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Ron Valinoti, Director <br /> Page 3 of 5 <br /> The RDSI of November 1988 and an amendment to the RDSI dated <br /> March 1990, state that the Austin Road Landfill will accept 5,000 <br /> cubic yards per year of non-hazardous sewage sludge from the <br /> Stockton Wastewater Treatment Plant. It is further stated that <br /> this sludge, which has been dried to more than 50% solids, will <br /> be placed in the foundation layer of the final cover. <br /> The WDR Order No. 90-122, Section 15, states that 20,000 cubic <br /> yards of digested sewage sludge has been accepted on a one time <br /> basis and that an additional 5,000 cubic yards of this sludge <br /> will be accepted annually. It is further noted that the sludge <br /> is being stockpiled at the landfill and that this sludge may be <br /> used in the foundation layer of the final cover . Under part B, <br /> Discharge Specifications, Section 15 states that sludge which is <br /> incorporated into the foundation layer shall be tested to <br /> determine if it has appropriate engineering properties to support <br /> the overlying clay liner, soil cover, and other potential loads. <br /> The Monitoring and Reporting Program Order No. 90-122 requires <br /> the discharger to submit a report to the RWQCB on a quarterly <br /> basis detailing the monitoring results and the suitability of the <br /> sludge for use in the foundation layer . <br /> Unlined storage of sludge, even at >50% solids, creates the <br /> possibility of further degradation of groundwater . To be in <br /> compliance with 23 CCR 2523(c)- Nonhazardous Solid Waste, <br /> dewatered sewage or water treatment sludge may be discharged at a <br /> Class III landfill if the landfill is equipped with a Leachate <br /> Collection and Removal System (LCRS) . Furthermore, sludge is a <br /> putrescible waste and as such must be disposed of properly. <br /> Proper disposal means being covered and meeting adequate drainage <br /> and erosion control measures. The State Inspector did not <br /> observe the storage of sludge occurring in an impoundment area <br /> with containment structures capable of preventing degradation of <br /> waters of the state. <br /> In light of groundwater contamination at Austin Road Landfill, <br /> Board staff urge that the acceptance and storage of sludge be <br /> stopped until a LCRS is installed and the SWFP is revised to <br /> address this practice. Staff also recommend that the discharger <br /> be requested to conduct a study to determine the long term, net <br /> impact on water quality resulting from the storage of sludge on <br /> site. This study should address the introduction of liquids <br /> which may further increase leachate production leading to further <br /> degradation of groundwater quality. <br /> 14 CCR 17710- Grading of Fill Surfaces <br /> This violation was addressed in the inspection reports (9/19/90 & <br /> 10/26/90) from Mr . Wickes, LEA. The response is acceptable. <br />