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California Refonal Water Quality Central Valley Region Robert Schneider, Chair Terry Tamminen Secretary for Environmental Protection 28 September 2004 W. Michael Carroll, P.E. County of San Joaquin Department of Public Works P.O. Box 1810 Stockton, CA 95201 Antrol Board a Sacramento Main Office Internet Address: http://www.swreb.ca.gov/rwgcb5 11020 Sun Center Drive #200 Rancho Cordova, CA 95670-6114 Phone (916) 464-3291 1 Owarzenegger Governor SEP 2 9 2004 ENViR0,`,JYv,!E i' ` HEALTH PERMIT/SERVICES munrum f . rQ 'l JJII The subject Report was submitted in compliance with Cleanup and Abatement Order (CAO) No. R5-2004-0706. The CAO required the following: "By 31 August 2004, the Discharger shall submit a Project Design Report, which shall contain, but not be limited to, a general description of the proposal to eliminate the release of LFG from Module "I" (the "Project"), the details of the proposed barrier between Module "I" (unlined) and Module 1 (new expansion) refuse, the conceptual LFG collection system for Module "I," additional groundwater monitoring wells, and intermediate cover for the side slopes for all modules in compliance with WDRs and the minimum standards set forth in Title 27 CCR." The report was prepared and signed by the County of San Joaquin Public Works, Kleinfelder, Inc., Lewis Engineering and GC Environmental. Based on our review, we have a few areas of concern that require clarification as follows: On page 3 it states, "The low permeability and leachate drainage layers will direct leachate migration from Module 1 into Module I. It is not appropriate to allow leachate from Module 1, the lined site, to flow to Module I, the old unlined site. The purpose of lining/capping the old refuse is to preclude leachate from migrating to the unlined Module I. Please clarify this statement and submit a replacement page 3. 2. Additional Monitoring Well Installation, page 26: We find that the well locations are acceptable. We understand the rationale for wanting to put monitoring wells around the property boundary out of the planned footprint of future modules. Nevertheless, future modules will need monitoring wells adjacent to the footprint in order to capture the earliest possible impacts to groundwater and the vadose zone. MW -2R currently sits downgradient of Module 1. Based upon results of MW -4, the new upgradient well, additional wells may be needed to monitor groundwater along the southeastern edge of the Modules in the Unit and other modules as they are expanded. 3. Addition of Soils to the Existing Soil Cover, page 29-30: As discussed in the field on 14 September 2004, the Board would like a final inspection/verification report showing that the appropriate areas have received the minimum soil thickness and relative compaction required. Include all field test data and maps signed and stamped by the professional engineer or engineering California Environmental Protection Agency