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RECEIVE10 Q EDMUND G. BROWN JR. GOVERNOR MARCALIFOW NIA MATTHEW RODRIUUEZ Wa�er Boards ENVIROARY FOR ENVIRONMENTAL PROTECTION HEALTH Central aIleRegional Water all trot o IT( .� — 18 March 2015 Taj M. Bahadori, P.E. San Joaquin County Dept. of Public Works 1810 East Hazelton Avenue Stockton, California 95205 RESPONSE TO COMMENTS, TENTATIVE REVISED WASTE E DISCF! GE REQUIREMENTS, FOOTHILL LANDFILL, SAN JOAQUIN COUNTY Central Valley Water Board permitting staff reviewed your 16 March 2015 comments (copy enclosed) on the recently-issued tentative revised Waste Discharge Requirements (WDRs) for the Foothill Landfill. The tentative WDRs are scheduled for consideration at the Central Valley Water Board's 16/17 April 2015 board meeting in Fresno. This letter provides Water Board staff's response to your comments. A summary of your comments and staff's response to each is provided below. 1. LF-1 Closure Comment -- The County requests that the requirement for closure of LF-1 be removed from the WDR or delayed. LF-1 is already partially closed, with a final evapotranspirative (ET) cover on the top deck. . . The placement of additional soil cover over LF-1 at this point serves no environmental purpose, and imposes a significant financial burden on the County. The cost of full closure of LF-1 will be in excess of Three Million Dollars ($3 Million). . . Staff Response —As noted in Finding 20 of the proposed WDRs, landfill LF-1 does not have a base liner and underlying geologic materials do not meet Title 27 containment standards. Given that the landfill has already been developed and it is not feasible to retrofit the landfill with a base liner, the remainder of the landfill unit (i.e., side slopes) must be closed. As previously discussed, existing soil cover on the landfill's side slopes may be of sufficient thickness and type to be approved as envirotranspirative (ET) final cover, but the Discharger will need to make this demonstration under the WDRs. If the Discharger is not able to make an ET cover demonstration for the remaining landfill slopes, another closure design would need to be proposed consistent with the WDRs. To provide the Discharger more time to complete the required tasks, the due dates in the WDRs for submitting closure-related documents and completing landfill closure have been extended by one year. See Closure and Postclosure Maintenance Specifications E.1 and E.2; and Provision H.9. 2. LF-1 Leachate/Condensate Disposal Comment -- This Finding states that landfill gas (LFG) condensate from LF-1 cannot be discharged to LF-2. However, a review of the referenced regulatory criteria for condensate handling appears to indicate that the LF-1 condensate can be discharge to LF-2. . . Based on KARL E. LONGLEY SCD, P.E., CHAIR I PAMELA C. CREEDON P.E., BCEE, EXECUTIVE OFFICER 11020 Sun Center Drive#200,Rancho Cordova,CA 95670 1 www.waterboards.ca.gov/centraIvalley Z'j RECYCLED PAPER