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North Count Sanitary Lan , -2 - 8 January 2018 <br /> Y Y rY <br /> San Joaquin County <br /> detecting, at the earliest possible time, a release to groundwater from the Unit. Detection <br /> monitoring (and any evaluation and/or corrective action monitoring required in the event of a <br /> release) shall be conducted in compliance with the WDR Monitoring Specifications E.1 through <br /> 33, as applicable. <br /> As stated above, the NCSL DMP does not meet the intent of Groundwater Monitoring F.3., or <br /> Title 27 sections 20415 or 20420. Non-compliance with the WDRs or Title 27 is a condition that <br /> may result in further enforcement if appropriate actions by the Discharger are not taken in an <br /> appropriate time frame. As such, the Response to NOV dated 8 December 2017 is inadequate. <br /> In Summary <br /> The Discharger has been granted the time they asked for to determine if groundwater levels <br /> have or will rebound and to install/deepen wells accordingly. However, with the installation of <br /> G-7 and G-8 the groundwater flow model has changed and new well locations for background <br /> and down gradient, point of compliance wells are required. Until the entire groundwater <br /> monitoring network has been installed and accepted as being compliant, waste can no longer <br /> be placed into Area 5B or any future cell. <br /> As stated above, staff considers the response to the 17 October 2017 NOV to be materially <br /> deficient. To return to compliance with the WDRs, the groundwater monitoring network must be <br /> compliant. Therefore, by 1 February 2018 the Discharger shall submit a work plan that <br /> complies with the requirements outlined in the 17 October 2017 NOV. <br /> Finally, upon receipt of this letter all waste discharges into Area 5B must cease. All waste in <br /> Area 5B must be covered with daily/interim cover depending on the Discharger's expectation <br /> have a compliant DMP in place and approved by staff. <br /> If you have any questions or would like to meet to discuss, please contact Todd Del Frate at <br /> 916-464-4737 or email him at tdelfrate@waterboards.ca.gov. <br /> P <br /> HOWARD HOLD, P.G. <br /> Acting Supervisor <br /> Compliance and Enforcement Section <br /> cc: Robert McClellon, San Joaquin County Environmental Health <br />