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THOMAS R. FLINN P.0.BOX 1810-1810 E.HAZELTON AVENUE _,l� t STOCKTON,CALIFORNIA 95201 DIRECTOR [ o (209)468-3000 FAX(209)468-2999 cqt;F O R�`P www.sjgov.org/pubworks THOMAS M.GAU t� CHIEF DEPUTY DIRECTOR E �E�R /70 MANUEL SOLORIO for YOU In DEPUTY DIRECTOR STEVEN WINKLER UG 1 0 2009 DEPUTY DIRECTOR ftp pNMHEALTH ROGER JANES VI OEN Y i' BUSINESS ADMINISTRATOR August 3, 2009 PER IFF/SERVICE Mr. Todd Del Frate, PG California Regional Water Quality Control Board 11020 Sun Center Drive, #200 Rancho Cordova, California 95670 SUBJECT: EVALUATION MONITORING PLAN ALTERNATIVE, HARNEY LANE LANDFILL Dear Mr. Del Frate: f I " This is submitted in compliance to the requirement that an Evaluation Monitoring Plan be submitted by August 11, 2009, as stated in your letter dated May 11, 2009. Two volatile organic compounds (Benzene and Toluene) have been detected at low levels at groundwater monitoring wells MW-2 and MW-4; however, their presence does not appear to threaten health and safety at this time. Each of these compounds is below the drinking water standard at the monitoring well and these compounds were not found at either of the other two landfill groundwater monitoring wells or at any of the four domestic water wells near the landfill (Figure 1). In fact, the wells near the landfill appear to be free of VOCs or other indications of landfill impact(analyses attached). We estimate the cost to evaluate the "extent of the plume"to be over$180,000, including investigating the presence of VOCs in groundwater on other's property(if we are allowed access) and installing additional LFG extraction wells. The benefit gained by this expenditure is questionable at best, as the VOCs in the groundwater at the landfill are within drinking water standards, and surrounding drinking water wells are not affected. With a high cost and little or no benefit, such a project appears economically infeasible, and the County could request Concentration Limits Greater than Background (CLGB) in accordance with Title 27 Section 20400. Additional monitoring would be more appropriate if we now were in detection monitoring and detected a new release. However, we are presently in corrective action, and our resources could be better applied to increasing the corrective action effort in accordance with Section 20430(i). I believe this was the conclusion reached and approach identified in our most recent conversation, and that the following actions by the County would be acceptable in lieu of Evaluation Monitoring Program and Engineering Feasibility Study: 1. Analyze the domestic drinking water at the Migrant Labor Housing facility to verify lack of impact. This analysis will include general water quality parameters and VOCs per ASTM Method 8260. 2. Install four additional LFG extraction wells, two each in the general vicinity of groundwater monitoring wells MW-2 and MW-4 (Figure 1). These wells will penetrate through the base of the landfill, and will be designed to collect maximum gas from the soil beneath the landfill. The location of these wells will be coordinated with existing wells. Each well will be provided with control port and sampling valve.