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DRAFT [TENTATIVE] WASTE DISCHARGE REQUIREMENTS ORDER R5-2023-OOXX 32 <br /> FORWARD, INC. <br /> FORWARD LANDFILL <br /> SAN JOAQUIN COUNTY <br /> Post-Closure Maintenance & Financial Assurances <br /> 113. The Discharger's Multi-phased CPMP is the operative document providing for <br /> post-closure maintenance of Stage IC through Stage V for the entire post-closure <br /> maintenance period of at least 30 years, and until it is demonstrated that the <br /> Facility no longer poses a threat to the public health and safety and the <br /> environment. (See Title 27, sections 20950 subdiv. (a)(1), 21180 subdiv. (a)). <br /> 114. The CPMP includes cost estimates for closure (Title 27, sections 21820, 22206), <br /> post-closure maintenance (sections 22210-22212), and foreseeable corrective <br /> action for releases (sections 22220-22222). As of the date of this Order, these <br /> estimates, calculated in accordance with Title 27, are specified in Table 9. <br /> Table 9—Current Cost Estimates (Financial Assurances) <br /> Requirement Estimated Cost <br /> Closure $ 27,854,721 <br /> Post-Closure Maintenance $ 27,310,621 <br /> Corrective Action $ 378,766 <br /> 115. This Order requires the Discharger to maintain financial assurances with <br /> CalRecycle in accordance with Title 27 sections 22221, 22225, 22226. With the <br /> addition of WMU FU-19, Forward Landfill herein will be referred to as one landfill. <br /> 116. The Discharger utilizes a surety bond (Title 27, section 22244) financial <br /> assurance mechanism. The penal sum of the bond must be in the amount at <br /> least equal to the closure and/or post closure and/or the corrective action cost <br /> estimate, except as provided in Title 27, section 22228. Therefore, there is <br /> currently no fund balance to report. <br /> 117. Title 27, section 22221 requires a cost estimate for corrective action of all known <br /> or reasonably foreseeable releases. The Discharger submitted a 2014 cost <br /> estimate of$345,574 for corrective action of all known or reasonably foreseeable <br /> releases. As of 2021, the balance of the corrective action fund was $378,766. <br /> This amount seems unrealistically low and this Order requires that the <br /> Discharger re-evaluate the corrective action cost estimate and maintain financial <br /> assurance with the CalRecycle in at least the amount of the re-evaluated cost <br /> estimate adjusted annually for inflation. See Section I, Table 11 Item 8. <br /> California Environmental Quality Act <br /> 118. In accordance with the California Environmental Quality Act (CEQA), Public <br /> Resources Code section 21000 et seq., on 14 January 2020, San Joaquin <br /> County Community Development Department certified a final Supplemental <br />