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,:.;:, ✓ <br /> ;. EDMUND G. BROWN JF. <br /> GOVERNOR <br /> CA LIFO pNIA MATTHEW RODRIQUEZ <br /> Water <br /> ars SECRETARY FOR <br /> ENVIRONMENTAL PROTECTION <br /> etral Valley Regional Water Quality Control Board <br /> R;:cE.IVED <br /> 5 May 2017 fimal <br /> Taj M. Bahadori, P.E. 2017 <br /> San Joaquin County Department of Public Works -"RON,VEN'1AL <br /> P.O. Box 1810 PC-RM1T/JCR0�ES <br /> Stockton, California 95201 <br /> REVISED PARTIAL FINAL CLOSURE AND POSTCLOSURE MAINTENANCE PLAN, <br /> WASTE DISCHARGE REQUIREMENTS ORDER R5-2015-0058, FOOTHILL LANDFILL, SAN <br /> JOAQUIN COUNTY <br /> Central Valley Water Board permitting staff reviewed the February 2017 Revised Partial Final <br /> Closure and Postclosure Maintenance Plan (Partial FC/PCMP) for the Foothill Landfill (15 <br /> October 2016 Final Closure and Postclosure Maintenance Plan, Landfill 1, Foothill Sanitary <br /> Landfilo, prepared by CB&I Environmental, Inc. The report was submitted in response to <br /> Provision H.9.b of Waste Discharge Requirements (WDRs) Order R5-2015-0058, which <br /> requires that the Discharger submit a Partial FC/PCMP for all portions of Landfill 1 that have not <br /> yet been closed. Based on our review of the report, the report appears to be incomplete. <br /> The facility includes two landfill units referred to as Landfill 1 (LF 1) and Landfill 2 (LF-2). LF-1 <br /> is an 85-acre, unlined unit in the central portion of the site. The top deck of LF-1 was partially <br /> closed with an evapotranspirative (ET) cover meeting Title 27 performance standards in 2006 <br /> after a.multi-year pilot demonstration approved by Water Board staff. LF-2 is a lined, expansion <br /> landfill being constructed one module at a time around (and partially overlapping) LF-1. The <br /> Partial FC/PCMP provides a technical demonstration that the existing soil cover on the exterior <br /> side slopes of LF-1 functions as an ET cover meeting or exceeding Title 27 standards for final <br /> cover. The technical demonstration included an evaluation of the side slope soil cover <br /> characteristics, comparison with the top deck soil data and pilot results, water balance modelling <br /> and other information. Based on this evaluation, the Partial FC/PCPM proposes no additional <br /> final cover installation at LF-1 other than minor repairs. <br /> Our comments on the Partial FC/PCMP are as follows: <br /> 1. The technical demonstration of existing LF-1 side slope cover as ET final cover appears to <br /> be adequate per WDR Construction Specification D.5.b.2; however, it is not clear what the <br /> closure plan will be for areas overlapped by LF-2 as it is developed around LF-1. Also, as <br /> noted in the report and the WDRs, the lower portion of LF-1 is already overlapped by LF-2. <br /> 2. A final cover design for all LF-1/1-F-2 overlap areas also needs to be proposed consistent <br /> with Construction Specifications D.1 and D.5 (e.g., liner-cover combination system). See <br /> Closure and Postclosure Specification E.1. <br /> 3. Based on its title, the report appears to have been submitted as a FC/PCMP not a Partial <br /> FC/PCMP. Given that the top deck of LF-1 has already been closed, the scope of the report <br /> should address only the areas that have not yet been closed. The certification page in the <br /> KARL E. LONGLEY SCD, P.E., CHAIR I PAMELA C. CREEDON P.E., BCEE, EXECUTIVE OFFICER <br /> 11020 Sun Center Drive#200,Rancho Cordova,CA 95670 1 www.waterboards.ca.gov/centralvalley <br /> Z�'RECYCLED PAPER <br />