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WASTE DISCHARGE REQUIREMENTSORDER NO. R5-2003-0020 -5- FOR COUNTY OF SAN JOAQUIN FOR CONSTRUCTION, OPERATION, CLOSURE AND EVALUATION MONITORING FOOTHILL SANITARY LANDFILL, MUNICIPAL SANITARY LANDFILL SAN JOAQUIN COUNTY 29. The Discharger proposes to install ten soil -pore gas monitoring wells around the landfill modules, and subsequent modules, to monitor the unsaturated zone for VOCs, as shown on Attachment B. If VOCs are detected, an evaluation -monitoring program will be required pursuant to Title 27. 30. The Discharger's proposed detection monitoring program for sampling soil -pore gas in the unsaturated zone at this Unit satisfies the requirement of Title 27 for monitoring landfill gases. 31. Section 20164 of Title 27 defines: "Containment" = means the use of waste management unit characteristics or installed systems and structures to prevent or restrict the release of waste constituents, including waste constituents mobilized as a component of leachate or of landfill gas. 32. Volatile organic compounds (VOCs) are often detected in a release from a landfill, and are the primary waste constituents detected in groundwater beneath a municipal solid waste landfill in cases of a release. Since volatile organic compounds are not naturally occurring and thus have no background value, they are not amenable to the statistical analysis procedures contained in Title 27 for the determination of a release of wastes from a Unit. 33. Sections 20415(e)(8) and (9) of Title 27 provide for the non -statistical evaluation of monitoring data that will provide the best assurance of the earliest possible detection of a release from a Unit in accordance with §20415(b)(1)(B)2.-4. of Title 27. However, Title 27 does not specify a specific method for non -statistical evaluation of monitoring data. 34. The Board may specify a non -statistical data analysis method pursuant to Section 20080(a)(1) of Title 27. Section 13360(x)(1) of the California Water Code allows the Board to specify requirements to protect underground or surface waters from leakage from a solid waste site, which includes a method to provide the best assurance of determining the earliest possible detection of a release. 35. In order to provide the best assurance of the earliest possible detection of a release of non -naturally occurring waste constituents from a Unit, this Order specifies a non -statistical method for the evaluation of monitoring data. 36. The specified non -statistical method for evaluation of monitoring data provides two criteria (or triggers) for making the determination that there has been a release of non -naturally occurring waste constituents from a Unit. The presence of two non -naturally occurring waste constituents above their respective method detection limit (MDL), or one non -naturally occurring waste constituent detected above its practical quantitation limit (PQL), indicates that a release of waste from a Unit has occurred. Following an indication of a release, is verification testing will be conducted to determine whether there has been a release from the Unit, or there is a source of the detected constituents other than the landfill, or the detection was a false detection. Although the detection of one non -naturally occurring waste constituent