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State of California California Environmental Protection Agency MEMORANDUM Date: October 14,2008 To: Ms. Christine Karl, Waste Management Specialist MSW Facilities&EA Inspections&Enforcement Section From: Mica . Wochnick, P.E., Supervisor Closure and Technical Support Section CALIFORNIA INTEGRATED WASTE MANAGEMENT BOARD REQUEST FOR ADDITIONAL INFORMATION-LANDFILL PERIMETER GAS MIGRATION MONITORING PLAN- FOOTHILL SANITARY LANDFILL-SAN JOAQUIN COUNTY,SWIS#39-AA-0004 California Integrated Waste Management Board(CIWMB) staff has received the Perimeter Gas Migration Monitoring Plan(Plan)for the Foothill Sanitary Landfill(FSL). The Plan is dated September 15, 2008,and was prepared by the County of San Joaquin as the operator of the landfill. The Plan was submitted to provide for the landfill gas monitoring requirements as outlined in Title 27 of the California Code of Regulations, Sections 20917 through 20939(27 CCR, §20917 - §20939). County of San Joaquin Local Enforcement Agency(LEA)has requested a concurrent review of the Plan. FSL is a Class III Waste Management Unit located in eastern San Joaquin County. It is 800 acres in size of which approximately 674 acres are permitted for refuse fill activities. FSL accepts commercial and household waste as well as agriculture and construction/demolition waste. The operator is proposing to utilize one of its existing landfill gas wells(SG-12)which had been installed in June 2004 in accordance with the regulation in place at that time(depth of waste within 1,000 feet). Based on Closure staff review of the Plan, CIWMB cannot agree with the recommendation made in the Plan since the Plan does not include information demonstrating that the depth of the existing gas well SG- 12 is adequate to monitor for migrating landfill gas. Staff suggests the following option not in any specific order: 1. The operator can demonstrate that the current depth to which SG-12 has been installed is adequate. Such demonstration shall be in accordance with 27 CCR§20925(c)(2)and shall demonstrate that SG-12 installed to a depth of 40 feet above the bottom of the waste is sufficient to detect migrating landfill gas and provide protection to public health and safety and the environment. 2. The operator may be able to reconfigure the location of the proposed landfill gas wells so that SG- 12 would not be necessary to meet the maximum 1,000 feet spacing standard. 3. The operator could choose to replace SG-12 with a new gas well installed to the depth of waste. Additional information is therefore necessary and required for well SG-12 for CIWMB staff to agree with the proposed landfill gas plan. Please note that the remainder of the Plan as proposed is acceptable. Should you have any questions regarding this matter,please contact Gino Yekta of my staff at(916) 341-6354.