CORRESPONDENCE_2007 (1/07 - 6/07)

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CaliforniikRegional Water Quality C trol Board Central Valley Region - Karl E.Longley,ScD,P.E.,Chair Linda S.Adams Arnold Secretafor Sacramento Main Office Schwarzenegger 11020 Sun Center Drive#200,Rancho Cordova,California 95670-6114 Environmental Phone(916)464-3291 •FAX(916)464-4645 Governor Protection hilp://www.waterboards.ca.gov/centralvalley Ece, J�I 5 February 2007 L 207 W. Michael Carroll ENVIRON TENT HEALTH San Joaquin County Dept. of Public Works PE M'T/SE VICES Solid Waste Division P.O. Box 1810 Stockton, CA REVIEW OF PROPOSED INCREASE OF CORRECTIVE ACTION, CORRAL HOLLOW SANITARY LANDFILL, SAN JOAQUIN COUNTY The Regional Water Quality Control Board (Regional Water Board) staff issued a Notice of Violation (NOV) dated 7 December 2006 for violating Waste Discharge Requirement (WDRs) Order No. 5-01-176. The NOV requested the Discharger initiate an Evaluation Monitoring Program (EMP) and prepare a work plan to delineate the lateral and vertical extent of the release of pollutants in the vadose zone and groundwater by 22 January 2007. A work plan to evaluate the lateral and vertical extent of the release was not submitted; instead a report called Increase of Corrective Action was submitted. The NOV was issued and the work plan requested based on a review of the 2nd and 3rd quarter 2006 groundwater monitoring data for the Corral Hollow Sanitary Landfill (CHSL). These quarterly reports continue to show elevated levels of gas in the vadose zone and increasing trends of volatile organic constituents (VOCs), and chloride in groundwater. Based on this data, staff has determined that the current corrective action (LFG system) is not effectively controlling LFG or mitigating the groundwater impacts. Because of the increasing trends in pollutants in groundwater further delineation of the lateral and vertical extent of LFG and groundwater is required, especially north-northeast of the landfill Staff is concerned that groundwater quality will continue to be affected by increasing VOC concentrations, as historical data suggests, and that installing an engineered solution alone without knowing extent or severity of the pollution will usually result in an inadequate remedial design and possibly further degradation to groundwater quality. The reports should provide the necessary data to define the lateral and vertical extent of LFG and to design the appropriate corrective action to control and prevent further releases to the vadose zone and groundwater, and to remediate the groundwater plume. The following technical reports are requested to ensure compliance with the Waste Discharge Requirements. The Discharger shall submit the technical reports in accordance with the following schedule. Please note the first document due date was agreed upon during the 31 January 2007 meeting between Regional Water Board and County of San Joaquin staff. California Environmental Protection Agency �a Recycled Paper