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WASTE DISCHARGE REQUIREMENTS ORDER NO. R5-2010-0123 -5- H.M. HOLLOWAY, INC. H.M. HOLLOWAY SURFACE MINE LANDFILL PROJECT KERN COUNTY Title 27. As such, the site is suitable for operating new Units or lateral expansions of existing Units for the discharge and containment of the wastes described in Finding No. 15, without the construction of additional waste containment features contained in Section 20260(b)(2) of Title 27 and State Water Resources Control Board Resolution No. 93-62. DETECTION MONITORING PROGRAM 32.The groundwater detection monitoring system, initiated in the second quarter of 1995, consists of 12 monitoring wells. Three wells monitor Pit E, three wells monitor Pit F, four wells monitor Pit G, and two wells monitor the Pits F and G connection area. 33.The Discharger's detection monitoring program for groundwater satisfies the requirements contained in Title 27. 34.The Discharger was not required by Chapter 15 to conduct unsaturated zone monitoring since the Units were unclassified. 35. Pit G, when built for waste disposal, will include a leachate collection and removal system. The vadose zone will be monitored by the inclusion of a pan lysimeter beneath the leachate collection sump of the leachate collection and removal system. The Discharger adequately demonstrated that it is impractical to retrofit Pits E and F to monitor the unsaturated zone. 36.The Discharger's proposed detection monitoring program for the unsaturated zone will satisfy the requirements contained in Title 27. 37.There is no surface water at or adjacent to the facility for the Discharger to monitor. 38.Volatile organic compounds (VOCs) are often detected in a release from a landfill. Since VOCs 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. 39.Because the Units were previously unclassified, a water quality protection standard (WQPS) has not been established pursuant to Title 27. This Order requires the Discharger to submit a WQPS report that reflects recent and historical monitoring data and monitoring points. (see Detection Monitoring Specification EA). 40.Title 27, 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 Section 20415(b)(1)(B)2.-4. However, Title 27 does not specify a specific method for non-statistical evaluation of monitoring data.