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Negotiations in January 2004 resulted in a Clean Up and Abatement Order which required the County to initiate the Foothill Landfill Site Improvement Project, which included: • Final closure of the crest of Module"I" • Installation of a barrier between Module"I"and the future refuse placed over Module "I" in extension and completion of Module 1 • Landfill gas collection system • Partial Cover of those surfaces of Module"I"that are not covered by the inter-Module barrier or final closure • Two groundwater monitoring wells This project was to be pursued in lieu of complete closure of Module"I". On July 20, 2004,the San Joaquin County Board of Supervisors approved a contract with Kleinfelder to design the Site Improvement Project. By February 2007, five years since VOCs were detected at MW-3, construction of the Site Improvement Project was substantially complete; however,the vegetation in the evapotranspirative (ET) closure cap was not well established. At that time, it was assumed that difficulty in growth was due to the failure of the Contractor to include fungus inoculants with the seed, as specified. This project also included a barrier between existing Module"I"refuse and new refuse that can be placed due to the presence of Module 1. At the direction of CVRWQCB staff,this barrier was an extension of the Module 1 liner with significant effort expended to ensure that the barrier over Module"I"refuse was gas-tight. In November 2007,the ET area was again reseeded,this time with fungus inoculants as specified. In the spring of 2008, it was determined that the seed growth remained insufficient for adequate ET cover. In November 2008,the closure cap soil was amended and fertilized, and again seeded. In the spring of 2009, vegetation was growing healthily on the ET cap area. On June 10, 2009, CVRWQCB staff issued a notice of violation for discharge of wastes outside of containment. On March 4, 2009, San Joaquin County staff noticed that the landfill gas (LFG) condensate pump discharge was connected to the secondary leachate sump of Module 1. In April 2009,the LFG condensate pump discharge line connection was removed, and condensate was pumped from the secondary sump. The soil gas trench(installed beneath the liner of Module 1) was activated to enhance the protection of groundwater. An investigation in October 2009 indicated that the condensate had been forced between the primary and secondary liner up the side of the landfill, and had been discharged into the anchor trench along the side of the landfill where the primary and secondary liners terminate. Foothill Sanitary Landfill 4 Department of Public Works/Solid Waste 2"d Semester and Annual 2010 Groundwater Monitoring County of San Joaquin—January 31,2011