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STATE OF CALIFORNIA - Environmental PI CALIFORNIA REGIONAL WATER QUALITY CONTROL CENTRAL VALLEY REGION 3443 Routier Road, Suite A Sacramento, CA 95827-3098 PHONE: (916) 255-3000 FAX: (916) 255-3015 23 February 1995 Stephen Chen Department of Public Works City of Stockton 425 N. El Dorado Street Stockton, CA 95202-1997 PETE CITY OF STOCKTONA USTIN ROAD LANDFILL, SAN JOAQUIN COUNTY (Case No. 2148) Waste Discharge Requirements, Regional Board Order No. 90-122 required the City of Stockton to begin operation of a ground water remediation project by 1 March 1992. The City has never fully complied with this requirement. Order No. 90-122 was rescinded on 28 October 1994 by Order No. 94- 303. Order No. 94-303 does not contain a specific requirement to operate a ground water remediation project because at the time that Order No. 94-303 was adopted we were under the impression that the ground water treatment system was up and running. Based on our inspection of the site on 20 December 1994, and discussions with staff at the San Joaquin County Public Health Services, we understand that the ground water remediation project is not functioning near the proposed treatment rate of 300 gallons per minute. Although failure to implement ground water remediation is not a specific violation of current waste discharge requirements, it can be a violation of Title 23, California Code of Regulations, Division 3, Chapter 15 because the City has substantially deviated from its proposed corrective action program submitted for compliance with Chapter 15. On 17 August 1994 we asked the City of Stockton to immediately sample an agricultural well and two supply wells at houses east of Austin Road. While the City made some inquiries regarding one of these wells, we have no record that the City completed any sampling at these wells. What is the current status of this sampling? In a letter dated 30 August 1994, we noted our concerns that there are no clean monitoring wells between the landfill and the three supply wells we requested to be sampled. Since these wells apparently have not been sampled, the City of Stockton is in violation of Chapter 15, Section 2550.9 which requires the discharger to define the nature and extent of the plume. The City of Stockton is also in violation of Regional Board Order No. 92-143, NPDES No. CA0082911, which regulates discharge to surface water from the landfill's ground water treatment system. No monitoring reports have been submitted during 1994, which is a violation of Monitoring and Reporting Program No. 92-143. Order No. 92-143 requires the City to submit an annual report by 30 January of each year on the effectiveness and progress of the ground water cleanup. This report must indicate whether the contaminant plume is being captured or is continuing to spread. The annual report shall also include the reasons for and duration of all interruptions in the operation of the treatment systems. These reports have not been received.