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State Inspection- French Ca Landfill Site Page 6 of 6 Facility No.- 39-AA-0002 Landfill under performance standards may begin on May 4, 1992.11 A complete description of the use of Performance Standards should be included in an updated RDSI. 14 CCR 17681 Availability of Cover- Cover material is not available on-site. On the day of the inspection, the site operator reported that only 2 - 3 days of cover was stockpiled on site (see attached map) . This standard requires that "if on-site sources of cover material are insufficient, substantiation must be shown to the Enforcement Agency that an adequate supply of cover material will be provided." 14 CCR 17684 Intermediate Cover- On the day of the inspection, waste was observed to be "daylighting" in several areas of intermediate cover. These areas of "thinning" intermediate cover were located both north north-west and south of the active face (see attached map) and apparently were the result of the removal of previously stockpiled cover from these areas. 14 CCR 17696 Operating Site Maintenance- The casing surrounding Monitoring Well 2 located along the French Camp Slough was loose. This apparently happened during grading activities on the north slopes of the landfill. The significance of the loose casing to the integrity of the well's sanitary seal was not determined during the inspection. 14 CCR 17704 Leachate Control- The Corrective Action Program of the 11/13/92 Tentative WDRs reported, "Monitoring well MW-1 has VOC contamination. As of 29 June 1990, ground water from this well contained benzene, ethylbenzene, chlorobenzene, dichlorobenzene, toluene and xylene. A Verification Monitoring Report prepared by the Discharger indicates that downgradient wells have not been affected. The Discharger has been requested to initiate evaluation monitoring and propose corrective actions pursuant to Article 5, Chapter 15. The Corrective Action Program shall include, but not be limited to, any evaluation monitoring, investigation, data collection, data analysis or other tasks necessary to monitor the effectiveness of corrective actions or to begin any ground water cleanup needed to achieve compliance with the Water Quality Protection Standard." This standard will remain as an "area of concern" until such time the RWQCB determines that "compliance with the Water Quality Protection Standard" has been achieved. 14 CCR 17709 Contact with Water- In the Description of the Site, section #11, of the 11/13/92 Tentative WDRs, it is reported that "refuse is in contact with ground water in a localized area in the vicinity of well MW-1 and is the suspected source of VOCs in ground water from this well. VOCs have not been detected in water from the three downgradient monitoring wells. An evaluation monitoring program pursuant to Article 5, Chapter 15 will be required as specified in this Order." The Information Sheet attached to the Tentative WDRs notes that "Refuse was encountered in Boring MW-1 to a depth of 37 feet, which is approximately 4 feet below first encountered ground water. It is suspected that this portion of the southern portion of the landfill may have been the original course of the French Camp Slough which was filled with refuse during the early development of the landfill." Since the placement of this waste pre-dates the implementation of this standard, this will remain as an "area of concern" until "an evaluation monitoring program pursuant to Article 5, Chapter 15" is initiated "to investigate this matter and implement appropriate remedial action." 14 CCR 17777 Final Site Face- This standard requires that the slope of those portions of the fill which will be the final exterior surface shall not be steeper than approximately 300. Using a clinometer, slopes of greater than 300 were found along both the French Camp and Walker sloughs (see attached map) . In 9/28/92 correspondence to the operator, Board staff noted that "due to the age of the landfill and the lack of available information regarding the stability and placement of the fill, a slope stability study is required to be conducted. The timing of the execution of the slope stability study should precede the design of the perimeter road/drainage system." Waste Management Speciali