CORRESPONDENCE_2003-2004 - Laserfiche WebLink

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NOTICE OF VIOLATION 2 FOOTHILL SANITARY LANDFILL SAN JOAQUIN COUNTY these releases from the Unit as part of the compliance record; therefore, this is a violation of the following: WDRs, Reporting I.6.c. states: "A comprehensive discussion of the compliance record, and the result of any corrective actions taken or planned which may be needed to bring the Discharger into full compliance with the waste discharge requirements." Adequate reporting of constituents of concern (COCs) impacting the unsaturated zone is supported by WDRs Prohibition A.7. which states: "The discharge shall not cause degradation of the waters of the state by release of waste constituents in soil-pore gas, soil-pore liquid, soil, or other geologic materials outside of the Unit if such waste constituents could migrate to waters of the State; in either the liquid or the gaseous phase, and cause a condition of nuisance, degradation, contamination, or pollution." 2. The Report does not include a map or aerial photograph showing the soil-pore gas monitoring points required by WDRs, Reporting Requirements IA.b. which state: "A map or aerial photograph showing the locations of observation stations, monitoring points, and background monitoring points." 3. Stiff Diagrams were included in Appendix H, but the report did not include an analysis of the diagrams as part of the groundwater evaluation. 4. Sampling and Analysis Plan: Please include the fate of the purged water from each well(i.e., disposal) in cases where the water is presumed clean and when it has been found to contain constituents above background and/or determined to be polluted. 5. The report should include basic background information about the site geology, hydrogeology, hydrology, disposal history, status of each module (i.e., lined or unlined), monitoring points, landfill design, brief description of the liner under each module, identify areas with interim cover or closure caps, and current activities occurring at the facility in order to provide the reader with a complete understanding of the site on a semiannual basis. This information is necessary so members of the public who review these documents have a better understanding of the facility in one, stand-alone report and to assist Regional Board staff to ensure that all necessary information is available for a complete understanding of the facility. The County is welcome to visit the Regional Board to review other similar reports for comparison. The County of San Joaquin representative has stated that they do not agree with the Regional Board's interpretation of Title 27 with regards to our authority over the unsaturated zone. This is evident in the lack of an evaluation of the soil-pore gas data in the Report. The County of San Joaquin is required to comply with all the minimum standards by not only reporting the data, but providing an evaluation of all COCs released from the Unit to the environment in surface water, unsaturated zone, and groundwater. If subsequent reports do not include a complete compliance evaluation, the Regional Board may consider