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i Foothill Sanitary Landfill - 2 - 20 June 2016 San Joaquin County Constituents of Concern Anthropogenic compound concentration limits for groundwater, surface water, and vadose zone monitoring will be the method detection limit (MDLs) as outlined in the WDRs. Inorganic data from wells will be evaluated using the interwell tolerance limit method based on data collected from background well MW-4. The Discharger has proposed criteria for tentatively identifying a release of inorganics. The criteria proposed are valid and are stated below for clarity. • A release has occurred when a naturally occurring monitoring parameter, or COC, is detected at a concentration which exceeds its concentration limit (or falls below in the case of pH), and • The naturally occurring monitoring parameter, or COC, is not detected in the laboratory quality control samples. Proposed inorganic concentration limits cannnot be approved at this time since the Revised WQPS Report did not provide the data set used to develop these limits. The Discharger shall provide these calculations so that staff can review the data set used to derive the limits, prior to approving the limits. The Discharger proposes that Total Dissolved Solids (TDS) and Electrical Conductivity (EC) will not be considered separately since they measure total ionic species in solution. Staff cannot agree to this statement because it does not comply with the WDRs. Any increase of any COC could result in the determination that a release to the environment has occurred. Board staff regards each concentration limit for each COC independent of the other. For staff to approve the Revised WQPS Report, by 30 July 2016, the Discharger must electronically submit the data set (Excel Table, tab or text delimited) and statistical analysis used to develop the concentration limits presented in the WQPS Report. Staff also requests the Discharger provide additional explanation of the inter-point tolerance limit method. The Discharger shall submit all data, technical reports and plans, and monitoring reports to the State Water Resources Control Board's web-based Geotracker database system (http://geotracker.waterboards.ca.gov). This includes uploading all reports, plans, and data required under WDR R5-2015-0058 and the MRP. Following Geotracker submittal, the Discharger shall notify staff vie email at centralvalleysacramento(a).waterboards.ca.gov. Please include the following information to ensure proper routing of the notification. Regulatory Program Title 27 Unit Compliance and Enforcement Regulated Party Name San Joaquin County Facility Name Foothill Landfill County San Joaquin CIWQS Place ID 224836