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1 <br /> a <br /> Mr. Horton <br /> Page 6 <br /> r <br /> leachate in accordance with 14 CCR 17781 (a) (2) . Sampling <br /> must occur quarterly at the time of ground water sampling <br /> [14 CCR 17781 (b) (2) ] . Ground water samples must be analyzed <br /> for the chemical parameters listed in Appendix 1 of <br /> Article 7 . 8 as well as those specified in Waste Discharge <br /> Order #87-088 [14 CCR 17781 (d) (5) ] . All costs associated <br /> with leachate monitoring must be included in the postclosure <br /> maintenance cost estimates. The postclosure maintenance <br /> plan must state that the Plans will be revised to account <br /> for verification monitoring and corrective action activities <br /> and associated costs should they become necessary. <br /> 4 . 14 CCR 17783 - Gas Monitoring and Control During Closure and <br /> Postclosure. The revised Plans do not address the <br /> monitoring of off-site structures for methane gas in <br /> accordance with Title 14 , California Code of Regulations (14 <br /> CCR) , Division 7 , Chapter 3 , Article 7 . 8, section <br /> 17783 (a) (2) . The operator has agreed to monitor the <br /> buildings at the adjacent farm labor camp for methane and <br /> selected volatile organic compounds (VOCs) . Preliminary <br /> results for the first such event were received on March 12, <br /> 1992 . Additional monitoring will be required for both the <br /> closure and postclosure maintenance periods. A description <br /> of these monitoring activities and the associated costs must <br /> be included in both the closure and postclosure maintenance <br /> plans. <br /> Data from the first two sampling events of the perimeter gas <br /> monitoring network indicate the presence of methane gas in <br /> excess of compliance levels at the facility boundary [14 CCR <br /> 17783 (a) ] . It now appears that a gas control system will be <br /> necessary pursuant to 14 CCR 17783 . 15 (x) (5) . The revised <br /> Plans must include the specifics of a gas control system and <br /> associated costs. <br /> Why is it that two of the existing gas probes that were <br /> scheduled for decommissioning could not be located and hence <br /> were not destroyed? Please advise the LEA and Board of the <br /> status of this issue. <br /> 5 . 14 CCR 18264.3 (a) (3) (E) & (F) - A program to maintain and <br /> inspect the gas monitoring network and gas control systems <br /> and groundwater monitoring network. Please elaborate on the <br /> gas and ground water monitoring and control postclosure <br /> maintenance activities pursuant to 14 CCR sections 17783 and <br /> 17782 , respectively. <br /> 6 . 14 CCR 18270 (b) - Evaluation of Closure and Postclosure <br /> Maintenance Plans, 14 CCR 18271 (b) . Approval of Closure and <br /> Postclosure Maintenance Plans. San Joaquin County <br /> Environmental Health Division did not receive a letter of <br /> California Environmental Quality Act (CEQA) compliance from <br /> the Governor's Office of Planning and Research referenced in <br /> response to comment #30 in the January 28, 1992 , letter to <br /> the Board from Mr. Tom Horton (operator) . Also, item #3 of <br /> the Notice of Determination for this project states that <br />