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soon would be issued. In the interest of accuracy, we suggest that this Finding be reworded to reflect that the meeting which we attended was not attended by Caltrans. Finding 13 is accurate as written, but does not reflect the receipt of the draft Water Code Section 13267 Order by both Caltrans and the County ori July 7, 2011. Receipt of this draft Order provided the County and Caltrans with the specifics of the Order. Once the two parties knew what actions were required of them, the two parties were able to quickly develop the Memorandum of Understanding. Without knowing about the receipt of that draft Order, members of the Water Board will be left to speculate why Caltrans and the County did not arrive at a Memorandum of Understanding earlier. Therefore, in the interest of accuracy and completeness, we ask that the receipt of that draft Order be included in these Findings. Findings 14, 15, 16, 17 and 18: We have no further comments. Finding 19 states that "The delay in installing the cap over the additional waste has likely increased the generation of landfill gas and the subsequent impacts to groundwater'. We are not aware of the basis for this statement, which is not supported by data provided in the periodic groundwater monitoring reports, the Evaluation Monitoring Report, or the Engineering Feasibility Study. Instead, water quality is seen to be stable the past two years, unaffected by a "delay". We therefore ask that this sentence not be included in these Findings. Finding 20: We have no further comments (see comment to Finding 9). Finding 21: We have no comments. Finding 22: The last sentence of this Finding reports statements by the County that "...additional LFG extraction wells installed adjacent to the northeastern property boundary would remediate the impacts." (emphasis mine). It would be more accurate to state that County staff believed that the LFG extraction wells in this area were likely to improve groundwater quality. In the interest of accuracy, we ask that the wording be revised to reflect the tentative nature of statements by the County. Groundwater monitoring data at that time indicated that the source of the problem was the northeastern portion of the landfill, this conclusion further confirmed by the Evaluation Monitoring wells installed in 2011. The County stated to Water Board staff that, rather than expending resources in further delineation, it would be better to apply additional corrective action. Water Board staff seemed to agree with this approach. Finding 23 through 30: We have no comments. Finding 31 describes the Notice of Violation for not sufficiently delineating the extent of groundwater impact, for not providing a water supply well search, and for not installing two additional LFG migration monitoring probes. It would be accurate to note that Water Board staff agreed in a subsequent meeting that the groundwater monitoring wells installed in October 2011 were sufficient to determine the extent of groundwater impact for the purpose of conducting an Engineering Feasibility Study. It would also be accurate to note that the water supply well search and installing two additional LFG migration monitoring probes were not previously requested by Water Board staff. The County would have installed these two wells and provided Comments to Second Draft CDC 3 San Joaquin County Submitted February 28,2013 Public Works/Solid Waste