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d <br /> tT <br /> la EDMUND G.BROWN JR. <br /> OOVEflNOR <br /> RA6IFOW N/A MATTHEW RODRIQUEZ <br /> TARY <br /> Water ars RTAR SECREFOR <br /> ENVSAL PROTECTION <br /> Central Valley Regional Water Quality Control Board <br /> 20 June 2016 REC'PIVED <br /> Mr. Taj M. Bahadori, PE JUN I <br /> 2016 <br /> Senior Civil Engineer VfR0 ^f <br /> San Joaquin County Public Works, Solid Waste Division °��R111',36TA <br /> ! CTS <br /> 1810 E. Hazelton Avenue G� <br /> Stockton, CA 95201 <br /> REVIEW OF REVISED WATER QUALITY PROTECTION STANDARD REPORT, FOOTHILL <br /> SANITARY LANDFILL, SAN JOAQUIN COUNTY <br /> The Foothill Sanitary Landfill is owned by San Joaquin County Department of Public Works and <br /> operated by Foothill Landfill Inc. (hereinafter jointly known as Discharger) and is regulated by <br /> Waste Discharge Requirements (WDRs) Order R5-2015-0058 and Cleanup and Abatement <br /> Order R5-2004-0706. The WDRs requires the Discharger to submit a Water Quality Protection <br /> Standard (WQPS) Report by 31 January 2016, which was submitted on 27 January 2016. Staff <br /> issued a Notice of Violation (NOV) on 10 February 2016 because the report was incomplete. <br /> The NOV required the Discharger to resubmit the WQPS report with a complete analysis for <br /> establishing concentration limits. The Discharger resubmitted the WQPS report on 9 March <br /> 2016. Staff cannot approve the Revised Water Quality Protection Standard Report dated 9 <br /> March 2016 at this time. Staff s comments are below. <br /> Groundwater <br /> Both LF-1 and LF-2 utilize the same background groundwater monitoring well MW-4 to define <br /> background conditions. Statistical analysis will be defined by the Tolerance interval Method, <br /> which complies with the WDRs, where concentration limits are developed from data collected <br /> from well MW-4. <br /> Vadose zone <br /> For the unsaturated zone the Discharger has proposed to utilize suction lysimeters and pan <br /> lysimeters to develop the WQPS for this interval. Vadose zone samples collected have been <br /> limited. If soil water pore fluid can be collected from the lysimters, the Discharger proposes to <br /> evaluate the data using the inter-point tolerance limit method to determine inorganic <br /> concentration limits. The WQPS Report does not discuss the inter-point tolerance limit method. <br /> The WQPS must use a method outlined in Title 27 to comply with the WDRs. <br /> Surface Water <br /> According to the WQPS Report, limited data exists to develop concentration limits for surface <br /> water. The Discharger shall make every effort to collect liquid samples from both the surface <br /> water locations to develop concentration limits. In the interim, for surface water, the Discharger <br /> proposes to assess surface water concentrations when sufficient flow between SW-1 (up- <br /> stream) and SW-2 (down-stream) enable sampling. Direct comparison between SW-1 and <br /> SW-2 samples will be performed to determine if a release to surface water has occurred. If <br /> SW-2 has a 10% or greater inorganic constituent concentration, then a release is indicated. <br /> Staff concurs with this interim approach. <br /> KARL E. LONGLEY SCD, P.E., CHAIR I PAMELA C. CREEDON P.E., BCEE, EXECUTIVE OFFICER <br /> 11020 Sun Center Drive 5200,Rancho Cordova,CA 95670 1 www.waterboards.ca.gov/centralvalley <br /> �a RECYCLED PAPER <br />