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n Dr. Andrew Altevogt December 15, 2017 Page 2 of 6 Discharge Prohibition A.3.b states as follows: The discharge of LF -1 leachate and/or LFG condensate to LF -2 after 15 October 2016 (see Discharge Specification 8.6); Facility Specifications C.1. states as follows: Consistent with Discharge Prohibition A.3, LFG extracted from LF -1 shall be routed through a condensate knock -out sump prior to being commingled with LF -2 LFG, if condensate removed from LF -2 LFG is to be returned to LF -2. Discharge Prohibition A.3. states as follows: The following discharges of leachate andlor landfill gas condensate are prohibited. a. The return or discharge of leachate andlor LFG condensate to unlined unit LF -1; San Joaquin County has been diligently following the provisions of WDR R5-2015-0058 with respect to the handling of landfill gas (LFG) condensate from landfill unit LF -1. An Operations and Maintenance (O&M) Plan was submitted to Board staff in January 2017 in accordance with Provision H.B., to ensure that LFG condensate generated by LF -1 is handled and disposed of in accordance with the requirements of the WDR The O&M Plan for the handling LFG condensate generated from LF -1 stated in summary that: LF -1 condensate is collected in two (2) 1,000 -gallon polyethylene storage tanks, installed specifically for compliance with the new condensate handling provisions. Condensate Tank No. 1 is located on the West side of the landfill and Tank No. 2 is located on the East side of the landfill. As the tanks fill, each tank will be pumped into a tanker truck and the condensate is hauled off-site for disposal. At the time when the O&M Plan was written, it was envisioned that the disposal of LFG condensate off-site would be a trivial task of disposal at a municipal wastewater treatment plant (i.e., an authorized offsite facility as defined in Discharge Specification B.6.) within San Joaquin County or in a nearby county. However, due to the typical composition of condensate, which contains volatile compounds that can be harming to treatment plan operations, treatment plants are hesitant to accept LFG condensate. Condensate generation calculations determined an average of 400 to 500 gallons per day of condensate would be generated, or up to 15,000 gallons per month. The County received an estimate from a waste hauler who indicated the cost to haul the condensate for disposal at the Altamont Landfill in Livermore, CA would be nearly $5,000 per trip, or roughly $1 per gallon, resulting in up to $180,000 per year in disposal costs alone. At the estimated generation rate, three hauling trips per month with a 5,000 -gallon tanker truck would be needed. The County would need to incur additional equipment and operating costs to store collected condensate in larger tanks prior to hauling and disposal. The WDR allows for the discharge of condensate from LF -2 back into LF -2, because it has a Title 27 compliant base liner. LF -1 is unlined, with the exception that a portion of LF -2's liner overlaps a portion of its side slope. During the wet -weather season of 2016-2017, the LF -1's LFG extraction system generated approximately 400 gallons per day (gpd) of condensate on average. When the