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June -19-2008 07:53 AM CA I egrated Waste Management 916-%413884 2/3 <br />w <br />Mr. Andrew .Keller <br />June 17, 2p0$ <br />Page 2 of 3 <br />RWQCB grad/or the C.IW10) the landfill to be capped with nataral sediment layer <br />and covered with a vegetated layer of topsoil, rather than an impervious layer. <br />The presentation goes on to state that the coves was designed to contain from up <br />to a 100 -year, 24-hour storm. The presentation prompts us to ask the following <br />questions: <br />1) Has the RWQCB approved such a cover design? <br />2) If the RWQCB has approved the stated covet design, were there <br />calculations included for the cover design? If there were calculations to <br />support the design., please submit tlae calculations. <br />Corrective Action Plan: <br />On Page 2, Site History: 'llie statement is made that, "...the CIWMB directed <br />Cove Contractors to address these issues in a Corrective Action Playa, including <br />the recommendation for the installation of new perimeter gas probes outside the <br />landfill footprint: and an increased monitoring -Eiequency." The statement is <br />mostly correct but not entirely. <br />CIWMB staff' did not recommend installing new perimeter gas probes. - What we <br />stated was that, if upon review of the as-builts it is determined that the two probes <br />(PGP1 and PG- P2) were found to have been installed is waste, Cove Contactors <br />will be approved to install two other replacement probes outside the landfill <br />footprint. As we indicate in this letter, our review of the as-built.S fbr the two <br />probes do not indicate that the probes are located in refuse. The contention that <br />the probes axe installed in refuse has not been proven. Our conclusion is that <br />PUP 1 and PGP2 appear to be good compliance probes and they have indicated <br />gas migrating from the site. <br />'On. Page 13, .Implementation of.Preftrred Alternative: The statement is made that <br />the preferred corrective action, alternative is the installation of a passive system <br />with carbon filter treatment. Because the gas migration monitoring probes have <br />uidicated that gas is migrating from the site, Cove Contractoirs is hereby directed <br />to submit to th.e Enforcement Agency for review and approval the following: <br />a The design plan for the preferred passive system_ The system shall be <br />designed in such a way that it could be converted to an active system, if <br />monitoring results should indicate the need, and shall also be easy to <br />expand to all other areas of the landfill. <br />• Within thirty (30) days, submit proposed time lines for the installation of <br />the system. ,(Mote: the design and installation of the control system may <br />require approval by the San Joaquin. Air Pollution Control District. <br />