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v 1, 4 Attachment 1 DEC 0 4 ZOOZ Subject: Permitting and Inspection Branch Joint Site Visits with the Diversion,PLT H Assistance Division h*#Nks During the week of July 29,2002 staff of the Permitting and Inspection(P&I)Branch of the Permitting and Enforcement Division assisted staff of the Diversion,Planning and Local Assistance(DPLA) Division in evaluating conditions and obtaining information at pre-selected landfills for a possible follow- up agenda item to be presented by the DPLA staff regarding Alternate Daily Cover(ADC)usage. A total of nine sites were visited. Since ADC material processing was the only reasons for site visits to the Guadalupe Sanitary Landfill and Norcal Waste Systems Pacheco Pass landfill the assessment by P&I Branch staff only focused on the adequacy of cover and particle size analysis of the construction/demolition ADC. The other seven facility's assessments included an evaluation of the Solid Waste Facility Permit(SWFP),Report of Disposal Site Information(RDSI),and the California Environmental Quality Act(CEQA)documents as they relate to ADC (as well as beneficial use materials). These specifications were compared and evaluated to site conditions. In addition,the following Title 27,California Code of Regulations(27 CCR) State Minimum Standards (SMS)were evaluated at each site: 27 CCR 20510—Disposal Site Records (focusing on disposal tonnage and ADC usage),27 CCR 20640—Spreading and Compacting,27 CCR 20670—Availability of Cover Material, 27 CCR 20680—Daily Cover,and 27 CCR 20690—Alternate Daily Cover. An analysis of ADC use was also conducted to determine if appropriate quantities are being utilized based upon the sites typical working face size. Part of the study included CIWMB staff arriving at the facility without prior knowledge to the operators or in other words a"surprise"visit so the operator would not change any regular cover practice. Holes were dug into the ADC using either a hand shovel or an excavator. The operator was requested to select representative areas where they felt ADC was applied in accordance with the regulations. Regarding the overall assessment of records,much of the tonnage information that was requested from the operators has not been forth coming or was submitted as incomplete. A full assessment regarding 27 CCR 20510(Records)and 20690(a)(5)the records requirement for ADC could not be made for all sites. The following result of the assessment has been completed with the information submitted at the time of the writing of this memo: Forward Landfill(Facility No.39-AA-0015) This facility is a municipal solid waste landfill and is located in San Joaquin County. It was visited on Friday morning August 2. The site is permitted to accept a maximum of 6,680 tons per day. This limit includes tonnage destined for the Forward Resource Recovery Facility. Tonnage records obtained from the operator for the 18 month period of January 1, 2001 to June 30, 2002 indicated that the average daily tonnage of waste accepted for disposal was 4,069 tons per day. These figures do not include soil received for cover or ADC. This facility takes in contaminated soils some of which are allowed to be used as cover material and some of which is not. The contaminated soils that are not allowed for cover are disposed of in a separate working face area along with other Class II wastes. The tonnage disposed of in the Class II working face area during the 18 month period that was 543,469 tons leaving 1,316,252 tons for disposal at the refuse working face. The SWFP dated June 22, 1999 allows acceptance of TASW,designated waste,contaminated soil, sewage sludge, ashes,dredge and fill material however it does not specify that any of the materials will be used as ADC. It does allow a geosynthetic blanket providing that it is not used to cover designated waste. The RDSI dated February 1999 identifies contaminated soil as a cover material and mentions that they are 1