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n LJ The goals of the LFG system include: 1. Protection of groundwater against potential impact by LFG; 2. High system reliability; 3. Low system maintenance requirements; 4. Ease of operation; 5. Compatibility with landfill design and closure activities; 6. Compatibility with energy recovery; 7. Compliance with Title 27 requirements for landfill gas control to limit migration; and 8. Compliance with the San Joaquin Valley Air Pollution Control District requirements. Standards of Performance for New Stationary Source Municipal Solid Waste Landfills, 40 CFR Part 60, Subpart WWW (NSPS) require that the County estimate the emissions for the previous year on the anniversary date of the most recent Tier II estimate. If the estimate of emissions submitted at that time indicates that emissions will exceed 50 MMg NMOCs per year due to the placement of refuse in the previous full calendar year, then the County will be required to prepare a plan to control emissions. The emissions estimate incorporating refuse disposed in 2003, submitted in October 2004, indicated that the NMOC emissions were 46.8 Mg per year (Appendix O). However, the NMOC emissions due to the refuse placed in 2004 is estimated to exceed 50 Mg per year. Current landfill gas management practices are described in the facility Gas Management Plan (Appendix P). 6.7. ENVIRONMENTAL MONITORING The current groundwater monitoring system for the landfill is comprised of an up -gradient well (MW -1) and down -gradient wells MW -2R and MW -3 (Plate 5). Due to its location in the Module 1 expansion footprint, MW -2 was abandoned in June 2003 in accordance with standard practices. In addition to the three monitoring wells, a domestic/supply well (LW -1) on the property is included as part of the monitoring and reporting program for the landfill (Waste Discharge Requirements Order No. R5-2003-0020). Foothill Sanitary Landfill Page 36 of 62 Public Works/Solid Waste JTD County of San Joaquin — Revised 10/6/05