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WASTE DISCHARGE REQUIREMENTS ORDER NO. R5-2003-0049 -7- FORWARD INC. AND ALLIED WASTE INDUSTRIES FOR OPERATION OF FORWARD CLASS II LANDFILL SAN JOAQUIN COUNTY 32. The Board may specify a non-statistical data analysis method pursuant to Section 20080(a)(1) of Title 27. Section 13360(a)(1)of the California Water Code allows the Board to specify requirements to protect underground or surface waters from leakage from a solid waste site,which includes a method to provide the best assurance of determining the earliest possible detection of a release. 33. In order to provide the best assurance of the earliest possible detection of a release of non- naturally occurring waste constituents from a Unit,this Order specifies a non-statistical method for the evaluation of monitoring data. 34. The specified non-statistical method for evaluation of monitoring data provides two criteria (or triggers) for making the determination that there has been a release of non-naturally occurring waste constituents from a Unit. The presence of two non-naturally occurring waste constituents above their respective method detection limit(MDL), or one non-naturally occurring waste constituent detected above its practical quantitation limit(PQL), indicates that a release of waste from a Unit has occurred. Following an indication of a release, verification testing will be conducted to determine whether there has been a release from the Unit, or there is a source of the detected constituents other than the landfill, or the detection was a false detection. Although the detection of one non-naturally occurring waste constituent above its MDL is sufficient to provide for the earliest possible detection of a release, the detection of two non-naturally occurring waste constituents above the MDL as a trigger is appropriate due to the higher risk of false-positive analytical results and the corresponding increase in sampling and analytical expenses from the use of one non- naturally occurring waste constituent above its MDL as a trigger. GROUNDWATER DEGRADATION 35. Significant VOC impacts to groundwater including but not limited to dichloroethane, dichloroethylene,tetrachloroethylene, and trichloroethylene are associated with the old Austin Road Landfill,now the north Unit at Forward landfill. Impacts were initially detected in 1989,by 1991 evaluation monitoring determined that chlorinated hydrocarbons impacts extended as far as 1,000 feet down-gradient from the Austin Road landfill. A corrective action was approved in 1991,by 1998 it was apparent that the initial corrective actions had failed to remediate the groundwater impacts. In June 2002 the Board adopted Order No. R5- 2002-0121 to implement revised corrective actions and remediate groundwater impacts. All outstanding corrective active provisions adopted in the previous order are continued in this order. 36. The old Forward Landfill has a history of sporadic, low concentration detections of VOCs in groundwater since monitoring began in 1987. VOCs have most commonly been detected in the northeast corner of the old Forward Landfill site. The most frequently detected VOCs are: benzene, cis-1,2-dichloroethene,tetrachloroethene, toluene, 1,1-dichloroethane, and