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California eiol iter ypontrol oar <br /> Central Valley Reg t <br /> Robert Schneider,Chair a: : T <br /> Winston H.Hickox '" Gray Davis <br /> Secretary for Sacramento Main Office ! <br /> ## t Governor <br /> Environmental Internet Address: http://www.swrcb.ca.govirwgcW : <br /> Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 <br /> Phone(916)255-3000•FAX(91 G)255-3015 <br /> 22 June 2001 <br /> Mr. Curtis G. Fujii <br /> Forward Inc. <br /> 1145 West Charter Way <br /> Stockton, CA 95206 <br /> REVIEW OF REVISED ENGINEERING FEASIBILITYSTUDY, AUSTIN ROAD LANDFILL, <br /> SAN JOAQUIN COUNTY(Case No. 2148) <br /> We have reviewed the Revised Engineering Feasibility Study, Austin Road Landfill, San Joaquin <br /> County, California prepared on your behalf by Herst&Associates, Inc. and Andrews Environmental <br /> Engineering Inc and submitted 11 June 2001. The Engineering Feasibility Study(EFS)presents the <br /> results of a hydrogeologic model study undertaken to evaluate cleanup strategies. The EFS <br /> concludes that cleanup can best be achieved by improved landfill gas extraction, continued operation <br /> of the existing groundwater pump and treat system, and artificial recharge of treated groundwater. <br /> We have the following comments regarding the EFS: <br /> 1. The EFS as written does not meet the minimum requirements of Title 27. Section 20420(k)(6) <br /> states in part: ...submit to the RWQCB an engineering feasibility study for a corrective action <br /> program necessary to meet the requirements of Section 20430. Section 20430(a) - 0) spells out <br /> the requirements for corrective action programs. The main points that are missing from the EFS <br /> may be summarized as follows. <br /> a. The discharger shall take corrective action to achieve compliance with the Water <br /> Standard; <br /> b. corrective action measures shall be designed to ensure that COCs achieve their respective <br /> concentration limits at all Monitoring Points and throughout the zone affected by the <br /> release; <br /> c. establish a water quality monitoring program to demonstrate the effectiveness of the <br /> corrective action program; <br /> d. propose a compliance schedule to implement corrective actions; <br /> e. and submit semi-annual corrective action progress reports. <br /> At a minimum the EFS should address items a through e listed above. The Water Standard for <br /> VOCs is non-detect and the EFS should clearly address cleanup to that level throughout the <br /> affected zone. The EFS should address generally the following: establish a revised monitoring <br /> program including additional monitor wells to demonstrate progress toward cleanup,propose a <br /> schedule to implement corrective actions, and establish a plan for semi-annual progress reports <br /> with criteria to determine if corrective action is successful. <br /> California Environmental Protection Agency <br /> Qa Recycled Paper <br /> The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. <br /> For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at http://www.swreb.ca.gov/rwgcb5 <br />