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Lodi City Landfill November 16,2011 • North of Awani Drive, Lodi, California Project No. 104690061 As indicated in their report, volatile organic compounds were not detected in the samples of wastes, vadose zone, groundwater, or surface water. Low concentrations of total petroleum hy- drocarbons (TPH) (27 to 94 milligrams per kilogram) were detected in the six samples analyzed by United States Environmental Protection Agency test method 418.1 (TPH-IR)were detected in the fill and vadose zone beneath the fill. High concentrations of some metals (lead, chromium, copper, iron, manganese, and zinc) were detected in the wastes and reportedly were attributed to the presence of "small metal objects observed in the fill."Two samples of the fill contained lead at concentrations exceeding the total and soluble threshold limit concentrations for lead. Based on review of the analytical report, in samples analyzed, iron concentrations were as high as 100,000 mg/kg and lead concentrations were as high as 10,000 mg/kg(Appendix A). It was stated that "Visual observations made during this phase of work and previous phases indi- cated that approximately 60 to 70 percent of the fill is largely (at least 90 percent) composed of soil.Approximately 30 percent of t he filled area appears to contain layers of disposed waste that are 15 to 85 percent refuse. Based on these estimated volumes and concentrations, it appears that approximately 25,000 cubic yards of waste was disposed at this site."The highest concentration of debris was reported to be located approximately 150 feet south of the Mokelumne River, in the center of the site. Groundwater during drilling was present at an approximate depth of 19.5 feet bgs at the location the well was constructed. The report recommended that the landfill be granted an exception from performing a SWAT be- cause "The landfill appears to have received less than 50,000 cy of waste, and does not appear to contain, or be leaking hazardous waste other than pieces of metal debris." In a January 4, 2000 Memorandum from Michael Bledsoe of the California Integrated Waste Management Board to Michael Wochnick, Permitting & Enforcement Division; infor- mation was provided responding to statutory authority pursuant to which local enforcement agencies (LEAs) can enter, inspect, and enforce CIWMB statues and regulations at closed solid waste disposal sites, including those that ceased operating before 1977. CIWMB indicated the LEAs have authority to enter, inspect, and enforce CIWMB statutes and regulations at closed disposal sites, including those closed before 1977 and that their authority arises from their re- sponsibility to inspect closed sites and to carry out standards adopted by CIWMB. It was also indicated that CIWMB has authority to obtain funds to clean up sites, which cause or threaten harm to the public health and safety or the environment. Although not known at this time, because historical aerial photographs reviewed suggest waste disposal may have occurred west of the railroad tracks on the property previously belonging to the winery, available background information was also obtained and reviewed for this area. 104690061 R ana1.aa 8 �11�11 'MOOT e