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North County Recycling Center and Sanitary Landfill Storm Water Pollution Prevention Plan Page 58 12.3.1 Level 2 ERA Action Plan If Level 2 status is reached, a facility must certify and submit, via SMARTS, a Level 2 ERA Action Plan prepared by a facility designated QISP that addresses each new Level 2 NAL exceedance. This must be completed by January 1 following the reporting year during which the NAL exceedance(s) occurred. For each new Level 2 NAL exceedance, the Level 2 Action Plan will identify which Level 2 ERA Technical Report demonstration the facility has selected to perform as an evaluation. See SWPPP Section 12.3.2 for the list of technical reports demonstrations All elements of the Level 2 ERA Action Plan shall be implemented as soon as practicable and completed no later than one year after submitting the Level 2 ERA Action Plan. The Level 2 ERA Action Plan shall include a schedule and a detailed description of the tasks required to complete a facility’s selected demonstration. On December 28, 2017, a Level 2 ERA Action Plan was prepared to address the iron NAL exceedances. The Action Plan selected the industrial activity BMP demonstration. However, soil analytical tests performed in December 2017 are showing that there is a considerable amount of aluminum and iron in the native soils. (Refer to Section 2.3 of this SWPPP.) Upon further testing and evaluation, the demonstration may be changed to a natural background pollutant source. A copy of the Level 2 ERA Action Plan (and any revisions to it) is included in Appendix K. 12.3.2 Level 2 ERA Technical Report On December 11, 2018, San Joaquin County submitted on SMARTS a Technical Report proposing a “Natural Background Pollutant Source Demonstration” as described in Section XII.D.2.c of the General Permit. The County believes the cause of the aluminum and iron NAL exceedances to be solely attributable to the natural soils for the following reasons: 1. Samples of storm water discharges collected from drainage areas SW-3 and SW-4 have had elevated aluminum and iron concentrations. The concentrations have been very consistent and similar for the two drainage areas even though the industrial activities in these areas are very different. There are essentially no aluminum or iron producing activities within drainage area SW-4, while most of the landfill activities that could produce those metals are found in drainage area SW-3. Drainage area SW-4 is generally upwind and higher in elevation than the SW-3 drainage area; meaning that it would not typically experience wind deposition or run-on from drainage area SW-3. 2. Soil samples that were collected from the storm water conveyance swales in both drainage areas tested significantly high in aluminum and iron. The same was true for soil samples collected from exclusively non-industrial areas. When some of the soil was placed in deionized water and the water was tested, it was found to be very high in aluminum and iron. These soil samples had never come into contact with industrial activities or with runoff from industrial activities. 3. NRCS soil survey data and other studies show that the site has alluvial soil types derived of granite. Academic literature references show minerals contained in granitic