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Response to Comments on Ttive WDRs -4- 16 March 2009 <br /> Harney Lane Landfill <br /> San Joaquin County <br /> 6. Groundwater Monitoring Data (Finding 30) <br /> a. Excerpt From Comment —Please consider identifying "sporadic reports of VOCs"as <br /> probable "false positive"results. Also, please note the lack of VOC impact in three out of <br /> four wells. <br /> b. Response — The following language will be added to this finding: <br /> No VOCs have generally been detected in the other three wells at the site, except <br /> for a few sporadically detected in upgradient well MW-1 and reported as probable false <br /> positive results. <br /> 7. Groundwater Quality Trends (Finding 31) <br /> See Item 1 above, 20 February 2009 letter. <br /> 8. LFG Wells (Finding 43) <br /> a. Excerpt From Comment - Much space is devoted to a description of the various <br /> landfill gas wells. It is not clear what use we are to make of this information;perhaps this <br /> information need not be included. <br /> b. Response — The LFG extraction system is an important element of the corrective <br /> action system at the site and should therefore be adequately described in the <br /> WDR findings. This information is relevant as to the extent to which the <br /> Discharger has implemented corrective action at the site. Together with <br /> Attachment C, Finding 43 clearly shows where LFG extraction wells have, and <br /> have not been, installed at the site. No change to WDRs warranted. <br /> 9. Financial Assurances (Findings 47 and 48) <br /> a. Excerpt From Comment - The C11NMB has approved financial assurances for <br /> postclosure maintenance and corrective action. Documentation of this acceptance was <br /> sent by email to RWQCB staff on February 12, 2009. <br /> b. Response — The tentative WDR findings will be clarified to include this <br /> information as follows: <br /> Finding 47 . . . In 1993, the CIWMB approved a Pledge of Revenue <br /> agreement provided by the Discharger to cover the estimated annual cost . <br /> of landfill postclosure maintenance and monitoring. This agreement is still <br /> in effect. . . <br /> Finding 48 ... In January 2009, the CIWMB approved the corrective action <br /> financial assurances mechanism (a Pledge of Revenue)provided by the <br /> Discharger in the amount of the estimated cost estimate ($49,034 per year <br /> over 30 years). <br /> 10. Notice to RWQCB Staff Prior to Sampling (Monitoring Specification 2) <br /> a. Excerpt From Comment - This specification seems to require much coordination for <br /> little benefit. I suggest that the value of this Specification be reconsidered. <br /> b. Response —This is standard language in landfill WDRs intended to give staff <br /> sufficient advance notice Of the monitoring event should staff wish to obtain split <br />