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WASTE DISCHARGE REQUIREMENTS ORDER NO. R5-2014-0006 -13- FORWARD INC.AND REPUBLIC SERVICES INC. FORWARD CLASS II LANDFILL SAN JOAQUIN COUNTY incorporated into a regular monitoring program as part of a revised MRP. The Discharger's detection monitoring program for groundwater at the landfill satisfies the requirements contained in Title 27. 51.The existing unsaturated zone monitoring system for the landfill consists of: Unit Monitored Type Monitoring Points F — North Suction E-1, E-2, W-1, W-2 F — West Suction LY-Pond-N, LY-Pond-S Background Suction LY-BG-1 Forward Suction LY-A, LY-E1A, LY-E1B, LY-E2A, LY-E2B, D93A, D93B Austin Road Suction FU-03, FU-04W, FU-04E, FU-05, FU-06 Forward Pan D-01 S, D-01 N, D-02 Austin Road Pan FU-03, FU-04W, FU-04E, FU-05, FU-06 Landfill units built after 2001 are constructed with pan lysimeters below the landfill sump as a final check of the integrity of the base liner. New landfill units at Austin Road have a suction lysimeter in addition to the pan lysimeter. In recent years, lysimeters at new units have not been sampled on a regular basis. This Order requires quarterly monitoring of all currently existing and any future lysimeters if liquid is present. 52.Volatile organic compounds (VOCs) are often detected in a release from a MSW landfill and are often associated with releases of landfill gas rather than leachate. Since volatile organic compounds are not naturally occurring and thus have no background value, they are not amenable to the statistical analysis procedures contained in Title 27 for the determination of a release of wastes from a landfill unit. Title 27, sections 20415(e)(8) and (9) allows the use of a non-statistical evaluation of monitoring data that will provide the best assurance of the earliest possible detection of a release from a landfill unit in accordance with Title 27, sections 20415(b)(1)(13)2.4. However, Title 27 does not specify a specific method for non- statistical evaluation of monitoring data. 53.The Central Valley Water Board may specify a non-statistical data analysis method pursuant to Title 27, section 20080(x)(1). Water Code section 13360(a)(1) allows the Central Valley Water Board to specify requirements to protect groundwater 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. 54.In order to provide the best assurance of the earliest possible detection of a release of non- naturally occurring waste constituents from a landfill unit, the SPRRs specify a non-statistical method for the evaluation of monitoring data for non-naturally occurring compounds. 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 landfill unit. The presence of two non-naturally occurring