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,;T+ A!rr-OF CALIFORNIA GEORGE DEUKMEJIAN,Governor <br /> CALIFORNIA REGIONAL WATEM QUALITY CONTROL BOARD— <br /> CENTRAL VALLEY REGION <br /> 3443 ROUTIER ROAD <br /> SACRAMENTO,CA 95827-3098 <br /> 4 November 1988 <br /> Mr. Greg Basso <br /> Forward Inc. <br /> P. O. Box 6336 <br /> Stockton, CA 95206 <br /> FORWARD LANDFILL, SAN JOAQUIN COUNTY (CASE NO. 2209) <br /> Based on our phone conversation of 1 November 1988 I <br /> understand you intend to construct a surface impoundment at <br /> the Forward Landfill . The proposed impoundment will be used <br /> to dispose of leachate from the Class III landfill trenches <br /> and Class II ash pit, and any surface run off from the WMU A <br /> cap which has contacted contaminated soils placed on top of <br /> the unit for use in final closure construction. Construction <br /> of a surface impoundment is necessary in the event that <br /> leachate is generated during the wet season. <br /> I am concerned about several aspects of the proposed surface <br /> impoundment project including impoundment design , <br /> construction, construction quality assurance (CQA) , <br /> monitoring , and closure. I recognize that you need to begin <br /> construction as soon as possible due to weather conditions . <br /> However, the impoundment must be designed in accordance with <br /> Title 23 , California Code of Regulations, Chapter 3 , <br /> Subchapter 15 (Subchapter 15) . Your suggestion that this <br /> surface impoundment would only be used temporarily until a <br /> permanent impoundment is available does not relieve you of <br /> your responsibilities under Subchapter 15. In addition, your <br /> waste discharge requirements (WDRs) Order No . 88 - 023 , <br /> Specification B. 29 , requires that any surface impoundment be <br /> designed and constructed in accordance with Subchapter 15 and <br /> approved by the Board prior to construction and again prior <br /> to operation. Impoundment design could consider engineering <br /> alternatives as permitted by Subchapter 15 based on a <br /> specific period of operation, e.g . 6 or 12 months . However, <br /> the design needs to be submitted to the Board and approved <br /> before construction. <br /> With respect to construction of the impoundment, I recognize <br /> that your construction contractor has substantial experience <br /> in building compacted soil liners at your facility. I want <br /> to emphasize again, however, the importance of implementing a <br /> Board approved CQA plan during liner construction. The CQA <br /> process is the only method available to insure that a low <br /> permeability soil liner is built and to document the liner <br /> testing results. Order No . 88-023 and Subchapter 15 also <br />