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State Inspection- French Camleandfill Site Page 5 of 6 Facility No.- 39 -AA -0002 Violations PRG 44014(b) Permit, Terms and Conditions- The 10/3/89 5 -Year Permit Review reported, "...there is a significant change in the current design and operation of the solid waste facility." Significant changes include hours of operation, increased tonnage, installation of a scale, zoning changes on adjacent properties, the exclusion of the southeast corner of the landfill from the permitted acreage due to the extension of Downing Avenue and a PG&E gas pipeline project, the implementation of a hazardous waste screening program, and the addition of an asphalt stockpile to the types of waste received. At the time of the 5 -Year Permit Review the LEA "...determined that the significant changes of the existing permit will require a permit revision. A CEQA Review will also be required." On 3/8/91 the LEA issued a Notice and Order (N&O) to the City of Stockton (operator) which documented a violation of PRC 44004(a) (exceeding the authorized daily tonnage of 100 tons) and ordered the operator to revise the Solid Waste Facilities Permit (SWFP). The N&O reported that a CEQA Initial Study was completed and the City of Stockton subsequently approved a Negative Declaration on 6/24/91. The N&O established daily peak loadings of up to 330 tpd with an approved average of 150 tpd during the permit revision process. A draft SWFP dated 10/24/91 and Report of Disposal Site Information (RDSI) dated 4/2/90 were submitted for Board staff review on 10/30/91. Board Permits Branch staff supplied the LEA with comments regarding the 10/91 draft SWFP, 4/90 RDSI, and 11/88 Periodic Site Review (PSR) on 1/13/92. On the day of the inspection (10/27/92), a revised SWFP had not been issued for this facility. (Note: Waste Discharge Requirements (WDRs) are incorporated by reference into an SWFP as a conditioning document. As reported in the 10/17/91 State Inspection Report, this facility has not been issued WDRs by the Regional Water Quality Control Board (RWQCB). Tentative WDRs dated 11/13/92 for the French Camp Landfill were received by Board staff on 11/16/92 for comment by 11/30/92. The tentative WDRs are proposed to be adopted by the RWQCB on 12/4/92. With regard to the issuance of WDRs for this facility, please contact Mr. James Brathovde of the Central Valley RWQCB at 916-255-3137.) 14 CCR 17710 Grading of Fill Surfaces- This standard requires covered surfaces of the disposal area to ..be graded to promote lateral runoff of precipitation and to prevent ponding." On the day of the inspection, the active face was located within a regional depression on the western portion of the landfill (see attached map). Also, areas of depression and/or subsidence were observed along the Walker Slough near Monitoring Well 2, west of the storage container -fueling area along the lower access road, and along the French Camp Slough just west of the winter pad area (see attached map). All of these locations have the potential to pond storm water. (Note: This is a repeat violation for this standard (see 11/91 State Inspection Report). Although several locations of the landfill still do not promote the lateral runoff of precipitation and represent areas for the potential ponding of water, Board staff note that the operator has made excellent progress in correcting this violation. After the 11/91 State Inspection, the City of Stockton provided Board staff with a 12/5/91 Intermediate Grading Plan which stated, "with the estimated 100 tons of greenwaste deposited per day, it should take approximately 3 years to complete this plan." During the intervening year between State Inspections, the City and contract operator have regraded and rectified grading problems over approximately 70% of the landfill.) Areas of Concern 14 CCR 17616 Report of Disposal Site Information (RDSI)- The 8/77 RDSI has been updated and amended several times (11/88, 9/89, 4/90). As noted under PRC 44014(b) above, the RDSI must be updated to reflect all current operations at the site (operating hours, tonnage, acreage, etc.) and to thoroughly and completely address each section (a -p) of 14 CCR 18222. A thorough description of the City's (Public Works Department) use of the landfill for the storage/stockpiling of asphalt and/or concrete (rip -rap) should be included in the RDSI. Also, in response to the operator's 3/92 Statement of Intent (14 CCR 18310) for the use of Performance Standards (14 CCR 17683), the LEA in 4/92 correspondence stated, "if the City of Stockton is agreeable to the conditions of this letter, operation of the French Camp Waste Management Speciali