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Califotia Regional Wate ri Quality Control oar <br /> Central Valley Regi®n <br /> Winston H.Aickox I Robert Schneider,Chair <br /> Secretaryrr Gray�-- <br /> GDavis <br /> o <br /> Sacramento Main Office Governor <br /> Environmental Internet Address: http:[/www.swrcb.ca.gov/rwgcb5 <br /> Protection 3443 Routier Road,Suite A,Sacramento,California 958274003 <br /> Phone(916)255-3000+FAX(916)255-3015 <br /> 10 October 2001 <br /> Mr. Kevin Basso <br /> General Manager <br /> Forward Inc. <br /> 1145 West Charger Way <br /> Stockton, CA 952061 <br /> I <br /> RESPONSE TO FINAL DRAFT JOINT TECHNICAL DOCUMENT, FORWARD LANDFILL, <br /> SAN JOAQUIN COUNTY' <br /> We have reviewed the Final Draft Joint Technical Document, submitted on 17 September 2001 in <br /> support of your application to combine the Forward and Austin Road Landfills under a single Waste <br /> Discharge Requirements (WDR.$). The document reviews long range development of the combined <br /> landfill and provides Ithe information necessary to revise the WDRs. <br /> Staff has the following comments: <br /> 1. A Liner Performance Appraisal is required for any new Waste Management Units (Vv7� <br /> constructed in the Central Valley Region, A general liner performance appraisal that considers <br /> conditions at the Forward/Austin Road site should be submitted as an addendum to the JTD. <br /> This wi11 allow staff to write general liner requirements for the entire site. <br /> 2. Plans for the Interim Final Cover to be installed on the existing unlined Austin Road WMU calls <br /> for, from bottom to top: a 24 inch foundation layer, a 12 inch low permeability soil layer with a <br /> permeability of less than 10" cm/sec, a 12 inch protective soil layer and a drainage layer. Waste <br /> will be placed over the drainage layer. The Interim Final Cover should comply with the <br /> requirements for a final landfill cover in Title 27 Section 21090 which calls for a 12 inch thick <br /> Low Conductivity Layer with a hydraulic conductivity of 10-6. The JTD should be revised to <br /> comply with this'requirement. <br /> 3. In previous correspondence, dated 8 March 2000, and 29 November 2000, the Regional Board <br /> asked for plans with time schedule to close the existing unlined landfill footprint and install a <br /> cover. Closure with a cover of the unlined footprint is an important element in Corrective <br /> Actions to cleanup contaminant groundwater at Austin Road. The JTD with the changes noted <br /> complies with our request for a plan but fails to address the time schedule. Title 27 Section -•.r <br /> 22190 states that if the RWQCB finds that early closure of a waste management unit isnecessary <br /> to prevent (or curtail) violation of waste discharge�requirements(e.g., as a source control <br /> measure in corrective action,) it shall adopt a Cease and Desist Order,which requires closure. At <br /> this time, Staff believes a Cease and Desist Order is unnecessary but the Austin Road WMU <br /> California Environment Protection Agency <br /> 0 Recycled Paper <br /> Tne energy challengip facing California is real. Every Californian needs to take irrImediate action to reduce eneconmp <br /> sution <br /> For a list of simple 4Ys you can reduce demand and cut your energy costs,see our Web-9ite rgy at http:r/www.swrcb.ca.¢ov!rwoch5 <br /> Z 'cl OOZE 131783Sd1 dH 00 :8T 2002 ST wur <br />