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Foothill Sanitary Landfill -2— San 2— San Joaquin County Dichloropropane 0.42 ppb), and downgradient well MW -3 (Acetone 4.4 ppb and Methylene Chloride 1.9 ppb). According to the data sheets provided in the report, this is the first time that 1,3- Dichloropropane has been detected in MW -2. Methylene chloride and acetone were detected in the field, trip, and lab blanks at similar concentrations, indicating contamination from sampling techniques and/or laboratory practices. Field blanks reflect the quality of rinsate from the equipment used to sample water; therefore, the sampling equipment may not have been clean prior to sampling. Trip blanks should contain deionized water from the laboratory prior to being transported to the field. These sample bottles should reflect either contamination picked up along the "trip" from the cooler, persons handling the bottles with contaminated gloves, or laboratory contamination prior to the trip. We highly recommend that Sequoia Laboratory, in Sacramento and Petaluma, and EMCON/IT technician(s) be notified that this is occurring and should be more cautious in their respective procedures. We also request the County provide an analysis of these contaminants as part of their evaluation monitoring program to verify whether they are truly artificial contaminants or from the groundwater. The report implies that because GW -3 has been impacted by VOCs that an evaluation monitoring ' program has been proposed for well MW -3. This is an incorrect interpretation of Title 27 §20425 for a Detection Monitoring Program. Title 27 clearly states that a measurably significant evidence of a release at a Monitoring Point is considered a release from the Unit. The evaluation monitoring program shall be used to assess the nature and extent of the release from the Unit and to design a corrective action program meeting the requirements of § 20430 Corrective Action Program. Therefore, it is not MW -3 that is in evaluation monitoring, but the entire landfill. Water Sample Field Data Sheets show Turbidity as "trace" with one number written outside the page ' border. MRP Order No. 94-268 requires Turbidity be reported in Turbidity Units, which are NTUs. Please ensure that subsequent reports are not reported as Visual for each purge volume, but include Turbidity in NTUs. Second Quarter Report: Traces of VOC's were found in upgradient well MW -1 (Methylene Chloride 2.4 ppb), downgradient well MW -2 (Acetone 2.8 ppb, Methylene Chloride 0.17 ppb, and , Chloromethane 0.16 ppb), and downgradient well MW -3 (Acetone 4.6 ppb, Chloroform 1.0 ppb, and Methylene Chloride 2.5 ppb). According to the tables in the report, this is the first time that chloromethane has been detected in MW -2. Methylene chloride and acetone were detected in the field, trip, and lab blanks at similar concentrations, indicating contamination from field personnel, sampling equipment, and laboratory contamination. Please inform Sequoia Laboratories, in Sacramento and Petaluma, and EMCON/IT of this issue. Ensure that the Sampling and Analysis Plan is strictly followed. The report states that a revised EMP will be submitted by October 1, 2002, if necessary. Respectfully, the Board has been attempting to receive a complete EMP from the County since the first EMP (Joint Technical Document) report was submitted on 24 November 2000. It is now almost two years later and we still do not know the extent of pollution at the site. We feel we have been very flexible in our , requests for additional information to ensure the County complies with Title 27 and WDRs to evaluate pollution in groundwater caused by the discharge of waste at the Foothill Landfill. Our requests are not only necessary, but are required by Title 27 and WDRs Order No. 94-268. Furthermore, the Porter - Cologne Water Quality Control Act (WC) § 13267 states that a regional board may require a discharger submit a technical report in connection with any action relating to WDRs and that the discharger shall I�