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Mr. Padilla <br /> Page 2 <br /> Additional Comments <br /> Staff reviewed the financial assurance mechanism and determined <br /> that it does not meet the requirements of 14 CCR 18284 and <br /> 18285. If you have any questions concerning the financial <br /> assurance mechanism contact Nancy Jestreby of the Board's <br /> Financial Assurance Section at (916) 255-2441. <br /> The WDR #90-122 sets a time schedule for the completion of <br /> verification monitoring and corrective active measures for <br /> ground water clean up. This schedule must be implemented on <br /> time. <br /> It appears that there may be a change in the design of the <br /> landfill per a letter dated December 21, 1991 to the Regional <br /> Water Quality Control ontrol Board (RWQCB) regarding the treatment of <br /> condensate on-site. if this happens an addendum or amendment to <br /> the RDSI describing the change must be submitted and included as <br /> a conditioning document to the permit. <br /> The September 19, 1991 inspection conducted by Board staff <br /> identified State Minimum Standards violations. The facility <br /> must be in compliance with the State Minimum Standards before <br /> Board staff can recommend concurrence in the issuance of a SWFP. <br /> In a May 28, 1991 letter the CIWMB outlined certain concerns <br /> about disposal of condensate in the landfill. Please detail how <br /> the Board's concerns have been addressed. <br /> 40 CFR 258 requires that by October 1993, leachate or gas <br /> condensate be placed only in landfills which are designed with a <br /> composite liner and leachate collection system. <br /> The Periodic Site Review (PSR) dated November 1988 referenced <br /> other documents. It is recommended that PSR's be "stand-alone" <br /> documents. 14 CCR 17607 requires that the PSR include the <br /> estimated remaining site life, conclusions, and recommendations <br /> be included. <br /> The application and draft permit differ in the daily peak load <br /> and expected closure year. In addition, the date the <br /> application was received and accepted must be completed by your <br /> office. The permit application should be corrected. <br /> It is important that all supporting documents be consistent. <br /> For example, the information contained in the permit, RDSI, and <br /> WDRs should be consistent with one another. <br /> Thanks for providing me with the opportunity to comment. If you have <br /> any questions, please contact me at (916) 255-2434. <br /> Sincerely, <br /> Beatrice Cuenca <br /> Waste Management Specialist <br /> Permits Branch <br /> Permitting and Compliance Division <br />