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EDMVND G. BROWN JR. P fa !r UDVENNOH ate,. G RL1 y ` MATTHEW FIODPtOUE2 ..RICA SECRETARY FOR Water Boards ENVIRONMENTAL PNOfEC710N Central Valley Regional Water Quality Control Board 13 July 2012 W. Michael Carroll Dennis Agar San Joaquin County Dept. of Public Works Deputy District Director P Solid Waste Division California Department of Transporta o P.O. Box 1810 P.O. Box 2048 Stockton, CA 95201 Stockton, CA 95201 REQUEST TO EXTEND CONSTRUCTION SCHEDULE TO 2013, CORRAL HOLLOW LANDFILL, SAN JOAQUIN COUNTY On 7 July 2011, the Central Valley Water Board issued a Water Code section 13267 Order(the "Order") that required the San Joaquin County Department of Public Works (the "County") and the California Department of Transportation (collectively referred to as the "Dischargers") either to remove waste that was identified outside of the Corral Hollow Landfill footprint on CalTrans property or to extend the closure cover from the landfill, thus incorporating this waste into the existing waste management unit. The Board circulated a draft of the Order to the Dischargers before issuance, and the Board revised the Order in response to the Dischargers' comments, accommodating both the Dischargers' decision to construct a single extension cap over the uncovered waste and the Dischargers' proposed schedule. The intent of the Order was to commit the Dischargers to a plan of action so that the waste would be covered during the 2012 construction season. The Order required that the Dischargers submit a Final Cover Expansion Design Report("Design Report") by 10 October 2011. Though the Dischargers submitted a Design Report by this deadline, which proposed to cover the waste during the 2012 construction season, the Design Report was materially deficient on multiple technical points and did not comply with Title 27. On 15 March 2012, the Board issued the Dischargers a Notice of Violation due to the deficiencies in the Design Report. The Notice of Violation acknowledged that the County had made a subsequent written commitment to resubmit a Design Report that would comply with Title 27, and would propose the installation of the cover during the 2012 construction season. Based on that commitment, Board staff stated that we would not recommend that the Executive Officer issue an administrative civil liability complaint to address the compliance deficiencies. However, the County's 7 July 2012 letter describes concerns about construction taking place in the late fall of 2012, and the County now proposes that the project go out to bid in December 2012. Construction would then begin in May 2013, and would not be completed until August 2013. The County has asked that Board staff approve this delayed construction schedule. Board staff will neither approve nor deny the County's proposed schedule. Instead, we reiterate the need to cover the waste on the CalTrans property as soon as possible, and note that the Dischargers will face potential liability under the Water Code for missing the deadlines contained in the Order. However, if the Executive Officer proposes to issue an administrative civil liability complaint to address the violations, the reasons for the Dischargers' delays in covering the waste according to the proposed timeline may be considered as a KARL E. LONGLEY SCD, P.E., CHAIR PAMELA C. CREEDON, EXECUTIVE OFFICER 11020 Sun Center Drive#200,Rancho Cordova,CA 95670 1 www.waterboards.ca.gov/centralvalley `,J RECYCLED PAPER