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WASTE DISCHARGE REQUIREMENTS ORDER NO. R5-2014-0006 -24- FORWARD INC.AND REPUBLIC SERVICES INC. FORWARD CLASS II LANDFILL SAN JOAQUIN COUNTY 0 Title 27, section 21090(a)(4)(A). Defects will be repaired and tested for adequacy based on the closure CQA Plan. FINANCIAL ASSURANCES 105. Title 27, sections 21820 and 22206 require a cost estimate for landfill closure. The cost estimate must be equal to the cost of closing the landfill at the point in its active life when the extent and manner of operation would make closure the most expensive. When closing units in phases, the estimate may account for closing only the maximum area or unit of a landfill open at any time. The Discharger's 2008 revised Preliminary Closure and Post Closure Maintenance Plan includes a cost estimate for landfill closure. The lump sum estimate is for the cost to close largest future area needing closure at any one time. The total amount of the closure cost estimate in 2008 dollars is $12,571,034. This Order requires that the Discharger maintain financial assurance with the California Department of Resources Recycling and Recovery (CalRecycle) in at least the amount of the closure cost estimate. As of 2012, the balance of the closure fund was $13,407,553. 106. Title 27, sections 21840 and 22211 requires a cost estimate for landfill post-closure maintenance. The Discharger's December 2008 revised Preliminary Closure and Post Closure Maintenance Plan includes a cost estimate for landfill post-closure maintenance. The amount of the cost estimate for post-closure maintenance in 2008 dollars is $12,740,328. This Order requires that the Discharger maintain financial assurance with CalRecycle in at least the amount of the post-closure maintenance cost estimate adjusted annually for inflation. As of 2012, the balance of the post-closure maintenance fund was $13,588,125. 107. Title 27, section 22221 requires a cost estimate for corrective action of all known or reasonably foreseeable releases. The Discharger submitted a 1992 cost estimate of $143,473 for corrective action of all known or reasonably foreseeable releases. As of 2012, the balance of the corrective action fund was $187,046. This amount seems unrealistically low and this Order requires that the Discharger re-evaluate the corrective action cost estimate and maintain financial assurance with the CalRecycle in at least the amount of the re-evaluated cost estimate adjusted annually for inflation. CEQA AND OTHER CONSIDERATIONS 108. On 24 September 2013, the San Joaquin County Planning Commission certified the Final Environmental Impact Report (EIR) (SCH#2008052024) for the Forward Landfill Expansion Project, which included analysis of (a) the discharge of cannery waste by land application and the discharge of cannery rinseate at the compost facility; and (b) revised base grades east of WMU FU-06. Because the landfill expansion project is inconsistent with the County Airport Land Use Plan and the San Joaquin County Board of Supervisors did not override that land use plan, the landfill expansion project was not approved and therefore a Notice of Determination for CEQA was not filed. The discharge of cannery waste at Forward Landfill and revision of the base grades east of FU-06 do not require additional discretionary permits