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EDMUND G. BROWN JR. 005� a60VEPNOR MATTHEW RODRIOUEZ SECRETARY FOR WaterBoards ENVIRONMENTAL PROTECTION Central Valley Regional Water Quality Control EIVED MAR 2 0 2012 15 March 2012 ENVIRONMENTAL HEALTH PERMIT/SERVICES W. Michael Carroll Dennis Agar San Joaquin County Dept. of Public Works Deputy District Director Solid Waste Division California Department of P.O. Box 1810 Transportation Stockton, CA 95201 P.O. Box 2048 Stockton, CA 95201 NOTICE OF VIOLATION FOR INCOMPLETE FINAL COVER EXPANSION DESIGN FOR THE CORRAL HOLLOW LANDFILL, SAN JOAQUIN COUNTY On 7 July 2011, the Central Valley Water Board issued a Water Code section 13267 Order requiring the San Joaquin County Department of Public Works and the California Department of Transportation (Dischargers') to either remove waste identified outside of the Corral Hollow Landfill footprint on CalTrans property or extend the closure cover from the landfill to incorporate this waste. Prior to issuance, the 13267 Order was revised to accommodate the Dischargers' decision to construct a single extension cap over the uncovered waste, and to accommodate the Dischargers' proposed schedule. The intent of the 13267 Order was to commit the Dischargers to a plan of action such that the waste would be covered during the 2012 construction season. The 13267 Order required the Dischargers to submit a Final Cover Expansion Design Report by 10 October 2011. The Final Cover Expansion Design Report was submitted on time and underwent a cursory review by Compliance and Enforcement staff, followed by a full review by Permitting staff The Dischargers proposed to construct a closure cap extension using a Geosynthetic Clay Liner, or GCL. The Permitting Unit found the proposed closure cap extension to be inadequate on multiple technical points, and as such, the proposed design does not meet the performance standard of Title 27. The Permitting Unit is unable to update the Corral Hollow WDRs to allow the additional waste to be covered. Because the Permitting Unit found the proposed design does not comply with Title 27 requirement, the Dischargers are in violation of Task 1 of the 13267 Order and are subject to possible enforcement actions. Board staff and the Dischargers met on 9 March 2012 to discuss the inadequate technical report, the County's proposed delay in closure, and CalTrans' liability in the matter. Board staff stated that we would recommend that the Executive Officer issue an Administrative Civil Liability Complaint if the parties did not comply with the intent of the 13267 Order and submit a closure plan that complies with Title 27 or cover the waste during the 2012 construction season. In a letter dated 14 March 2012, San Joaquin County stated that it has re-evaluated the situation and will submit a revised closure design in April and commit to install the cover during the 2012 construction season. In particular, the County proposes to submit revised plans, technical specifications, and a Construction Quality KARL E. LONGLEY SCE), P.E., CHAIR I PAMELA C. CREEDON, EXECUTIVEOFFICER .................... ......................................................................... .. . --............. ............................................ .....................-- . .. ................. .........-. ...... ............--.....................--..........--....... .............................................. .................- ....................- 11020 Sun Center Drive#200,Rancho Cordova,CA 95670 1 www.waterboardS.ca.gov/contralvalley C,�RECYCLED PAPER