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PUBLtC ALSE VICESPQ,o... ..�o <br /> ... <br /> SAN JOAQUIN(A)tINTY z <br /> Q: <br /> UX r :< <br /> JOU KHANNA M.O..M.P H. <br /> Health Officer <br /> P.O. Box 2009• (1601 East Hazelton Avenue) • Stockton, California 95201 <br /> (209)468-3400 <br /> Mr. Robert Evans September 3, 1992 <br /> California Regional Water Quality Control Board <br /> Central Valley Region <br /> 3443 Routier Road <br /> Sacramento, CA 95814 <br /> San Joaquin County Public Health Services, Environmental Health Division (E.H.D.) has reviewed the Long <br /> Term Surface Runoff and Leachate Disposal Plan for the North County Recycling Center and Sanitary Landfill <br /> dated August 11, 1992. E.H.D has the following questions/comments regarding the aforementioned plan: <br /> 1. A letter of April 23, 1992 to Tom Horton from Robert Evans states that " All stormwater runoff that <br /> is inside the landfill should be managed as leachate". This is reiterated in a letter of July 22, 1992 to <br /> Mr. Gabriel Karam from William J. Marshall. The Long Term Surface Runoff and Leachate Disposal <br /> Plan states that surface runoff that ponds outside the berm and has not contacted waste will be used for <br /> dust control wherever needed. This implies that surface runoff in the module outside the bermed area <br /> will not be treated as leachate. Is this acceptable? <br /> 2. A letter of April 17, 1992 to Mr. Tom Horton from William J. Marshall states that "Discharge of <br /> leachate back to the Class II landfill would be a violation of Prohibition A.2 of Regional Board Order <br /> No. 91-021, which prohibits the discharge of liquid or semi-solid waste to the landfill units." Based <br /> on Prohibition A.2, the Interim Leachate Diposal Plan dated January 31, 1992 was rejected. Then, in <br /> a letter of June 12, 1992 to Tom Horton from William J. Marshall, the Interim Leachate Disposal Plan <br /> was approved, allowing for the return of leachate and pounded surface water to the landfill module. <br /> What was the rationale behind this "about face" and why is the return of leachate to the landfill no <br /> longer a violation of Regional Board Order #91-021? <br /> 3. The County proposes to use an "Eliminator 1000" water filtration system to filter leachate during <br /> periods of wet weather. What is the sampling protocol for the post filter discharge? How frequently <br /> will the material be sampled and for what constituents will it be sampled? How often will the carbon <br /> filter be replaced? <br /> Thank you for the opportunity to comment on this plan. Should you have any questions, please contact Jerry <br /> Wickes at (209) 468-3459. <br /> Jim Miller, Supervisor <br /> Environmental Health Division <br /> JM/JW:lc <br /> cc: Brad Williams, CIWMB <br /> .A Division of San Joaquin County Health Care Senices <br />