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g raze`�2'•. SAN3JOAQUIN <br />—COUNTY--- <br />�icX Greatness grows here <br />jacq*o <br />Wamas for YOU <br />December 15, 2017 <br />Dr. Andrew Altevogt, PhD <br />Assistant Executive Officer <br />Central Valley Regional Water Quality Control Board <br />11020 Sun Center Drive , Suite #200 <br />Rancho Cordova, CA 95680 <br />E <br />Department of Public Works <br />Kris Balaji, Director of Public Works <br />Fritz Buchman, Deputy DirectorJDevelopment <br />Michael Selling, Deputy Director/Engineering <br />Jim Stone, Deputy Director/Operations <br />Najee Zarif, Intenm Business Administrator <br />SUBJECT: REQUEST FOR WAIVER OR EXTENSION OF DISCHARGE SPECIFICATION B.6. <br />FROM WASTE DISCHARGE REQUIREMENT NO. R5-2015-0058 FOR THE <br />FOOTHILL SANITARY LANDFILL, SAN JOAQUIN COUNTY <br />Dear Dr. Altevogt: <br />San Joaquin County Public Works, Solid Waste Division, is requesting a waiver of Discharge <br />Specification B.6. from Waste Discharge Requirement (WDR) No. R5-2015-0058 for the Foothill <br />Sanitary Landfill (FSL). WDR R5-2015-0058 was issued by the Central Valley Regional Water Quality <br />Control Board (Water Board) to San Joaquin County on 17 April 2015. <br />This new WDR classified FSL as two (2) separate waste management units (WMU), the unlined LF -1 <br />and the lined LF -2. The previous WDRs had classified FSL as a single WMU, and the condensate <br />from the unlined module was discharged to the common sump with the adjacent lined module and the <br />leachate was recirculated back into the lined module in accordance with CCR T27. The condensate <br />from LF -1 was managed in this manner since the gas system was first installed and approved by the <br />Water Board in 2006. San Joaquin County is at a loss as to why these new Specifications were <br />instituted at this time: <br />Discharge Specification B.6. states as follows: <br />After 15 October 2016, leachate and LFG condensate derived from LF -1 shall be discharged at an <br />authorized offsite facility or appropriately handled for such discharge (e.g., stored in tanks pending <br />pick-up). See Facility Specification C.2. <br />In addition, Facility Specification C.2. states as follows: <br />Per Title 27, section 21760(b), the Discharger shall develop and implement an operations and <br />maintenance (O&M) plan for the LFG extraction system, as approved by Central Valley Water Board <br />staff, to ensure that LFG from the landfill units is controlled and handled appropriately in accordance <br />with the requirements of this Order and Title 27 regulations. The plan shall include, but not be limited <br />to, a plan for the separate removal and offsite disposal of LFG condensate from LF -1 per Discharge <br />Specification B.6 above. See also Provision H.8. <br />Further, Provision H.8. states as follows: <br />By 15 January 2017, the Discharger shall submit, for Board staff approval, an Operations and <br />Maintenance (O&M) Plan for the LFG control system, to ensure that LFG extracted from the landfill <br />units is handled and disposed of in accordance with the requirements of this Order and Title 27 <br />regulations. See Discharge Prohibition A. 3.b, Discharge Specification B.6, and Facility Specifications <br />C.1 and C.2. <br />1810 East Hazelton Avenue I Stockton, California 95205 1 T 209 468 3000 I F 209 468 2999 <br />