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t e STAFF REPORT ADMININSTRATIVE CIVIL LIABILITY ORDER FOR COUNTY OF SAN JOAQUIN AND FOOTHILL SAiNITARY LANDFILL, INC. FOOTHILL SANITARY LANDFILL SAN JOAQUIN COUNTY INTRODUCTION The County of San Joaquin owns and Foothill Sanitary Landfill Inc. (hereafter Discharger) operates the Foothill Sanitary Landfill. The facility is a municipal solid waste landfill' (Class III) about 1 mile south of Shelton Road east of Lodi, San Joaquin County. The landfill is regulated under Waste Discharge Requirements (WDRs) Order No. R5-2003-0020 for Construction, Operation, Closure and Evaluation Monitoring. The facility is comprised of an 800-acre parcel containing a single Waste Management Unit (Unit). This Unit is comprised of two areas: LF-1 and LF-2. LF-1 contains a single, unlined module (referred to as "Module I"), covering approximately 83 acres. Monitoring results indicate that landfill gas (e.g., volatile organic compounds) from the unlined Module "I" has impacted groundwater and the unsaturated zone. LF-2 is currently being expanded with an approved liner system. The Executive Officer issued Administrative Civil Liability Complaint (ACLC) Order No. R5-2003- 0519 because the Discharger failed to submit an adequate closure plan for Module"I" in compliance with specifications set forth in WDRs and the minimum requirements of Title 27, California Code of Regulations (Title 27). Prior to the ACLC Order, the Executive Officer required the Discharger submit technical reports pursuant to California Water Code (CWC) Section 13267. The Discharger failed to submit the reports. The Discharger has since asked that the Regional Board hear the issue. REGULATORY OVERVIEW Volitile organic compounds (VOCs) as LFG have been detected and confirmed in groundwater since 1997. Subsequently, The Discharger submitted several incomplete Evaluation Monitoring Plans designed to delineate the nature and extent of the release to groundwater and the unsaturated zone as required by WDRs and Title 27, Section 20385(2). Section 20385(2) requires the discharger institute an evaluation monitoring program whenever there is "measurably significant'2 evidence of a release from the Unit during a detection monitoring program. In this case, VOCs were detected and confirmed by performing a discrete retest (i.e., resample groundwater from the impacted well) as required in WDRs and Title 27. Therefore, the Discharger met the test by confirming that the landfill has released constituents of concern3 (COCs) to the environment. 1 Title 27, Section 20164: "Waste management unit"or"Unit"means an area of land,or a portion of a waste management facility, at which waste is discharged.The term includes containment features and ancillary features for precipitation and drainage control and for monitoring. ' Title 27, Section 20164: "Measurably significant"means a change in the Monitoring Point data that,relative to the reference background value(or other approved reference value or distribution), is sufficient to indicate that a release has occurred,pursuant to the applicable data analysis method(including its corresponding trigger). s Title 27, Section 20164: "Constituent(s) of concern"or"COC(s)"means any waste constituent(s), reaction product(s), and hazardous constituent(s)that is reasonably expected to be in or derived from waste contained in a waste management unit.