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e EDMUND G.BROWN JR. .v � GOVERNOR CALIFC NNIA MATTHEW OORIOUEZ SECRETARY IIFOR ENVIRONMENTAL PROTECTION Water Boards Central Valley Regional Water Quality Control Board RECEIVED 9 October 2018 T 1 ENVIRONMENTAL H E LT DEPARTMENT Mr. Taj M. Bahadori, PE Senior Civil Engineer San Joaquin County Public Works, Solid Waste Division 1810 E. Hazelton Avenue Stockton, CA 95201 NOTICE OF VIOLATION, REVIEW OF WORK PLAN FOR THE DETECTION OF FLUID AT LYSIMETER LZ-4, FOOTHILL SANITARY LANDFILL, SAN✓OAQU►N COUNTY The Foothill Sanitary Landfill is owned by San Joaquin County and operated by Foothill Sanitary Landfill, Inc., (hereafter Discharger). The Foothill Sanitary Landfill is regulated by Waste Discharge Requirements (WDRs) Order R5-2015-0058. The work plan reviewed was submitted following the detection of liquids within suction lysimeter LZ-4, which is part of the vadose zone monitoring system at Foothill Sanitary Landfill. Liquids with volatile organic compounds (VOCs) detected in suction lysimeters installed below the liner system of LF-2 is a release from the waste management unit (WMU), which is a violation of the WDRs. During the second semester 2018 monitoring and sampling event, liquids were collected from lysimeter LZ-4 and analyzed for VOCs. Ten (10) VOCs were detected above the method detection limit triggering notification to the Water Board. After the initial sample results, the Discharger notified staff of the liquid sample collected and proposed to collect the verification sample. In an email dated 13 August 2018, staff concurred with the verification sampling and their proposal to initiate an Evaluation Monitoring Program (EMP) to characterize the release if additional liquid was collected. However, staff stipulated that a work plan outlining the EMP approach was required to be submitted. On 6 September 2018, lysimeter LZ-4 was monitored for liquids to verify the prior event. Liquids were available for sample collection and submitted for laboratory analysis of VOCs. Six (6) VOCs of the 10 detected in the first sample were confirmed. Consequently the work plan was submitted as a result of the verification sampling and results and the Discharger's requirement to expand this investigation in accordance with Title 27, section 20425. The presence of liquid in the lysimeter is a violation of the WDRs, indicates a release, and requires corrective action. Staff has reviewed and evaluated the work plan and proposed EMP. The EMP work plan offers no substantial characterization work to define the nature and extent of the release and thus, does not meet the intent of Title 27, section 20425. The proposed actions described in the work plan are essentially, the same requirements of MRP KARL E. LONGLEY SCD, P.E., CHAIR I PATRICK PULUPA, ESO., EXECUTIVE OFFICER 11020 Sun Center Drive#200,Rancho Cordova,CA 95870 1 www.waterboards.ca.gov/centralvalley Z'@ RECYCLED PAPER