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10/10/91 10:17 1&91 66 7013 SACRAMENTO _ _ Q013/018 RWQCB in April 1991. Recent results indicate the in-place ASW may not be affecting groundwater at the site. In addition, ground water modeling in the RDSI indicates capping of the site will reduce infiltration and thus potential to affect groundwater. Therefore, remediation of potential impacts by capping is a viable alternative. Comment 2• "EHD feels that any proposal which adds new waste on top of the existing landfill will add to the potential for contamination at this unlined class 111 landfill site especially since waste is present at -20 feet mean sea level and first ground water is present at -17 feet mean sea level. " The waste which will be placed on portions of the existing site which contain waste will be ASW - which is treated as described in the RWD (Appendix D of the PSR). Based on the designated level assessment (Section 2.5 of the RWD) two scenarios were modelled. Ten years of uncapped operations would result in an increase in TDS estimated at around 100 mg/1 and negligible metal migration. Installation of a cap over the site would remove the driving force of the migration of both TDS and metals and thus effectively retard the migration of contaminants to groundwater. Additionally, as mentioned above, recent monitoring results suggest that existing waste is no longer in contact with ground water and may not be affecting ground water quality. Comment on Section A-3: "PDM section A-3 corresponding to PSR section C. 4. The PSR refers to drawing I as showing site access from El Dorado Street. The map known as drawing one does not clearly show the site access gate or driveway." A clear depiction of the site access is shown on the attached Plate 1.3. The access road, which is labelled "driveway" extends from South El Dorado Avenue to the fence gate as shown by the dotted lines. At the fence line it meets a chain link gate and concrete pavement as shown. (Plate 1.3 is taken from the SWAT for the site.) "PDM section A-5, A-6, B-1, B-2 corresponding to PSR sections C. 6, C. 6.1.5, D.1, and A 2. These sections are not present in the PSR. EHD requests these sections be made available to continue processing the 5 year permit review. Response: A-5 Geologic/Hydrogeologic Conditions with Respect to Site Design: Sections C.6.1.5 and C.6.3 contain information on Geologic condition with Respect to Sitg Design and Hydro logic Consi esti n on Design, respectively. There is also related backup information in other areas of Section C of the PSR, and an evaluation of these elements in Sections F.2 and F.3 of the PSR. JM -914 Page 2 of 7 Copyright 1991 Kleinfelder, Inc. KLEINFELOER 1077 File Circle Sacramento, CA 95827 (910) t66-1701