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.RW!N c ?� THOMAS M. G/�U P.O.BOX 1810-1810 E.HAZELTON AVENUE DIRECTOR STOCKTON,CALIFORNIA 95201 (209)468-3000 FAX(209)468-2999 FORNc www.sjgov.org/pubworks FRITZ BUCHMAN A r DEPUTY DIRECTOR MICHAEL SELLING wxlzmis f0T Y®14.9 DEPUTY DIRECTOR _ ROGER JANES 7©07 67/0 6000 'hECEIVED °i BUSINESS ADMINISTRATOR December 27, 2012 i DEC Mr. Vinoo Jain, PE Water Resources Control Engineer ENVIRONMENTAL HEALTH Waste Discharge to Land Permitting Unit PERMFd IS VI CES 11020 Sun Center Drive#200 Rancho Cordova, California 95670-6289 SUBJECT: COMMENTS TO TENTATIVE WASTE DISCHARGE REQUIREMENTS FOR THE CORRAL HOLLOW SANITARY LANDFILL Dear Mr. Jain: Thank you for the opportunity to comment on the tentative Waste Discharge Requirements (WDRs)for the Corral Hollow Landfill. Upon review, we find the documents factually correct, with the following suggestions for clarification. Closure Over Caltrans Property The County and the Caltrans intend to transfer the ownership of the Caltrans property to the County in the near future, but it is possible that this agreement will not be concluded for reasons that we cannot foresee at this time. If this were to occur, then the County would not be able to comply with this provision. In recognition of this situation, we suggest that directives regarding closure over Caltrans property be conditional, as reflected in the.following suggested passages: The first sentence of Order E-2 (Closure and Post-Closure Maintenance Specifications, page 19) would read: The Discharger shall close all uncovered landfill waste on its property,and on adjacent Caltrans property with Caltrans permission,with a final cover as proposed in the 26 October 2012 Addendum to the Closure and Postclosure Maintenance Plan (PCPCMP) and as approved by this Order. Tasks That County May Not Be Able to Perform The task schedule shown in Provision 7-A on page 22 reflects the County's intent for closure construction. Unfortunately, the schedule is subject to weather and contractor performance, as well as regulatory approval of documents (Construction Specifications, D-1 on page 18), of which the County is not in full control. Therefore, we suggest that the phrase "or as otherwise agreed with Board Staff' or equivalent be inserted in that Provision, allowing staff flexibility. Similar wording would be included in Task A and B of Section H Provisions (page 21).