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9 9 etc. ). The stockpiling of sludge at the site to possibly be used as a foundation layer in the final cover for closure needs to be included in the RDSI. In anticipation of a permit revision, the LEA and Board Permit staff reviewed the RDSI with regards to criteria specified in 14 CCR 18222 and provided comments (2/2/90 and 7/17/91 respectively) so that a revised or amended RDSI would completely and thoroughly address each section (a-1) of CCR 18222. Board Permit staff also recommended that the Periodic Site Review (14 CCR 17607) be rewritten to be a "stand alone" document as described in the Board's, 4/89, Permit Desk Manual. CCR 17710- Grading of Fill Surfaces Several areas of depression and subsidence were observed along the northwestern and northern slopes (just north of the current active face) of the landfill. These depressions provide areas for ponding of stormwater. (Note: An Interim Grading Plan (IGP) was submitted and approved by the RWQCB in 10/90. Phase I of the plan commenced in 12/90 with a completion date for grading of the entire landfill set for 12/91. In reviewing the 8/90 State Inspection Report and accompanying photo documentation, it is apparent that a great deal of progress has been made in addressing this problem. The site operator indicated that implementation of the IGP is on schedule and that the observed areas of depression noted in this inspection will be corrected by 12/91. ) CCR 17684- Intermediate Cover Exposed waste was observed alongside lengths of gas collection pipes located just north and northwest of the current active face. Waste was also observed in large desiccation cracks and areas of subsidence in this same general area. (Note: In reviewing the 8/90 State Inspection Report and accompanying photo documentation, it is apparent that progress has been made in addressing this problem by the implementation of the IGP. The operator indicated that problems occurring in areas of intermediate cover will be corrected by 12/91, the completion of the IGP. ) CCR 17704- Leachate Control Groundwater testing results indicate a significant degradation of groundwater quality at the landfill. Volatile organic compounds (VOCs), in concentrations above State Action Levels, have been detected (1/89) and verified (3/89, 2/91) in the first-encountered water- bearing zone of the landfill. Recent monitoring results (verification Monitoring Program and Conceptual Corrective Action Plan, EMCON, 4/91) indicate that a contaminated groundwater plume runs along the entire northern edge of the landfill (about 4,000 feet) and extends between 500 and 1,000 feet downgradient of the landfill. The 8/90 State Inspection Report documented a violation for Leachate Control in regards to groundwater testing results. This section will remain in violation of this standard until corrective measures have been implemented and the problem corrected. (Note: The Board received a Corrective Action Plan (9/3/91) for the treatment of the contaminated groundwater and staff is currently reviewing this plan. ) The 8/90 State Inspection Report also noted that . .in light of the groundwater contamination problem, we strongly urge that the disposal of condensate back into the landfill be stopped immediately." The State Inspection Report was followed by Board staff's 11/90 response to a compliance agreement, wherein staff again urged discontinuing the practice of returning condensate from the methane gas recovery system to the landfill. Staff noted that the return of liquid to the landfill might exacerbate the site's groundwater contamination problems. Staff reiterated this position again (4/10/91) in the LEA's Stockton Office at a meeting with representatives from the City of Stockton (site operator), the City's consultant (EMCON) , Pacific Energy (PE), and the RWQCB. Subsequent to this meeting, Board staff directed the LEA (5/28/91) to prohibit the disposal of landfill gas condensate at the landfill. Staff's concern regarding the further disposal of landfill gas condensate and its possible relationship to the site's groundwater problems was again discussed (7/2/91) at a meeting Board staff arranged with the RWQCB and LEA. In response to the 5/28/91 directive, Board staff received (7/2/91) a draft N&O to "cease and desist returning leachate gas condensate into the Austin Road Landfill within 90 days". on 8/19/91, Board staff received a letter from Mr. George Donlou of Pacific Energy ".. .requesting from [the) CIWMB and the Local Enforcement Agency (LEA) . . .not the ability to continue returning condensate indefinitely, but rather the time necessary to come to an agreement with the City of Stockton prior to implementing the various mitigation measures referred to above." Staff is currently developing a response to the LEA's draft N&O. During the inspection (9/19/91) it was observed that the depression where the return condensate leach line is buried had been recently covered with an additional 4 or 5 feet of dirt, possibly burying the leach line over 6 feet, in anticipation of advancing the fill over this area. This appears to be a violation of WDRs #88-208, B. Discharge Specifications 2. "return condensate shall be returned. . .via a leach line buried at least two, and not more than five, feet below the trash/soil cover interface." In addition, a condensate trap was observed to be located just outside the security fence around the power generation plant. The trap did not appear to be connected to the condensate return sypltem from the gas purification system and is apparently returning condensate to an area of tive Waste Management Specia