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*eq% Californi egional Water Quality Co of Board <br />Central Valley Region <br />Robert Schneider, Chair <br />Linda S. Adams <br />Secretaryfor Sacramento Main Office <br />Environmental 1 1020 Sun Center Drive #200, Rancho Cordova, California 95670-6114 <br />Protection Phone (916) 464-3291 • FAX (916) 464-4645 <br />http://www.waterboards.ca.gov/centralvalley <br />7 August 2006 R' OVEDD <br />Andrew Keller ENVIRONMENT HEALTH <br />Hugo Neu-Proler Company PEWIT/SERVICES <br />901 New Dock Street <br />Terminal Island, California 90731 <br />1� <br />COMMENTS ON 31 MAY 2006 LETTER FOR SUBMISSION OF SLOPE STABILITY <br />ANALYSIS FOR COVE CONTRACTORS LANDFILL, SAN JOAQUIN COUNTY <br />Arnold <br />Schwarzenegger <br />Governor <br />The Regional Water Quality Control Board (Regional Water Board) staff has reviewed the 31 <br />May 2006 letter prepared by Clayton Group Services, Inc. regarding their proposed schedule <br />and submittal process for the slope stability analysis. The letter proposed that the slope <br />stability analysis would be prepared during construction of the cover and would not be <br />submitted to the Regional Water Board for concurrence. <br />At this time, the Regional Water Board does not concur with Cove Contractors' proposed <br />schedule and method of submission of their slope stability analysis. Our review comments, <br />provided below, are based on a comparison of Cleanup and Abatement Order (CAO) No. R5- <br />2006-0707 to the 31 May 2006 letter: <br />Item No. 3 of the CAO requires that the "stability analysis shall be in accordance <br />with Title 27 Section 21090(a)(6)." In turn, Section 21090(a)(6) requires that "the <br />discharger shall meet the requirements of Section 21750(0(5)" for preparing the <br />slope stability analysis. For your convenience, these sections of Title 27 are <br />enclosed as Attachment A. In addition, Title 27 is available online at <br />www.ciwmb.ca.gov/Regulations/Title27. Please include all of the required technical <br />components of Section 21750(f)(5)—(f)(5)(D) into the analysis. You may use the <br />Maximum Probable Earthquake (MPE) for the maximum expected horizontal <br />acceleration in rock at the site. <br />2. Item No. 12 of the CAO states that "work shall be conducted only after submitted <br />documents have received concurrence or conditional concurrence" by the Regional <br />Water Board. Please'submit the slope stability analysis for review and concurrence <br />prior to initiating construction work. <br />Please prepare a slope stability analysis based on the above comments and the requirements <br />in the CAO. Please resubmit the analysis to the Regional Water Board by 6 September 2006. <br />California Environmental Protection Agency <br />Ca Recycled Paper <br />