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STATE OF CALJFOANIA'- ENVIRONME14TAL PAOTh., i 10N AMMY PM <br />CALIFORNIA REGIONAL WATER QUALITY CONTROL .O•r <br />VALLEY REGION <br />3443 ROUTIER ROAD. SUfTE A <br />SACRAMENTO. CA OM7-3098 <br />PHONE: (916) 25&3000 <br />FAX- (916)255-3015 <br />Cove Contractors <br />2711 Navy Drive <br />Stockton CA 95206 <br />RXVZRW OF CLrRB AND POST-CLOSURX XAXNTZKANCZ PLAN FOZ4 <br />COvZ CONTRACTORS LANDFXLL.- San Joaquln County (Case <br />2797) <br />We have reviewed the Closure and Post -Closure Mainterance Plan M <br />(CPCMP or Plan) submitted on your behalf by Kleinfelder, Inc. <br />Plan proposes: (1) to close your auto shredder waste landfill <br />using a flexible geosynthetic cover instead of a clay cap, (2) tio <br />divert storm water runoff into the topographically lowest portion <br />of the landfill area after the closure is complete, and (3) to <br />institute a Detection Monitoring Program for water quality, to be <br />continued for five years during the post -closure monitoring and <br />maintenance period. Appendix B of the Plan includes a proposed <br />water quality Sampling and Analysis Plan. In addition, the plan <br />discusses potential slope stability concerns in the northern cut <br />slope area. Detailed comments on the CPCMP are offered in the <br />attached memo. We will review the Sampling and Analysis Plan (S <br />separately and will prepare a Monitoring and Reporting Program f <br />submittal to the Regional Board. . In coordination with the -San <br />Joaquin County Local Enforcement Agency, we may, also, in the <br />future write Waste Discharge Requirements for closure of this <br />landfill. <br />The proposals to use geosynthetic membrane in the final cover and <br />to collect stormwater in the lowest portion of the closed landfill <br />(probably involving ponding of water over wastes) are both <br />engineered alternatives to the prescriptive requirements of <br />California Code of Regulations Title 23, Chapter 15, which <br />regulates discharges of wastes to land. Detailed design and <br />engineering/geotechnical analyses are needed to support the <br />proposals. our principal concerns are stability of the steep <br />slopes, especially if wetted by infiltration or leakage of <br />impounded waters, and stability of a flexible geosynthetic <br />