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STAFF REPORT 3 COUNTY OF SAN JOAQUIN AND FOOTHILL SANITARY LANDFILL,INC. SAN JOAQUIN COUNTY procedure would be applied to all future modules until final closure in the year 2050. Furthermore, there is no gas collection and control system at the facility. Financial Assurances: Required closure of Module "I"is considered a corrective action measure. WDRs require the Discharger provide the financial assurance for initiating and completing corrective action. The assurances of financial responsibility shall provide that funds for corrective action shall be available to the Regional Board upon the issuance of any order under California Water Code, Division 7, Chapter 5. By letter dated 2 May 2003, the Discharger submitted Financial Assurances for Closure, Post-Closure Maintenance, and Corrective Action at County-Owned Landfills. It states that funding for corrective action will be provided by Certificates of Participation, scheduled to be issued before 27 May 2003. Coverage is afforded at $1 million per occurrence with a$1 million annual aggregate within the San Joaquin County Self-Insurance Trust Fund. WDRs also require financial assurance for closure and postclosure maintenance. The assurances of financial responsibility shall provide that funds for closure and postclosure maintenance shall be available to the Regional Board upon the issuance of any order under California Water Code, Division 7, Chapter 5. The Discharger shall adjust the cost annually to account for inflation and any changes in facility design, construction, or operation. The estimated total closure amount is $3,603,638 for the Foothill Sanitary Landfill. The balance of funds as of 15 December is $2,252,223.50. Funds are accumulating at S0.66/ton. Full funding is anticipated to occur in 2011 with a disposal rate of 300,000 tons/yr. Enforcement: On 1 June 2003, the Discharger failed to submit the required documents pursuant to WDRs. On 11 June 2003, the Discharger submitted a request for a revised schedule with a proposed extension of ten weeks, to 11 August 2003. The Discharger exceeded this date without submittal of the required documents. On 16 September 2003, the Regional Board sent a CWC 13267 letter requesting the subject documents be submitted by 1 November 2003. On 1 October 2003, the Discharger submitted a report titled Results of Evaluation Monitoring Program (EMP) which showed that two temporary exploration borings as TB-1 and TB-2 did not detect VOCs in groundwater during the one-time sampling event. Recognizing the possibility that contamination could be detected in the unsaturated zone, a sample of soil gas was collected from deep beneath the surface, near the groundwater table at SG-l. Results of SG-1 showed high levels of VOCs as Freon 12, vinyl chloride, toluene and 4-methly-2-pentanone. A sample of landfill gas (LFG) was also collected from the refuse for comparison with the soil gas collected at SG-1. LFG collected within the waste pile included high levels of Freon 12, TCE, and 13 other VOCs. The Discharger stated that, "We believe that past detections were the result of a transitory increase in LFG production due to ponding at the edge of the landfill adjacent to MW-3. If so, then the grading to correct this ponding several years ago was the "corrective action" needed." The County's proposal describes, "Planned enhancement of soil cover at the site and continuing maintenance of drainage facilities which comply with the Waste Discharge Requirements and Title 27, Section §20365 will increase assurance that