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State Inspection- French CLandfill Site Page 5 of 6 Facility No.- 39-AA-000 CO S: Violation PRC 44004 Permit, Significant Change- The 10/3/89 5-Year Permit Review reported, ..there is a significant change in the current design and operation of the solid waste facility." Significant changes include hours of operation, increased tonnage, use of Performance Standards (14 CCR 17683), installation of a scale, zoning changes on adjacent properties, the exclusion of the southeast corner of the landfill from the permitted acreage due to the extension of Downing Avenue and a PG&E gas pipeline project, the implementation of a hazardous waste screening program, and the addition of asphalt and concrete rip-rap to the types of waste received. At the time of the 5-Year Permit Review the LEA ". . .determined that the significant changes of the existing permit will require a permit revision. A CEOA Review will also be recruired.11 On 3/8/91 the LEA issued a Notice and Order (N&O) to the City of Stockton (operator) which documented a violation of PRC 44004(a) (exceeding the authorized daily tonnage of 100 tons) and ordered the operator to revise the Solid Waste Facilities Permit (SWFP) . The N&O reported that a CEQA Initial Study-was completed and the City of Stockton subsequently approved a Negative Declaration on 6/24/91. The N&O established daily peak loadings of up to 330 tpd with An approved average of 150 tpd during the permit revision process. A draft SWFP dated 10/24/91 and Report of Disposal Site Information (RDSI) dated 4/2/90 were submitted for Board staff review on 10/30/91. Board Permits Branch staff supplied the LEA with comments regarding the 10/91 draft SWFP, 4/90 RDSI, and 11/88 Periodic Site Review (PSR) on 1/13/92. Subsequently, an updated RDSI was submitted to the LEA on 2/26/93 and WDRs (92-225) were issued on 12/4/92. On the day of the inspection (4/6/93) , a revised SWFP had not been issued for this facility. Areas of Concern 14 CCR 17616 Report of Disposal Site Information (RDSI)- The 8/77 RDSI has been updated and amended several times (11/88, 9/89, 4/90, 2/93) . As noted under PRC 44004 above, the RDSI must be updated to reflect all current operations at the site (operating hours, tonnage, performance standards, acreage, etc. ) . A 1/22/93 Compliance Agreement between the operator and LEA noted that an RDSI was to be submitted to the LEA by 2/26/93. The LEA is currently evaluating the RDSI for criteria specified in 14 CCR 18222. 14 CCR 17681 Availability of Cover- With the completion of the storm water runoff retention basin (see attached map) by 6/93, cover material will not be available on-site. 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 17704 Leachate Control- on the day of the inspection, a dark-blackish liquid was observed seeping from and being absorbed back into several locations near the active face (see attached map) . During the inspection, the operator placed additional cover material over these areas. The 12/4/92 WDRs noted 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." The 3/93 Evaluation Monitoring Program noted that "leachate from well MW-1 contains VOCs thought to be introduced through refuse buried during previous site activities. Since the current waste stream is restricted to yard and inert materials, VOC impact is likely due to the previous waste stream (municipal refuse) and would be expected to decrease over time." This standard will remain as an "area of concern" until such time the RWQCB determines that compliance with Water Quality Protection Standards have been achieved. 14 CCR 17710 Grading of Fill Surfaces- On the day of the inspection, minor ponding of water was observed just east and west of the ridge (see attached map) that has been created on the western portion of the landfill as specified in the 12/91 Intermediate Grading Plan. During the inspection, equipment operators placed additional cover material in these areas. A 1/22/93 Compliance Agreement between the LEA and operator reports that "areas where ponding water occurs will be pumped out within 7 working days and when weather permits filled and graded to drain. Although several locations of the landfill do not promote the lateral runoff of precipitation and represent areas for the potential ponding of water (see attached map) , Board staff note that the operator has made excellent progress in implementing a 12/91 Waste Management Special:6p4,e1 __3K