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WASTE DISCHARGE REQUIREMENTS ORDER NO. R5-2014-0006 -14- FORWARD INC.AND REPUBLIC SERVICES INC. FORWARD CLASS II LANDFILL SAN JOAQUIN COUNTY waste constituents above their respective method detection limit (MDL), or one non-naturally occurring waste constituent detected above its practical quantitation limit (PQL) [a.k.a., laboratory reporting limit (RL)], indicates that a release of waste from a Unit has occurred. Following an indication of a release, verification testing must be conducted to determine whether there has been a release from the landfill unit or the detection was a false detection. 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. 55.For a naturally occurring constituent of concern, the Title 27 requires concentration limits for each constituent of concern be determined as follows: a. By calculation in accordance with a statistical method pursuant to Title 27, section 20415(e)(8); or b. By an alternate statistical method meeting the requirements of Title 27, section 20415(e)(8)(E). 56.The Discharger submitted an October 2011 Concentration Limit Update (CLU) report proposing statistical data analysis methods to calculate new or revised concentration limits for each monitored constituent in accordance with Title 27. The CLU report proposed to use intrawell data analysis to calculate tolerance limits for the monitored constituents. The CLU and approved data evaluation methods are included in MRP No. R5-2014-0006. GROUNDWATER DEGRADATION AND CORRECTIVE ACTION 57.Groundwater down-gradient of the old Austin Road Unit is impacted with dichloroethane, dichloroethylene, tetrachloroethylene, and trichloroethylene. VOC impacts were detected in 1989 and by 1991 evaluation monitoring determined that chlorinated hydrocarbon impacts extended as far as 1,000 feet down-gradient of the landfill. A corrective action plan was approved for implementation in August 1991. The plan consisted of a load checking program; extraction and treatment of impacted groundwater from two wells; and continued monitoring of the effectiveness of corrective action. 58.In 1998 corrective action monitoring determined that the initial corrective actions had failed to contain groundwater contamination or remediate groundwater impacts. In April 1999, the City of Stockton (previous discharger) submitted a Draft Engineering Feasibility Study (EFS) for an improved corrective action plan. Staff determined that the Draft EFS was inadequate and requested changes. On 3 September 2000, ownership of Austin Road landfill was transferred to Forward Inc. The new Owner submitted a revised EFS on 11 June 2001 and revised in response to comments on 30 August 2001; a Time Schedule for Corrective Action was issued 13 December 2001; and the Discharger submitted an Evaluation Procedures for Proposed Corrective Action on 26 February 2002. The resulting corrective action plan, includes the following activities: