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WASTE DISCHARGE REQUIREMENTS ORDER NO. -4- FORWARD INC. FOR CLOSURE OF FRENCH CAW MUNICIPAL SOLID WASTE LANDFILL SAN JOAQUIN COUNTY 23. The designated beneficial uses of the groundwater, as specified in the Basin Plan, are domestic and municipal, agricultural, and industrial supply. GROUNDWATER MONITORING 24. The groundwater detection monitoring system consists of four background wells (MW-5, -6A, -7A, and—713) and five compliance wells (MW-2, -8A-9A, -913, and 10A). MW-3 and —4 will be replaced by hydraulically equivalent MW-8A, -9A and—10A. MW-3 and—4 are redundant and shall be abandoned in compliance with the San Joaquin County Department of Environmental Health well abandonment requirements. MW-lA is screened in waste and shall be monitored to evaluate landfill leachate. The facility is unlined and there is no vadose zone detection monitoring system. 25. The Discharger's detection monitoring program for groundwater at this Unit does satisfy the requirements contained in Title 27. 26. 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(see Finding Nos. 29 and 30). 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. 27. Title 27 CCR Sections 20415(e)(8) and(9)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 Title 27 CCR Section 20415(b)(1)(B)2.-4. However, Title 27 CCR does not specify a specific method for non-statistical evaluation of monitoring data. 28. The Regional Board may specify a non-statistical data analysis method pursuant to Title 27 CCR Section 20080(a)(1). Section 13360(a)(1)of the California Water Code allows the Regional 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. 29. 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. 30. 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