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I <br /> _ a <br /> PUBLIC HL6ALTH S <br /> SAN JOAQUIN COUNTY 2' i <br /> ENVIRONMENTAL HEALTH DIVISION <br /> Karen Furst, M.D., M.P.H., Health Officer P <br /> 304 East Weber Avenue, Third Floor • Stockton, CA 95202 <br /> 209/468-3420 <br /> October 31, 2000 FILE C <br /> Michael Kalish <br /> San Joaquin County Public Works Department <br /> Solid Waste Division <br /> 1810 E. Hazelton Ave. <br /> Stockton, California 95201 <br /> RE: Landfill Gas Extraction System at Harney Lane Landfill <br /> This letter is to document the gas monitoring events at the above referenced facility. The facility <br /> has been subject to high levels of methane at the boundary. Review of the past quarterly gas <br /> monitoring results indicates wells GW 1 through GW4 have the most consistent levels of <br /> methane. Re-sampling these wells showed GW3 was still above 5% on October 6, 2000. The <br /> Solid Waste Division has attempted to reduce the levels of methane by balancing the gas <br /> collection system. The changes have not brought the facility into compliance for violations of <br /> State Minimum Standards Title 27, California Code of Regulations, Section 20921(a)(2). The <br /> concentration of methane gas migrating from the landfill must not exceed 5%by volume in air at <br /> the facility property boundary. <br /> The close proximity of the farm labor camp to the above-mentioned wells has raised concerns <br /> regarding the potential health and safety risks to the occupants from off site gas migration. <br /> Quarterly gas monitoring for methane inside the individual dwelling units at the farm labor camp <br /> have indicated structures and vents measured 0.0% of the Lower Explosive Limit. The failure to <br /> detect methane gas in these off-site structures does not exclude the possibility for gas migration <br /> to occur into these structures. The concentration of methane gas at the boundary continues to <br /> pose a threat to the occupants of the structures. <br /> It is this Department's position that recent modifications and adjustments to the gas extraction <br /> system may have increased the efficiency of the system, but not to a level required for <br /> compliance with Title 27, California Code of Regulations. The gas extraction system will <br /> require further modifications in addition to the continuous adjustment and monitoring. Title 27, <br /> Section 20921 (a)(3)(d) states that"Gas monitoring and control systems shall be modified during <br /> the closure and post closure maintenance period to reflect changing on-site and adjacent land <br /> uses." <br /> A Division of San Joaquin County Health Care Services <br />