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STATE OF CAL.IF6;RNIA Pete Wilson, Governor CALIFORNIA INTEGRATED WASTE MANAGEMENT BOARD A . 8800 Cal Center Drive Sacramento, California 95826 ami e _ Mr. James B. Giottonini Public Works Director City of Stockton Department of Public Works 425 N. El. Dorado Street Stockton, California 95202-1997 RE: Alternative Daily Cover (ADC) Demonstration Projects, Austin Road and French Camp Landfills. San Joaauin County. Facility Nos. 39 -AA -0001 and 39 -AA -0002 Dear Mr. Giottinini: Thank you for your March 26, 1996 letter concerning the subject Alternative Daily Cover (ADC) demonstration projects. Your letter expresses concern that the San Joaquin County Solid Waste Local Enforcement Agency (LEA), in their monitoring report dated March 12, 1996, encourages the City of Stockton (City) to terminate the ADC projects even though the performance of the projects does not warrant such action. I hope this response will assist in allowing the projects to continue with the cooperation and agreement of the City and LEA. After discussing your letter with the LEA, CIWMB staff have confirmed that the LEA is not intending to terminate the ADC demonstration projects at this time, and is aware of the importance of the projects in the City's plan to meet the waste diversion mandates of AB 939. The LEA's monitoring report includes daily records which support the City's contention that the performance of the ADC projects is generally good and is meeting the minimum standards. However, the LEA's monitoring report also conveys concerns in several areas which should be resolved for their final approval upon conclusion of the demonstration projects. The main areas of LEA concern include lack of green material supply to adequately demonstrate use as ADC and tarp use at the Austin Road Landfill not fully reflected in the proposal. The LEA is also concerned that ADC operations may detract on the City's ability to adequately control other aspects of landfill operations not directly related to ADC use. CIWMB staff also note the need to improve communication protocols between the City, the City's contract operator, and the LEA in order to promptly resolve issues that come up. CIWMB staff understand that the green material supply may be accumulated and stored up to 72 hours from processing prior to use as specified in the October 1995 project proposal. To help alleviate concerns regarding lack of an adequate supply to test, CIWMB staff recommend the operator accumulate as much as possible prior to use for maximum coverage.