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1�1 Dr. Andrew Altevogt December 15, 2017 Page 3 of 6 E WDRs were issued in 2015 the LFG system generated only 50 gpd of condensate. The dramatic increase in condensate generation is due to the recent expansion in the number of LFG extraction wells from 8 to 12 wells, and the unusually wet 2016-2017 rainy season. The expansion of the LFG extraction system from 8 to 12 wells was required as corrective action to reduce the amount of LFG containing volatile organic compounds (VOCs) from leaving the landfill, which had caused an impact to groundwater and the vadose zone. This expansion was a response of a Notice of Violation (NOV) dated 1 August 2014 issued by the Water Board to the County. It should be noted that as more wells are added to LF -1 to further control the perceived release of LFG from LF -1, even more condensate would be generated. This poses a technical problem as far as sizing any system to handle the anticipated volume of condensate. San Joaquin County has been striving to achieve the water quality goals of Title 27 and respond in a diligent and expedient fashion to all of the Orders and NOVs issued by the Water Board at FSL. The County knows that the expansion of LF -1's LFG extraction system is crucial to the reduction of groundwater and vadose impacts from LFG. The well field expansions are costly but valuable to groundwater abatement efforts. The County would rather expend funds toward well field expansion rather than toward off-site condensate disposal when there are other options for condensate disposal as outlined below: San Joaquin County has identified three permanent condensate management options: 1. Combine the condensate from LF -1 with condensate from LF -2 for return to the lined LF -2, as has been done since 2006. 2. Inject the condensate from LF -1 into a new enclosed flare that will be constructed on site by end of 2019. 3. Construct a lined leachate pond onsite for the disposal of leachate and LFG condensate via evaporation. OPTION 1 Since the handling of the condensate proved to be more problematic than what was envisioned during preparation of the LFG O&M Report, the County is temporarily continuing to discharge LF -1 condensate to the LF -2 sump and thus is currently non-compliant for condensate management per the new WDR. The County sees no environmental advantage to haul the condensate off-site. To the contrary, discharging the condensate from a closed piped system, into holding tanks and pumping them into tanker trucks for transfer increases the likelihood of spills and potential contamination. CCR Title 27, Section 20340(g), states: (g) Leachate Handling — Except as otherwise provided under SWRCB Resolution No. 93-62 (for MSW landfills subject to 40CFR258.28), collected leachate shall be returned to the Unit(s) from which it came or discharged in another manner approved by the RWQCB. Collected leachate can be discharged to a different Unit only if. - (1) The receiving Unit has an LCRS, contains wastes which are similar in classification and characteristics to those in the Unit(s) from which leachate was extracted, and has at least the