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11 <br />It appears that under §18251(a)(8)(C), Cove Contractors Landfill would not be subject to the <br />provisions of Article 3.4 if the landfill received an "unclassified" designation from the <br />RWQCB. <br />A second set of regulations dealing with closure requirements is Article 7.8 of Chapter 3, <br />Division 7, Title 14, CCR titled "Disposal Site Standards Closure and Postclosure". The <br />regulations in this Article apply to "Solid Waste Disposal Sites". There is no definition of a <br />"Solid Waste Disposal Site" in Article 7.8. Article 4 contains definitions that apply to Chapter <br />3 which includes Article 7.8 but Article 4 does not define "Solid Waste Disposal Site". It does <br />reference Division 30 of the Public Resources Code (PRC) for additional definitions. Chapter <br />2 of Division 30 contains definitions that apply to the division. Chapter 2 does not have a <br />definition of "Solid Waste Disposal Site" but does define "Disposal Site" in §40122. This <br />section reads: <br />"Disposal site" or "site " includes the place, location, tract of land, area, or premises in <br />use, intended to be used or which has been used for the landfill disposal of solid wastes. <br />"Disposal site" includes solid waste landfill, as defined in Section 46027. <br />Section 46027 reads: <br />"Solid waste landfill" means a disposal facility that accepts solid waste and which meets <br />the requirements of a Class III landfall pursuant to Sections 2533 and 2541 of Title 23 of <br />the California Code of Regulations... <br />If the Cove Contractors Landfill is given an "unclassified" designation rather than a "Class III" <br />designation, would that mean that the landfill would not be a "solid waste landfill" under <br />§46027 and therefore also not a "disposal site" under §40122? If Cove Contractors Landfill is <br />not defined as a "disposal site", would the provisions of Article 7.8 not apply because they are <br />meant to apply to "solid waste disposal sites"? <br />We would appreciate a response from you at your earliest convenience. Please call if you <br />have any questions or require additional information. <br />Sincerely, <br />I : 1►I � 1 ;t 1► <br />B• <br />Timothy Crandall, P.E. <br />Project Engineer <br />, <br />Mr. Steve Sphar, CIWMB <br />Mr. Jack Hecht, Cove Contractors <br />Mr. David Sadwick, Cadwalader, Wickersham & Taft <br />24-215600 F02/CLI-248 (1993) <br />Copyright 1993 Kleinfelder, Inc. <br />Page 2 of 2 <br />KLEINFELDER 3077 Fite Circle, Sacramento, CA 95827 (916) 366-1701 <br />September 23, 1993 <br />