CORRESPONDENCE_2000-2005 - Laserfiche WebLink

Home Browse Search

a P California Regional Water Quality Control Board Central Valley Region Robert Schneider,Chair Winston H.Hickox Gray Davis Secretaryfor Fresno Branch Office Governor Environmental Internet Address: http://www.swrcb.ca.gov/rwgcb5 Protection 3614 East Ashlan Avenue,Fresno,California 93726 Phone(559)445-5116•FAX(559)445-5910 1 October 2002 T 0 2 200Z Tom Horton and W. Michael Carroll County of San Joaquin ENMRON EN-i HEALTH Department of Public Works PERMIT/SERVICES P.O. Box 1810 Stockton, CA 95201 NORTH COUNTYAND FOOTHILL LANDFILLS, SAN JOA QUIN COUNTY We have received the County's letters of 25 & 26 of September 2002 where you request reconsideration of"additional intermediate cover thickness" and"soil gas monitoring of VOCs" at the North County and Foothill Landfills regarding proposed revisions to Waste Discharge Requirements. The 26 September letter requests Board staff reconsider requiring landfill gas (LFG)monitoring in the unsaturated zone. The County states, "However, as RWQCB staff is aware, we are in urgent need to avoid any delay in obtaining acceptance of the liner design and construction of a new module at North County Landfill. Although we object, we must agree under duress because of contesting these requirements will delay the processing of our application. Therefore, we hope that RWQCB staff will see the reasonableness of our position, and not impose additional requirements beyond those of Title 27." Respectfully, Board staff cannot be held responsible for the County's waste management planning and financial concerns. The record shows that we have been very flexible and open to the County's needs with regards to all active and closed(i.e., Corral Hollow) landfills under the County's purview. We have expedited the drafting of revised Waste Discharge Requirements (WDRs) for the North County Landfill even though we have not received a complete Report of Waste Discharge. We have not received a Report of Waste Discharge for the Foothill Landfill as'of the date of this letter. In good faith and in agreement with County staff,we have included tasks with associated compliance dates in the draft WDRs to ensure that there is a complete record prior to construction of the expansion at North County Landfill The County states that requiring LFG monitoring in the unsaturated zone is not reasonable and beyond the scope of Title 27. The following references in Title 27 provide clear guidance to the Board in requiring landfill gas monitoring in the unsaturated zone: Section 20310 (c) states, "Class Ill landfalls shall have containment structures which are capable of preventing degradation of waters of the state as a result of waste discharges to the landfalls if site characteristics are inadequate. " In this case, the containment structure is the proposed alternative liner designed to contain waste constituents. Title 27, Section 20164 California Environmental Protection Agency Via,Recycled Paper The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at http://www.swreb.ca.gov/rwgcb5