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Mr. John Moody -2- <br />PLACING ADDITIONAL REFUSE ON EXISTING UNLINED FOOTPRINT <br />AT FOOTHILL SANITARY LANDFILL <br />Relevant Regulatory References <br />In 1989, Waste Discharge Requirements (WDRs) were issued to the County for this site under <br />Central Valley Region Order 89-018 (attached). This Order specifies the active fill area of <br />"approximately 85 acres", now called Area "I", as the actual waste boundary existing at that time. <br />In 1991, federal regulations were promulgated under 40 Code of Federal Regulations (CFR) Part <br />258 (commonly referred to as "Subtitle D"). This regulation required, among other things, that all <br />new landfills be constructed with liner and leachate collection and removal systems. In anticipation <br />of these federal regulations, the State of California Water Resources Control Board (SWRCB) <br />issued Resolution 93-62 requiring amended WDRs for all landfills. Item ILA of that Resolution <br />(excerpted below) defines a lateral expansion as any area "outside the actual waste boundaries of <br />an MSW landfill as it exists on October 9, 1993". <br />MSW landfills -- By the Federal Deadline (e.g., October 9, 1993), each Regional Water Board shall <br />amend the waste discharge requirements for discharges of waste at all MSW landfills in its region <br />(including discharges to any area outside the actual waste boundaries of an MSW landfill as they <br />exist on that date ["lateral expansion" hereinafter]), to require persons who own or operate such <br />landfills to.... (underline emphasis added). <br />Based on the above, placement of additional refuse within the actual waste boundaries of Area "I" <br />is not a lateral expansion, but rather continuing refuse placement within the waste boundaries <br />existing prior to 1993. In addition, the present WDRs (Order No. R5-2003-0020) do not require <br />installing impermeable membrane within the actual waste boundaries of Area "I" before placing <br />additional refuse. <br />Planned Continued Refuse Placement Within Area "I" Waste Boundary <br />Based on consideration of the above, the County intends to continue placing refuse within the <br />boundaries of Area "I". Standard refuse placement procedures will be used, including: <br />• Maximizing available airspace by removing as much cover soil as possible from the existing <br />fill surfaces before placing refuse. <br />• Placing refuse using standard landfill placement and compaction equipment. <br />• Covering the placed refuse with daily cover (soil or tarps) in accordance with the Operating <br />Permit. <br />• Placing intermediate cover over daily cover when appropriate. <br />• Retaining existing landfill gas (LFG) wells and geomembrane in fill areas. <br />The fill area under discussion is adjacent to an area over which a geomembrane was placed in <br />2006 (Figures 2 and 3). This membrane was placed to address a past concern that landfill gas <br />from newly -placed refuse could penetrate through older refuse, into the soil and to groundwater <br />below. To address this concern and prevent gas produced by refuse placed in the future from <br />entering beneath that geomembrane, the County will install a horizontal LFG collector at the edge <br />of the membrane (Figure 3). <br />