward Landfill in San Joaquin County. There appears to be some confusion regarding how the surface impoundments will be closed and how the entire site will be closed. On page 10, the Plan states that the surface impoundments will be closed pursuant to Section 2582(b) (1) . However, on page 11, the Plan states that due to the amount of salt-laden soil (hereafter referred to as wastes) at the entire site, it is infeasible to take all the wastes at the site to an approved landfill and, therefore, the surface impoundments will be closed as a landfill pursuant to Section 2581 . While it is our understanding that wastes were discharged to various portions of the site during past operations, we are not seeking to close the entire site at this time. Better delineation of both the salt and volatile organic contamination plumes and a revision of the existing monitoring program are necessary prior to development of a remediation strategy. Southwest Hide should proceed with the actions necessary to close the surface impoundments. Southwest Hide can address the rest of the wastes, previously discharged to ground, after more information is determined regarding the extent of salt and volatile organic contamination. Although we want to know how Southwest Hide will handle any wastes that have leaked below the liners or are contained in the berms, we do not wish to slow the progress Southwest Hide has made towards closing the site. Once the liner has been removed, the soils beneath the liners can be tested for salt contamination. At that time, we will resolve what course of action Southwest Hide will take regarding these wastes.