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s s <br /> FCL/ARL Green Waste ADC <br /> Page 2 of 2 <br /> Since the procedure at this landfill is to deposit wastes into <br /> shallow cells in a linear fashion (a new cell each day along the <br /> slope face) and then cover with the tarp(s) , an exceedingly large <br /> amount of waste surface area becomes dependent on this cover for <br /> an extended period of time. The tarp has limited approval for <br /> use and was never approved for more than overnight use; it is <br /> only approved as ADC upon consensus with EHD. EHD has requested <br /> and the GWADCP reflects an agreement for verbal communication <br /> from the operator regarding when the tarp may or may not be used. <br /> The operator has not communicated with EHD prior to tarp use. <br /> 2) Visquene plastic has been used as ADC at ARL. Visquene is <br /> not an approved ADC and is in direct violation of CCR14 cover <br /> regulations. This practice has been discontinued. <br /> 3) Litter, although not a large problem, continues to be of <br /> concern. There have been instances of incomplete coverage at the <br /> end of the day which allows litter migration at both sites. <br /> 4) At FCL the ADC shredding operation moves along smoothly and <br /> reduced quantities of landfilled wastes are more easily managed; <br /> however incidences of landfill maintenance neglect (ie. erosion, <br /> ponding, litter, intermediate cover inadequacies) have increased. <br /> CONCLUSIONS• <br /> The GWADCP plan specifically outlines procedures to perform a <br /> pilot demonstration to determine the acceptability of shredded <br /> green waste as a daily cover for other landfill wastes. Since <br /> quantities of green waste are in short supply and other ADC's <br /> are applied to fill in the gap, the intent of this project has <br /> become unclear. EHD has not approved any plan for demonstration <br /> of more than one ADC at any one time, or two ADC's used in <br /> conjunction with each other; according to the GWADC plan, tarp <br /> cover is only allowed under specifically approved instances and <br /> only with the verbal agreement of EHD. This provision was <br /> included only as an emergency measure, not as standard procedure <br /> when green waste supplies are insufficient. Soil cover is the <br /> only acceptable cover in this situation. <br /> Also, the plan to demonstrate green waste ADC cannot be carried <br /> out if there is not enough green waste to use for cover. Green <br /> waste ADC cannot be evaluated effectively for cover if there is <br /> not enough of it to use as cover. The operator does not meet the <br /> intent or follow specifications of the GWADC plan as approved by <br /> EHD. <br />