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PUBLtiHEALTH SEFZEICES SAN JOAQUIN COUNTY JOGI KHANNA MR, Nf.P 1-1. Health Officer P.O. Box 2009 0 (1601 East Hazelton Avenue) * Stockton, Califomia 95201 (209) 468-3400 October 30, 1992 C Brad Wiliams Permitting and Compliance Division California Integrated Waste Management Board - 8800 Cal Center Drive Sacramento CA 95826 Subject: Letter of September 28, 1992 from Robert Anderson CIWMB to Steph Chen regarding the City of Stockton French Camp Landfill i On September 18, 1992 California Integrated Waste Management Board (Board) Staff visited the French Camp Landfill. The Board staff whom were present were Brad Williams and Robert Anderson. Also present during this visit was Steve Sasson from San Joaquin County Environmental Division, Phil Nisperos from the City of Stockton and Phil Giambastiani and Rick Vitas from Gambii Enterprises. The Environmental Health Division (EHD) feels that Mr. Anderson did not follow proper protocol when evaluating the French Camp Landfill for a number of reasons. 1) EHD feels that the concerns addressed by Mr. Anderson would more appropriately belong on a CIWMB inspection report from you (Brad Williams). 2) All communication from CIWMB should be directed to the certified LEA for the County of San Joaquin which is EHD. 3) When Mr. Anderson's visit to the site was scheduled it was for training purposes and this was not to be an official inspection by the Board staff. Regarding the four areas which concern Mr. Anderson: 1) EHD is aware that the side slopes of the landfill are too steep. EHD will require the city to provide as slope stability study at closure or when and if the road proposal is ever implemented. 2) CCR Section 17705 states that the Enforcement Agency must have cause to believe a hazard or nuisance may be created by landfill decomposition gases prior to monitoring the site for the presence and movement of such gases. Mr. Anderson fails to demonstrate that there is gas present. EHD also feels that Mr. Anderson has confused regulations for Closure/Post Closure with regulations for currently'operating landfills. 3) There is no monitoring well no. 8 that EHD or the City of Stockton is aware of at this time. However monitor well #2 has some damage which needs to be repaired. A Division of San Joaquin County Health Care Service,;