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CaliforniaRegional Quality ControlBoard <br />�✓ , <br />Alan C. Lloyd Ph.D. <br />Agency Secretary <br />2 December 2005 <br />Sacramento Main Office <br />Internet Address: http://www.waterboards.ca.gov/centalvalley/ <br />11020 Sun Center Drive, #200, Rancho Cordova, CA 95670.6114 <br />Phone (916) 464-3291 • FAX (916) 4644780 <br />Andrew Keller <br />Hugo Neu-Proler Company <br />P.O. Box 3100 <br />901 Dock Street <br />Terminal Island, California 90731 <br />Arnold Schwarzenegger <br />Governor <br />11' <br />ENVIRONMENT HEALTH <br />PEWJIIT/SERVICES <br />COVE CONTRACTORS FACILITY, LANDFILL CLOSUREAND POST CLOSURE <br />MAINTENANCE PLANAND GROUNDWATER INVESTIGATION WORKPLAN, 3242 SOUTH <br />EL DORADO STREET, STOCKTON, SAN JOAQUIN COUNTY <br />Staff has reviewed the Landfill Closure and Post -Closure Maintenance Plan (Plan) and the Groundwater <br />Investigation Workplan for the Cove Contractors Facility (Facility) prepared by Clayton Group Services. <br />The technical reports were submitted in response to the Executive Officer's Request for Technical <br />Reports pursuant to California Water Code Section 13267, dated 26 September 2005. <br />Staff reviewed these reports and presents the following comments: <br />1. Clayton Group Services has proposed an alternative "store and release" cover design. The <br />proposed design does not demonstrate that this alternative meets the performance standard (e.g. <br />minimization of water infiltration through waste) of Title 27, California Code of Regulation, <br />Division 2 (Title 27) Sections 20950 (a)(2)(A). Plan narrative suggest that the "store and <br />release" design is comparable to an evapotranspiration (ET) cover. ET cover systems rely on <br />properties of soil to store water until it is either removed through evapotranspiration or through <br />vegetative uptake. We urge the Clayton Group Services to use reports such as Interstate <br />Technology Regulatory Council (ITRC) entitled, Technical and Regulatory Guidance for Design, <br />Installation, and Monitoring of Alternative Final Landfill Covers, December 2003, in making <br />sure all data needs for this type of alternative design are met. We support many of the positive <br />aspects of an ET cover over the prescriptive standard in Title 27. However, without a properly <br />designed cover we may have to reject a proposed cover based on inadequate data. <br />2. Sacramento climate data was cited. Climate data from the Stockton area should be used. <br />3. A test pad will need to be constructed and monitored to assess whether the alternative design <br />meets the performance standard. <br />California Environmental Protection Agency <br />cry Recycled Paper <br />