CORRESPONDENCE_2017-2018 - Laserfiche WebLink

Home Browse Search

EOM-NO G. BROWN JR. GOVERNOR MATTHEW ROORIOUEZ SECRETARY FOR Water Boards UENVIRONMENTAL PROTECTION Central Valley Regional Water Quality Control Board RECE LIVED JAN i i 2os 8 January 2018 ENWRONWNTALH�TH PminsERVyCES Mr. Taj M. Bahadori, PE Senior Civil Engineer San Joaquin County Public Works, Solid Waste Division 1810 E. Hazelton Avenue Stockton, CA 95201 CONTINUING NOTICE OF VIOLATION, REJECTION OF LETTER RESPONSE TO NOTICE OF VIOLATION, NORTH COUNTY SANITARY LANDFILL, SAN JOAQUIN COUNTY The North County Sanitary Landfill (NCSL) is owned and operated by San Joaquin County Solid Waste Division (Discharger), and is regulated by Waste Discharge Requirements (WDRs) Order R5-2010-0016 for construction, operation, and monitoring of the Class III Landfill. In a letter dated 17 October 2017, staff issued Notice of Violation (NOV)for the First Half 2017' Groundwater and Surface Water Monitoring Report. The October NOV is the second NOV issued since January 2016. Both NOVs outlined the deficiencies of the Detection Monitoring Program (DMP) at NCSL. This letter documents the continuing violation of the WDRs in preparation of further enforcement for not complying with the WDRs, Title 27, or staffs requests to address the DMP deficiencies identified. The 17 October 2017 NOV required the Discharger to submit by 31 October 2017, a brief letter with a location map and well construction detail based on the approved installation work plan of well G-9. The brief letter was to include a proposal to reconstruct wells G-3D, G-6, and background well G-1A to bring the DMP back into compliance. The NOV also requested the Discharger to address the LFG release by proposing to enhance the LFG extraction system by installing,additional LFG extraction wells. In an email dated 6 December 2017, staff requested an update to the NOV dated 17 October 2017 requesting a brief letter addressing the issues outlined in the NOV. On 8 December 2017 the Discharger submitted a letter response to the staff email dated 6 December 2017. In this letter response, the Discharger proposed to reconstruct background well G-1A (G-1 B), G-3D (G- 3E), and G-6 (G-6A). However, due to limited budget remaining in fiscal year 2017/2018, the Discharger only proposes to install well G-3E before July 2018. This is not acceptable because the entire DMP must be in place for the NCSL to comply with the WDRs and Title 27. As stated in the January 2016 and the October 2017 NOVs, the DMP and wells associated with the NCSL are not in compliance with the WDRs or Title 27. Monitoring and Reporting Program R5-2010-0016, Groundwater Monitoring F.3. states: The Discharger shall install, operate and maintain a groundwater detection monitoring system that complies with the applicable provisions of sections 20415 and 20420 of Title 27. Such a system shall be appropriate for KARL E. LONGLEY SCD, P.E., CHAIR I PAMELA C. CREEDON P.E., BCEE, EXECUTIVE OFFICER 11020 Sun Center Drive#200,Rancho Cordova,CA 95670 1 www.waterboards.ca.gov/centralvalley C4 RECYCLED PAPER