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t <br /> s <br /> MR. WES JOHNSON -2- 17 December 1991 <br /> Sections 2550.8 and 2550.7(b)(1)(B) of Chapter 15, Title 23, <br /> California Code of Regulations (Chapter 15) require monitoring <br /> points to be installed at appropriate locations and depths to <br /> yield ground water samples from the uppermost aquifer that <br /> represents the quality of ground water passing the point of <br /> compliance and to allow for the detection of a release from the <br /> waste management unit. Also, the detection monitoring points are <br /> required to provide the best assurance of the earliest possible <br /> detection of a release from the waste management unit. Since the <br /> screened interval of LW1 is over 50 feet below the water table, it <br /> would not provide the earliest possible detection of a release <br /> from the waste management unit. <br /> 3. Revisions to Article 5 of Chapter 15, which became effective 1 <br /> July 1991, requires the County to obtain and maintain a financial <br /> instrument by 31 December 1991 to cover the cost of a "known or <br /> reasonably foreseeable release" from the waste management unit. <br /> The revised Article 5 also requires the submittal of a Technical <br /> Report proposing updates to the existing monitoring program to <br /> bring Foothill into compliance with all aspects of the revised <br /> Article 5. The Technical Report for updating the existing <br /> monitoring program for Foothill Landfill is due 30 June 1992. <br /> WDRs No. 91-020 requires the use of statistical procedure in the <br /> development and use of Water Quality Protection Standards (WQPS) <br /> for each of the parameters and constituents in the Surface Water <br /> and Ground Water Monitoring Programs. After the WQPS have been <br /> established, Foothill is required to use a Board approved <br /> statistical procedure to determine if there has been a significant <br /> increase over water quality protection standards. To date, the <br /> County has not submitted a statistical procedure for review and <br /> approval by Regional Board staff. The approval of a statistical <br /> procedure should occur before the development of WQPS to avoid any <br /> unnecessary efforts by Foothill . <br /> Please address the above concerns in the Annual Monitoring Report or the next <br /> quarterly self-monitoring report which are due in January 1992. If you have <br /> any questions, please contact me at (916) 361-5737. <br /> ROBERT A. EVANS <br /> Project Engineer <br /> RAE <br /> cc: California Integrated Waste Management Board, Sacramento <br /> Mr. Ed Padilla, San Joaquin County Public Health Services, Stockton <br />