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Mr. Mike Miller -2 - 3 September 1999 "Surface drainage from tributary areas and internal site drainage from surface or subsurface sources shall not contact or percolate through wastes,and shall either be contained on-site or be discharged in accordance with applicable storm water regulations." The current condition of the southern perimeter ditch does not appear to comply with the facility's WDRs. The City must ensure the drainage channels are properly graded and maintained to prevent violations from occurring. The plan to use sandbags and pumps to ensure drainage is permissible as backup plan,but cannot be used a primary means of compliance with the drainage requirements in the WDRs. Please note that overflow of contaminated storm water into Littlejohns Creek would be a violation of the facility's WDRs, storm water permit and the Clean Water Act. My understanding from our meeting is that access, especially during wet weather,to the south side of the landfill is limited by the poor'condition of the perimeter road. Given the concerns about the poor drainage in this area and the potential to violate WDRs,wet weather access must be ensured before this rainy season begins. Erosion of the right bank of Littlejohn Creek has locally reduced the width of the southern perimeter road. This condition* contributes to the poor access to the south side of the landfill. Continued erosion could impinge on the landfill unit itself. Discharge Prohibition A. 8 states: "The discharge of waste within 50 feet of surface waters not relatedto landfill drainage structures is prohibited." The City must ensure proper measures are taken to remedy this erosion problem. A low area exists long the south central portion of the landfill's top deck. This area has the potential to pond water during storm events. This area should be brought up to grade and covered prior to the rainy season. The adequacy of interim cover soil on the landfill is a long standing concern. My letter of 2 November 1998 expressed this concern and cited the performance requirements in Title 27 for interim_ cover. The �r one foot of soil as placed on the City's landfill to meet minimum prescriptive standard for interim cover) may not be sufficient to meet the performance requirements of Title 27. The wet weather operations plan should discuss the adequacy of the interim soil cover. The wet weather operations plan should be submitted to us by 27 September 1999. The plan should clearly explain how the City will achieve and maintain compliance with its WDRs throughout the rainy season.If you have any questions,please call me at(9167.255-3131. STEVE E.ROSENBZ - Associate Engineering Geologist Enclosures(2) cc: Mr. Jeff Hackett, California Integrated Waste Management Board, Sacramento Ms.Frances McChesney, Office of Chief Counsel, State Water Resources Control Board, Sacramento SFR Austin iosp 9.1.99