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6 <br /> V <br /> COMMENTS TO <br /> SECOND DRAFT CEASE AND DESIST ORDS <br /> GENERAL <br /> Where useful, text suggested for addition is in bold font. <br /> COMMENTS TO FINDINGS <br /> Finding 1 and 2: We have no comments. <br /> Finding 3 refers to an area outside the landfill closure cap of 1.6 acres. Recent calculations <br /> indicates that area is approximately 1.3 acres. For accuracy, this is an area outside the original <br /> closure area, rather than the landfill area. <br /> Finding 4 states the Corral Hollow Creek flows intermittently toward the San Joaquin River. <br /> This is literally true, that it flows "toward"the San Joaquin River, but I recently became aware of <br /> a study by Shaw Environmental and Infrastructure done for another County department that this <br /> Creek does not actually reach the San Joaquin River, but instead is caused to pond and <br /> infiltrate near the city of Tracy. In the interest of accuracy, we ask that this sentence be revised <br /> to read "...which flows intermittently toward, but does not reach, the San Joaquin River'. <br /> Finding 5 correctly states that two aquifers (shallow and deep) are present at the site. The <br /> shallow aquifer is created by water perching on the Corcoran Clay formation. The County has <br /> installed seven (7) groundwater monitoring wells into that water. However, the wording of this <br /> Finding.implies that only three (3) of these six (6)wells reach that water. In the interest of <br /> accuracy, and to avoid this possible confusion, we suggest that the wording of this Finding be <br /> revised to reflect that all seven shallow-aquifer wells reach the same shallow aquifer, which is <br /> perched on the Corcoran Clay. Also, the shallow aquifer is sometimes found at 83 feet below <br /> ground surface, considering the new off-site wells. <br /> Findings 6 through 8: We have no comments. <br /> Finding 9 correctly describes closure of the landfill as corrective action in 1995. However, a <br /> landfill gas extraction system was installed in 2001, also as corrective action, but not noted in <br /> this Finding (it is noted much later, in Finding 20). In the interest of completeness and <br /> consistency, we suggest that the installation of the landfill gas collection system be noted in <br /> Finding 9. <br /> Finding 10: We have no additional comments. Note that the present area of closure is <br /> presently calculated to be approximately 1.3 acres. <br /> Finding 1: We have no comment. <br /> Finding 12 refers to a meeting between "Board Staff, Caltrans, and the County". Actually, the <br /> meeting attended by County staff did not include Caltrans personnel. At that meeting, Water <br /> Board staff discussed Caltrans' willingness to cooperate in the closure over refuse on Caltrans <br /> property, and that a Water Code Section 13267 Order, naming both Caltrans and the County, <br /> Comments to Second Draft CDO 2 San Joaquin County <br /> Submitted February 28,2013 Public Works/Solid Waste <br />