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WASTE DISCHARGE REQUIREMENTS ORDER R5-2015-0058-01 -5- <br />SAN JOAQUIN COUNTY DEPARTMENT OF PUBLIC WORKS <br />FOOTHILL SANITARY LANDFILL, INC. <br />FOOTHILL LANDFILL <br />SAN JOAQUIN COUNTY <br /> <br />16. On 8 May 2023, the Discharger notified Central Valley Water Board staff by email that, <br />due to an above average wet season, the leachate volume of Sumps 1, 2A, and 2B <br />were not in compliance with 40 C.F.R. part 258.40, subdivision (a)(2), which states: <br />“New MSWLF units and lateral expansions shall be constructed ... [w]ith a composite <br />liner… and a leachate collection system that is designed and constructed to maintain <br />less than a 30-cm depth of leachate over the liner.” Leachate levels in Sumps 1 and 2B <br />exceeded the compliance limits in approximately late December 2022. Sump 2A <br />exceeded the compliance limit in mid-January 2023. <br />17. On 6 June 2023, the Discharger submitted the Foothill Leachate Compliance Plan to <br />address the short-term and long-term management of leachate. In the short-term, the <br />Discharger proposed to continue to capture leachate in tanks and haul it offsite while <br />performing modifications within the Sump 1 to address pumping deficiencies. In the <br />long-term, the Discharger proposed continuous pumping, usage of storage ponds, a <br />pump station installation, consolidation of leachate recirculation lines, and utilization of <br />the existing flare and fill station. <br />18. On 27 June 2023, a Notice of Violation was issued for leachate levels exceeding the 30- <br />cm depth over the liner and for failure to comply with certain requirements of the <br />SPRRs. <br />19. On 26 July 2023, Central Valley Water Board staff approved the 6 June 2023 Foothill <br />Leachate Compliance Plan. <br />20. On 7 March 2024, the Discharger submitted Design Basis Analysis Calaveras Surface <br />Impoundment Report (Surface Impoundment Report), which included a conceptual <br />design, preliminary construction drawings, water balance, and slope stability evaluation <br />for the proposed 1.5-acre Calaveras surface impoundment (SI) (see Attachment G). On <br />16 May 2024, Central Valley Water Board staff issued a concurrence letter regarding <br />the preliminary review of the Surface Impoundment Report. <br />21. A complete Amended Report of Waste Discharge (ROWD) for the proposed <br />construction of a surface impoundment has not been submitted. In accordance with Title <br />27, section 21710, subdivision (a)(4), this Order requires the Discharger to submit a <br />complete Amended ROWD (see Provision H.9.n). The Discharger shall include and/or <br />reference previously submitted information relevant to proposed post-closure and <br />corrective action activities to be authorized via WDRs issued by the Central Valley <br />Water Board. The ROWD shall be certified by an appropriate professional per Title 27 <br />section 21710, subdivision (d). <br />22. In 2025, the Central Valley Water Board adopted Order R5-2025-XXXX, which <br />amended WDRs Order R5-2015-0058 to add prohibitions, specifications, provisions, <br />and monitoring and reporting requirements associated with the Class II surface <br />impoundment Waste Management Unit (WMU) in Finding 9. <br />23. As Facility owners and/or operators, the Discharger is responsible for compliance with <br />this Order. <br />