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Og45!!N..C B THOMAS R. FLINN _ P.O.BOX 1810-1810 E.HAZELTON AVENUE DIRECTOR e STOCKTON,CALIFORNIA 95201 (209)468-3000 FAX(209)468-2999 Fop`'P www.sjgov.org/pubworks THOMAS M.GAU CHIEF DEPUTY DIRECTOR MANUEL SOLORIO Wormn for YOU DEPUTY DIRECTOR D I[ FD ��' STEVEN WINKLER E LI�YI L DEPUTY DIRECTOR ROGERJANES AUG 1 8 2006 BUSINESS ADMINISTRATOR August 16, 2006 ENVIRONMENT HEALTH PERMIT/SERVICES Mr. Victor Izzo California Regional Water Quality Control Board 11020 Sun Center Drive, #200 Rancho Cordova, California 95820-6114 SUBJECT: NOTICE OF VIOLATION FOR INADEQUATE DETECTION MONITORING PROGRAM, CORRAL HOLLOW SANITARY LANDFILL Dear Mr. Izzo:�1Ukv We were most surprised to receive a violation that included insufficient groundwater monitoring of the shallow aquifer at the Corral Hollow Sanitary Landfill (letter dated July 12, 2006, enclosed). The County has followed the monitoring program as approved and directed by Regional Water Quality Control Board (RWQCB) Order and Board staff for the past seventeen years; to receive a violation now for inadequate monitoring at this time and without warning is disconcerting. However, we believe this violation was issued due to a misunderstanding of the most recent Waste Discharge Requirements (WDRs) and unfamiliarity with the history of the site by a member of your staff. As you know, the hydrology at the Corral Hollow Landfill is complex. Two aquifers are present beneath the northeastern portion of the site: a deep aquifer and a shallow aquifer perched on the Corcoran clay formation. Beneath the southwestern portion of this site only the deep aquifer is present because the Corcoran formation dissipates in that area, and does not provide a contiguous strata on which a shallow aquifer can perch. The shallow aquifer has been monitored quarterly under the approved monitoring program,with reports submitted to the RWQCB quarterly since 1997. However, in 2001 when the most recent WDRs were issued under Order 5-01-176,the deep aquifer monitoring wells were dry. To ensure that the deep aquifer was monitored, Finding 19 of that Order stated that"the groundwater beneath the waste within the southwestern half of the WMU [the deep aquifer] has no monitoring system currently in place" (excerpt enclosed). The County installed additional deep-aquifer wells in 2002. Unfortunately, Finding 19 was misinterpreted as a requirement that the shallow aquifer be monitored on the western side of the landfill, as well as on the eastern. Based on this interpretation, and on information from another site in the vicinity, we received a violation for inadequate monitoring of the shallow aquifer. This violation letter included a deadline of August 21 to submit a work plan to install shallow groundwater monitoring wells in the southwestern portion of that site.