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HarneyLane Landfill <br /> 2 <br /> San Joaquin County <br /> necessary to ensure the protection of human health or the environment. It has been approximately 7 years since <br /> the corrective action program(closure and landfill gas extraction)for the Harney Lane Landfill was initiated. <br /> WDRs were finalized in May of 1996, approximately 6 years ago. We propose that>5 years is an ample amount <br /> of time to evaluate the corrective action measure of capping the unlined landfill and extraction of landfill gas. <br /> Therefore,we propose the County submit a comprehensive evaluation report on the effectiveness of the <br /> corrective action measures because VOCs continue to be found in groundwater and Title 27 requirements. <br /> Information in the"Semi-Annual Progress Report"should include,but not be limited to,the status of the current <br /> gas control system,mass removal rates(increasing or decreasing),map of the gas extraction system, operations <br /> and maintenance history, effectiveness of mass removal,effectiveness of the cover system, effectiveness of the <br /> current groundwater monitoring system(i.e., enough wells in the right places), and a proposal to improve the <br /> corrective action measures to mitigate VOCs in groundwater. As part of the groundwater monitoring,we propose <br /> the statistical analysis using intrawell versus interwell be revisited based on updated U.S.E.P.A. draft guidelines <br /> and an evaluation of possible impacts from inorganic constituents (e.g., chloride,TDS, sulfate,hexavalent <br /> chromium) in groundwater. MW-4 has historically shown higher constituent levels of inorganics based on <br /> wastewater treatment ponds at the migrant farms labor camp located upgradient. The EMP should include an <br /> evaluation of the water quality of the wastewater treatment ponds for comparison to MW-4 water quality. An <br /> updated survey of wells within a one-mile radius should be included(i.e., domestic, irrigation,production). It <br /> may also be appropriate to include cross-sections,using well logs, showing the cross-gradient and downgradient <br /> lithology with landfill trenches projected to show distance to groundwater from the bottom of the waste. Based <br /> on the depth and nature of this comprehensive review, we request this report be submitted by 1 January 2003. <br /> Henceforth, semi-annual progress reports should be submitted per Title 27, §20430(h). <br /> Please note in the Annual reports when the last 5-year COC sampling event occurred and when the next is <br /> scheduled. Ensure that this statement is included in other San Joaquin County landfill (North County, Foothill, <br /> Corral Hollow)monitoring reports, as well. <br /> Please respond to comments in this letter and the attached Monitoring Report Compliance Checklist in <br /> subsequent monitoring reports, as applicable. <br /> If you have any questions,please contact me at(916)255-3137 or schwabk@rb5s.swreb.ca.gov. <br /> Lf <br /> KIM A. SCHWAB,RG <br /> Associate Engineering Geologist <br /> cc: Robert McClellon, San Joaquin County Environmental Health Division, Stockton <br /> Permitting and Enforcement Division, Solid Waste Management Unit, CIWMB, Sacramento <br /> KAS:Harney 4Q2001 Annual ltr <br />