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Cease and Desist Order R5- 13-XXXX - 3 - San 3 - San Joaquin County Department of Public Works Corral Hollow Sanitary Landfill San Joaquin County cap over the over the areas of refuse identified outside of the landfill footprint. The intent of the Order was to commit the Dischargers to a plan of action such that the waste would be covered during the 2012 construction season. 15. On 30 August 2011, the County and Caltrans signed a Memorandum of Understanding agreeing to allow access to Caltrans property to install the closure cap over both properties in a single project. 16. On 6 October 2011 the County submitted a Final Cover Expansion Design which was intended to satisfy the requirements of the Water Code 13267 Order. However, on 15 March 2012 Board staff issued a Notice of Violation to the County and Caltrans for submitting a cover design that did not meet the performance standard of Title 27. The two parties then committed to submitting a revised design by 25 April 2012. The County anticipated the project would be issued for bid in July 2012 with construction starting in October 2012 and completion by December 2012, which would meet the intent of the Water Code section 13267 Order. 17. On 23 April 2012 the County submitted a revised Final Cover Expansion Design with preliminary schedule showing completion in December 2012. On 31 May 2012 the County submitted a revised Final Cover Expansion Design with a new schedule showing that construction would not be completed until March 2013. 18. In a letter dated 7 July 2012 the Discharger submitted a proposed revised schedule for the construction of the final cover over the refuse encountered outside the extent of the known final cover. The Discharger proposed to begin the construction by spring 2013 and complete the construction by August 2013. The Discharger proposed the change to the construction schedule based on the possibility of the contractor working during the wet season and having to start and stop due to wet site conditions. Board staff neither approved nor denied the County's proposed schedule, but reiterated the need to cover the refuse as soon as possible and that the Discharger could face a potential administrative civil liability for not meeting the closure date of December 2012. 19. WDRs Order R5-2013-0013 requires the Discharger to extend the closure cover over the areas of uncovered refuse by 1 September 2013. The delay in installing the cap over the additional waste has likely increased the generation of landfill gas and the subsequent impacts to groundwater. Corrective Actions to Address Groundwater Impacts 20. In 2001, a landfill gas (LFG) collection system was installed as a corrective action to prevent further VOC impacts to groundwater, as well as to prevent offsite migration of LFG. Thirty-nine LFG extraction wells were installed initially.