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STATE OF CALIFORNIA GEORGE DEUKMEJIAN, Governor <br />CALIFORNIA REGIONAL WATER QUALITY CO , 4 Bk At ' <br />CENTRAL VALLEY REGION,r, <br />3443 ROUTIER ROAD <br />SACRAMENTO, CA 95827-3098 FEB 2 6 1 <br />NViER(AM-EN TAL H M-1 <br />Mr. Greg Basso P ERMIT/ S ERVii ,- 23 February 1990 <br />Forward Inc. <br />P. O. Box 6336 <br />Stockton, CA 95206 <br />We have reviewed the construction report for the expansion of waste management unit <br />(WMU) D, referred to as WMU D89. The construction of this Class III landfill WMU is <br />regulated by Waste Discharge Requirements (WDRs) Order No. 89-148 and Subchapter <br />15, Title 23, California Code of Regulations. The required construction certification was <br />provided by Mr. Duane Butler of EBA. <br />Based on the construction report submitted by EBA, including supplemental data from <br />Kleinfelder, and staff inspections on 2 November 1989 and 15 December 1989, WMU <br />D89 meets or exceeds the minimum requirements established in the WDRs and Subchapter <br />15 for Class III landfills. Therefore, we approve the completed portion of WMU D89 for <br />waste discharge. <br />We have also reviewed the 31 January 1990 proposal submitted by EBA to increase the <br />designated levels in WMU D89 above those currently set in the WDRs. Although we <br />believe this proposal has merit, several deficiencies in the proposal need to be addressed <br />before higher designated levels can be approved. One deficiency is the lack of mass <br />balance (e.g. HELP model) calculations for the active landfill WMU during periods of high <br />rainfall such as a 100 -year wet season. It is our opinion that wet weather operations at <br />landfills are a significant factor in leachate generation. The proposal also fails to discuss <br />whether the proposed designated levels, i.e. STLC and TTLC, are for organic or inorganic <br />compounds. Finally, the proposal makes implicit assumptions about fluid migration <br />through unsaturated soils to derive a travel time estimate for leachate to reach ground water. <br />These assumptions do not reflect the heterogeneous nature of the unsaturated zone beneath <br />the facility and lead to an invalid estimate of the travel time. Therefore, we request that the <br />designated level proposal be revised before we reconsider this issue. <br />If you have any questions on this subject, please call Steve Rosenbaum at (916) 361-5732. <br />WILLIAM . MARSHALL, Chief <br />Waste Discharge to Land Unit <br />M <br />cc: Ms. Pam Johnson, Department of Health Services, Sacramento <br />Mr. Jesse Adams, California Integrated Waste Management Board, Sacramento <br />Ms. Kim Schawb, California Integrated Waste Management Board, Sacramento <br />. Alan Biederman, San Joaquin County Public Health Services, Stockton <br />Mr. Ed Padilla, San Joaquin County Public Health Services, Stockton <br />Mr. Duane Butler, EBA, Santa Rosa <br />Ms. Carolyn Richardson, California Farm Bureau Federation, Sacramento <br />