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t California R$ional Water Quality Central Valley Region 0 Robert Schneider,Chair Winston H.Hickoa Gray Davis Secretaryfor Sacramento Main®Rice - Governor Environmental _ Internet Address: http://www.swrcb.ca.gov/rwgcb5 Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 Phone(916)255-3000•FAX(916)255-3015 19 November 2001 Mr. Devin Basso General Manager Forward Inc. 1145 West Charger Way Stockton, CA 95206 RESPONSE TO FINAL CLOSURE PLAN,FRENCH CAMP LANDFILL, SAN JOAQUIN COUNTY (CASE NO. 3032) We have reviewed the Final Closure Plan French Camp Landfill, submitted on 23 October 2001 on your behalf by EMCON/OWT Solid Waste Services. The Closure Plan was submitted to comply with the requirements of Title 27 California Code of Regulations for submittal of a Final Closure Plan and a Final Post-closure Maintenance Plan. Staff finds that the Final Closure and Post-closure Maintenance Plans are incomplete as submitted for the following reasons: 1. A requirement of Title 27 Section 21769 is that final closure and post-closure maintenance plan for units jointly regulated by the RWQCB and the CIWMB shall be included as an integrated or separable part of the Joint Technical Document(JTD). A complete discussion of the requirements and form of a JTD may be found in Section 21585 of Title 27. 2. The landfill is surrounded by an earthen levee on three sides where it is bound by French Camp and Walker Sloughs. Over much of the landfill perimeter waste has been discharged over the outside face of the levee and to the edge of the slough. In orrlpr to close the landfill, all waste that is outside the Waste Management Unit(outside the levee perimeter)must be removed and disposed of properly. 3. The plan proposes to use a minimum 1.5-foot foundation soil layer. Title 27 Section 21090(a)(1) requires that: Closed landfills shall be provided with not less than two feet of appropriate materials as a foundation layer for the final cover. The plan must be revised to incorporate 2 feet of foundation layer in the final landfill cover. 4. Drawing No. 3 The Final Grading Plan fails to show the design limit for the final soil cover on the eastern margin of the landfill. Drawing No. 3 should be corrected and resubmitted. 5. The use of grass-lined swales on the landfill top deck to collect and divert storm water is not consistent with the goal of limiting so far as possible infiltration through the cap. The design California Environmental Protection Agency bra Recycled Paper The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at http://www.swrcb.ca.gov/rwgcb5