COMPLIANCE INFO_1993-1996 - Laserfiche WebLink

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Mr. James B. Giottonini Pate 2 Regarding tarp use, CIWMB staff note that page three of the project proposal states: "The geoie-wile blanket will serve as a back up cover at Austin Road Landfill in the event that ground green material is not available or wet weather precludes the movement of green material and soil. However, prior to use of the Covertech C-440', verbal approval must be obtained fi-oin LEA staff." It would appear that a verbal approval for every tarp application has been difficult to implement. Therefore, the City and LEA should agree on an amendment to the proposal to clarify the circumstances of tarp use. CIW.NM staff recommend that Covertech C-440i0 (or equivalent) tarps be considered as the primary cover option after green material. Soil alone or in combination with green material would be used at least at the end of the operating week unless emergency conditions (i.e. extreme wet weather) make using soil or green material impractical. The City should also clarify the terms of proposed extended days use of tarps (i.e. allow for the tarps to remain in place for up to four days) so that the LEA can effectively evaluate such use. The LEA has also expressed concerns that routine landfill maintenance not be detracted on as a result of ADC use, in particular with regard to wet weather operations. CIWMB staff understand that the City's landfill contract operator is required to submit vet weather operations plans to address most of these problems and that this is a relatively new and developing procedure. The City, contract operator, and LEA should agree to meet prior to each wet season to reevaluate the plans and revise them if necessary. The Regional Board should also be kept informed and participate directly if they deem it necessary. In concert with Regional Board Waste Discharge Requirements, typically wet weather preparations are established by October 15 of each year. To improve communication, the City and LEA should reestablish protocols, including the chain of communication and specific contacts between the City, contract operator, and LEA inspector. Weekly meetings or conference calls are strongly recommended at the start of each operating week during the demonstration phase to go over ADC plans and issues. The City would provide the LEA during these meetings with each week's schedule for ADC placement (i.e. projected days of tarp and green waste placement and day of maximum extended days tarp use). If the projected schedule cannot be met the City should promptly notify the LEA. If problems cannot be corrected through informal communication, they must be documented and transmitted promptly in writing. The weekly meetings or conference calls should continue until the LEA's concerns have been alleviated. I hope these comments and recommendations are helpful. I would also be happy to meet with all parties at the site if requested. If you have any questions, please contact me at (916) 255-1198.