CORRESPONDENCE_2013 - Laserfiche WebLink

Home Browse Search

the well search if requested to do so; a violation for not providing information not previously requested was not necessary. Finding 32 states that County staff"insisted" in a letter that additional water wells would not affect the Engineering Feasibility Study. It would be accurate that the letter from the County confirmed the content of an earlier discussion with Water Board staff. In that conversation, County staff expressed the opinion that the wells installed in October 2011 sufficiently delineated the extent of groundwater impact for the purpose Engineering Feasibility Study, but did not"insist' this. Perhaps the characterization is not necessary. Finding 32 also refers to a component of this Cease and Desist Order in which "a complete Evaluation Monitoring Plan (EMP) report and Engineering Feasibility Study (EFS)... is pending." In the interest of accuracy, this finding should reflect that an EMP was submitted to RWQCB staff on August 20, 2012, and the EFS submitted to the RWQCB on January 25, 2013, and that both of these documents were complete. Finding 33 includes the statement in the first sentence that VOCs continue to affect the "groundwater beneath the site". I believe this statement is intended to refer to the shallow aquifer which is present at the northeastern landfill edge and extends north and east. In contrast, the deep aquifer, which has not been affected by the landfill, is beneath the landfill footprint. To avoid later confusion, we suggest that this Finding be reworded to refer to the "water quality of the shallow aquifer", rather to the "groundwater beneath the site". Findings 34 and 35: We have no comments. Finding 36 includes discussion of inorganic constituents. Historical groundwater chemistry data suggest that an inorganic release from the landfill has not occurred. Our EMP investigation has been directed to VOC impacts that originate at the landfill, as noted elsewhere in this draft Order. Thoughts regarding inorganic compounds in the off-site wells would be pure speculation, and would not validly be included in a Finding. Finding 37 and 38: We have no comments. Finding 39: We have no comment. COMMENTS TO ORDERS Order 1 requires a brief technical report submitted by September 1, 2013, documenting that that closure cap, LFG extraction wells, and perimeter migration monitoring wells are installed. The County intends and expects that these will be installed by that time; however, it possible that events beyond the control of the County prevent completion in that schedule. Therefore we suggest that this report be due by November 1, 2013. Order 2: We have no comment. Fortunately, the County has a contract in place that can be utilized to assist us with the audit of the LFG extraction system. Comments to Second Draft CDO 4 San Joaquin County Submitted February 28,2013 Public Works/Solid Waste