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California Regional Water Quality cloontrol Board Central Valley Region ; Robert Schneider,Chair Winston H.Hickox Gray Davis Secretary for Sacramento Main Office Governor Environmental Internet Address: http://www.swrcb.ca.gov/rwgcb5 Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 Phone(916)255-3000•FAX(916)255-3015 2 April 2001 Mr. Michael Kalish County of San Joaquin Department of Public Works P.O. Box 1810 Stockton, CA 95201 CORRECTIVE A CTION MEASURE FOR VOCIMPACTS TO SHALLOW GROUNDWATER, CORRAL HOLLOW SANITARYLANDFILL,SAN JOA QUIN COUNTY(CASE NO. 18967) The Regional Board has received the county's amended Application for Waste Discharge Requirements, dated 23 March 2001 indicating that the county will conduct corrective action for the VOC impacts to shallow groundwater at monitoring well MW-5. The county has proposed landfill gas extraction as a corrective action measure as demonstrated in their submittal of August 2000. Your submittal of 27 March 2001 includes a detailed description of the landfill gas extraction system that is being installed at the facility. I am drafting Tentative Waste Discharge Requirements and will incorporate the information you have provided. Water Quality Protection Standards Concentration Limits were set previously for Corral Hollow in accordance with CCR Title 27 §20390 and §20400, using non-detect for organic constituents and a statistical evaluation for inorganic constituents. Your letter proposed that a new standard should be set at the drinking water standard for each constituent for corrective action monitoring. Your letter does not provide details,but appears to propose this revised standard for all the monitoring wells at the facility. The standards proposed by the county are concentration limits greater than background(CLGB) and are not approved at this time. In accordance with Title 27 §20430, the water standards for the corrective action program shall be adopted under §20390, or for a CLGB, §20400. Section 20390 also states that separate program-specific water standards may be established when detection monitoring and a corrective action program are conducted concurrently. The Regional Board cannot establish a CLGB. unless it finds that it is technically or economically infeasible to achieve the background value for that constituent and that the constituent will not pose a substantial present or potential hazard to human health or the environment as long as the CLGB is not exceeded. In making this finding, the RWQCB shall consider the factors specified in §20400(d), the results of the engineering feasibility study submitted pursuant to f20425(c), data submitted by the discharger pursuant to $20425(4)(2)to support the proposed CLGB,public testimony on the proposal, and any additional data obtained during the evaluation monitoring program. While the county may wish to have the Regional Board consider CLGBs for the corrective action monitoring at well MW-5, adequate demonstration for that determination has not been provided at this time. Therefore, in the revision of the WDRs,the concentration limits will not be changed, however the Board will make a provision allowing the county California Environmental Protection Agency 00 Recycled Paper The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at http://www.swreb.ca.gov/rwgcb5