From: Bryan ClarksonTo: Shelton, Brad@Waterboards; Busby, Robert@Waterboards; Jain, Vinoo@WaterboardsCc: Phil Graham; Julian C. Isham (Julian.Isham@aptim.com); Haskell, KenSubject: Ostrom Road - Follow up Comments on Tentative WDRsDate: Thursday, January 11, 2018 5:38:20 PMAttachments: image2018-01-11-143525.pdf

Rob, Brad, and Vinoo, Thank you for your time this morning discussing the Recology Ostrom Road WDRs. As requested, following is a list of the additional Recology comments we discussed on the call as wellas two additional items that we noticed after our phone conversation:

1. Depth of leachate in LCRS: In the Response to Discharger Comments #3 and #24, theRegional Board stated that the depth of leachate in the LCRS (including the sump) shall be nogreater that 30 centimeters (12 inches). Recology is concerned that being required tomaintain a depth of 12 inches in sumps that are deeper than 12 inches (i.e. 18”-24”) mayresult in unnecessary wear and maintenance on the pumps. Based on the Standard ProvisionF.22 that states that the depth requirement excludes the leachate sump, Recology requeststhat an alternative depth of at least the depth of each LCRS sump be approved. During ourdiscussion, it was clarified that additional revised language was included that allows forgreater than 12 inches in the sump area if the Discharger is able to demonstrate that suchvariance is necessary. (The text added to Discharge Specification B.22 and Standard FacilitySpecification E.13 was “… unless the discharger demonstrates that it is infeasible to maintainless than 12 inches in the LCRS sump”).

2. MRP A.7.e Table (pg 18) : Recology is concerned that the “Daily” monitoring frequency listedin the table to confirm groundwater and side slope separation is excessive.

3. MRP Table III: The “Daily” Total Flow monitoring frequency is excessive and we discussedrevising to “Monthly”.

4. MRP Table III: The reporting frequency stated in Footnote 6 should be revised to“Semiannually”.

5. MRP A.7.b.iii: Landfill gas monitoring of the leachate sumps is unnecessary due to theexpected presence of landfill gas in the LCRS sumps. Please delete this section. As wediscussed, monitoring of pressure/vacuum at the base of the liner would be more beneficialto determine possible migration of landfill gas from the cells.

6. WDR Provision H.10.a, b, &c : Task reporting schedule: A proposed revised reportingschedule for the tasks listed in WDR Provision H.10.a, b, & c is attached. The proposed duedate is listed next to each task.

7. Additional Item - MRP A.7.b.ii: We noticed after our call that the sampling frequency for thepan lysimeters and suction lysimeter in corrective action is listed as “Monthly” in the MRPSection A.7.b.ii table. The sampling includes the Field and Monitoring parameters listed inTable II. It would seem that the sampling frequency would be the same as the correctiveaction groundwater monitoring frequency of “Quarterly” listed in Section A.7.a. MRP Table II

mailto:brad.shelton@waterboards.ca.govmailto:robert.busby@waterboards.ca.govmailto:vinoo.jain@waterboards.ca.govmailto:PGraham@recology.commailto:Julian.Isham@aptim.commailto:Ken_Haskell@golder.com

lists a sampling frequency of semiannually for pan lysimeters in detection monitoring so a“Quarterly” sampling frequency for corrective action pan lysimeters, if liquid is detected,seems reasonable and consistent.

8. Additional Item - MRP A.7.b.iv: We noticed after our call that the corrective action gasprobe sampling frequency is listed as “Monthly” in the MRP Section A.7.b.iv table. This isinconsistent with the table that is referenced (Table VII – Landfill Gas Corrective ActionMonitoring Program) that lists a sampling frequency of “Quarterly”. Please revise SectionA.7.b.iv table sampling frequency to “Quarterly”.

Again, we appreciate your time and effort while working with us updating the Recology Ostrom RoadWDRs. If you have any questions, please contact Phil Graham or me. Thanks. Bryan ClarksonGroup Environmental Manager Recology™ Environmental Solutions1 Town Square Place, Suite 200 | Vacaville, CA 95688T: 707.450-2339 | C: 707.249.1546 | bclarkson@recology.comWASTE ZERO

From: Shelton, Brad@Waterboards [mailto:Brad.Shelton@waterboards.ca.gov] Sent: Thursday, January 11, 2018 1:36 PMTo: Bryan Clarkson ; Phil Graham Cc: Busby, Robert@Waterboards ; Jain, Vinoo@Waterboards

Subject: Ostrom Road Bryan and Phil, Can you please send us a brief summary of the additional comments necessitating changes that wediscussed via phone today? This will provide us with a record of the conversation. By the way, here is the reference to the monthly leachate volume requirement we discussed: (h) Leachate Production Rate — After July 18, 1997, for a landfill equipped with an LCRS, the discharger shall note,as a part of each regularly scheduled monitoring report [under Article 1, Subchapter 3, Chapter 3 of this division(§20380 et seq.)], the total volume of leachate collected each month since the previous monitoring report. Thanks, Brad Shelton, P.G.Senior Engineering Geologist

Title 27 and Mining Unit ManagerCentral Valley Regional Water Quality Control Board11020 Sun Center Drive, Suite 200Rancho Cordova, California 95670Direct: 916-464-1588Cell: 916-225-3800Fax: 916-464-4782