CORRESPONDENCE_2007 (7/07 - 12/07)

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Mr. Robert McClellon, REHS Environmental Health Department 600 East Main Street Stockton, California 95202 uftl� MI -It 71 September 20, 2007 SUBJECT: REFUSE BEYOND COUNTY PROPERTY CORRAL HOLLOW SANITARY LANDFILL Dear Mr. McClellon: E P. O. BOX 1810 - 1810 E. HAZELTON AVENUE STOCKTON, CALIFORNIA 95201 (209) 468-3000 FAX (209) 468-2999 www.sjgov.org/pubworks Thank you for your letter to Desi Reno dated August 27, 2007 regarding the investigation of the extent of refuse and closure cap at the Corral Hollow Sanitary Landfill. As you correctly state, refuse was discovered in the property now owned by the California Department of Transportation (CalTrans) which we have designated area "J" (figure attached), and the full extent of the waste in this property has not been determined. Once the full extent of the waste onto CalTrans property is determined, CalTrans can consider their options to address the situation. We also acknowledge the need to amend the Closure Plan, Postclosure Maintenance Plan, and cost estimates for this site, to include the extension of the closure cap and related improvements at the landfill. The existing Closure Plan will be amended to include the newly closed areas; the Postclosure maintenance cost "estimate" will be based on actual expenditures since closure. Ensuring that all waste receives proper cover is a crucial aspect of closure of any landfill; however, it appears that the environment at the Corral Hollow Landfill is not threatened at this time by lack of cover due to the effectiveness of drainage improvements over the areas of concern by the County in 2003. The only verified environmental impact due to the presence of the landfill at this time is the presence of volatile organic compounds (found below 10 ppb) at one shallow aquifer groundwater monitoring well. The deep aquifer wells indicate no impact. Groundwater impact at the one shallow aquifer well is probably caused by inadequate collection of landfill gas at that edge of the landfill. The County's objective has been to increase the influence of the landfill gas system, thereby preventing continuing impact to groundwater. Improvement of the landfill gas system would be in coordination with extending the closure cap, and could easily be designed to influence the refuse in the CalTrans property immediately adjacent to the Corral Hollow Landfill. Delineation of the extent of refuse within County property is complete and we anticipated proceeding directly with design and construction. We were therefore disappointed when we were directed to include closure over the refuse in both County and CalTrans property in a single project because of the delay that this will entail. CalTrans' letter dated September 13, 2007 indicates an understandable reluctance to accept liability for refuse that may have been present but undisclosed on their property at the time of purchase, or that was placed on their property after purchase. Resolving this issue will further delay the start of the work. PQU'N THOMAS R. FLINN DIRECTOR C4�iFOP��P THOMAS M. GAU CHIEF DEPUTY DIRECTOR MANUEL SOLORIO DEPUTY DIRECTOR STEVEN WINKLER DEPUTY DIRECTOR ROGERJANES BUSINESS ADMINISTRATOR Mr. Robert McClellon, REHS Environmental Health Department 600 East Main Street Stockton, California 95202 uftl� MI -It 71 September 20, 2007 SUBJECT: REFUSE BEYOND COUNTY PROPERTY CORRAL HOLLOW SANITARY LANDFILL Dear Mr. McClellon: E P. O. BOX 1810 - 1810 E. HAZELTON AVENUE STOCKTON, CALIFORNIA 95201 (209) 468-3000 FAX (209) 468-2999 www.sjgov.org/pubworks Thank you for your letter to Desi Reno dated August 27, 2007 regarding the investigation of the extent of refuse and closure cap at the Corral Hollow Sanitary Landfill. As you correctly state, refuse was discovered in the property now owned by the California Department of Transportation (CalTrans) which we have designated area "J" (figure attached), and the full extent of the waste in this property has not been determined. Once the full extent of the waste onto CalTrans property is determined, CalTrans can consider their options to address the situation. We also acknowledge the need to amend the Closure Plan, Postclosure Maintenance Plan, and cost estimates for this site, to include the extension of the closure cap and related improvements at the landfill. The existing Closure Plan will be amended to include the newly closed areas; the Postclosure maintenance cost "estimate" will be based on actual expenditures since closure. Ensuring that all waste receives proper cover is a crucial aspect of closure of any landfill; however, it appears that the environment at the Corral Hollow Landfill is not threatened at this time by lack of cover due to the effectiveness of drainage improvements over the areas of concern by the County in 2003. The only verified environmental impact due to the presence of the landfill at this time is the presence of volatile organic compounds (found below 10 ppb) at one shallow aquifer groundwater monitoring well. The deep aquifer wells indicate no impact. Groundwater impact at the one shallow aquifer well is probably caused by inadequate collection of landfill gas at that edge of the landfill. The County's objective has been to increase the influence of the landfill gas system, thereby preventing continuing impact to groundwater. Improvement of the landfill gas system would be in coordination with extending the closure cap, and could easily be designed to influence the refuse in the CalTrans property immediately adjacent to the Corral Hollow Landfill. Delineation of the extent of refuse within County property is complete and we anticipated proceeding directly with design and construction. We were therefore disappointed when we were directed to include closure over the refuse in both County and CalTrans property in a single project because of the delay that this will entail. CalTrans' letter dated September 13, 2007 indicates an understandable reluctance to accept liability for refuse that may have been present but undisclosed on their property at the time of purchase, or that was placed on their property after purchase. Resolving this issue will further delay the start of the work.