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California Regional Water (duality Uontrol Board <br /> entral Valley Region <br /> Robert Schneider,Chair OP13 <br /> Dan Skopec Arnold <br /> Acting Secretary Sacramento Main Office Schwarzenegger <br /> 11020 Sun Center Drive#200,Rancho Cordova,California 95670-6114 Governor <br /> Phone(916)464-3291 •FAX(916)4644645 <br /> hUp://www.waterboards.ca.gov/centralvalley � I C LUi <br /> 1 May 2006 ` `° H06 <br /> r <br /> s, s "'T <br /> Michael Carroll <br /> Senior Engineer <br /> Department of Public Works <br /> County of San Joaquin <br /> P.O. Box 1810 <br /> 1810 E. Hazelton Avenue <br /> Stockton, California 95201 <br /> REVIEW OF ET FINAL COVER ADDITIONAL INFORMATION FOR FOOTHILL SANITARY <br /> LANDFILL, SAN JOAQUIN COUNTY FACILITY#5B390300001 <br /> We have reviewed the ET Final Cover Additional Information for the Foothill Sanitary Landfill <br /> received on 29 March 2006. The report was prepared for San Joaquin County Public Works <br /> (SJCPW) and submitted by Kleinfelder Inc (Kleinfelder). The report submitted provides <br /> additional information requested during the 3 March 2006 meeting between SJCPW, <br /> Kleinfelder, and the Regional Water Quality Control Board (RWQCB). We have the following <br /> comments. <br /> For any alternative landfill cover and test section it is essential to define the objective and <br /> performance criteria for the cover. It appears the objective and performance criteria for the ET <br /> test section and "Interim Final Cover" is either not presented clearly or not defined. To <br /> determine whether the ET test section was successful at the completion of the test period, the <br /> performance criteria has to be clearly defined. We acknowledge the prescriptive standard <br /> outlined in Title 27, subsection 21090(a)(2) requires a low-hydraulic conductivity layer to <br /> mimimize through-flow into waste and the engineered alternative must meet the performance <br /> of the prescriptive standard set forth in Title 27. However, we also recognize the Title 27 <br /> prescriptive standard has problems not totally understood when the regulations were written <br /> (desiccation cracks). Therefore, we request a clearly defined performance criteria to compare <br /> the data received during the 5 year test period for the ET test section and "Interim Final <br /> Cover". This performance criteria would have to be at least as protective as an one foot clay <br /> cover with a hydraulic conductivity of 1X10-6 cm/sec or greater without desiccation cracks. <br /> Also, when defining performance criteria, other studies should be reviewed and evaluated. <br /> For example, the ET cover being proposed is a relatively new concept with respect to landfill <br /> covers and as such must have some definitive way of measuring success of the proposed test <br /> section and "Interim Final Cover." The objective of the ET test section and "Interim Final <br /> Cover" should be defined similar to the Alternative Covers Assessment Program (ACAP), <br /> Kiefer Landfill site where "the primary objective is to demonstrate that the alternative earthen <br /> covers restrict percolation into waste to 3 mm/year or less, which is common equivalency <br /> California Environmental Protection Agency <br /> Qa Recycled Paper <br />