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WASTE DISCHARGE REQUIREMENTS ORDER R5-2015-0058-01 -7- <br />SAN JOAQUIN COUNTY DEPARTMENT OF PUBLIC WORKS <br />FOOTHILL SANITARY LANDFILL, INC. <br />FOOTHILL LANDFILL <br />SAN JOAQUIN COUNTY <br /> <br />natural geologic materials underlying the unit were sufficiently protective of <br />underlying groundwater beneficial uses to meet Class III unit containment standards <br />in Title 27, sections 20240 and 20260. Monitoring data have since indicated, <br />however, that waste constituents from LF-1 have migrated into the unsaturated zone <br />and groundwater, indicating that the natural geologic materials underlying the site do <br />not meet Class III containment standards.1 Instead of declassifying or reclassifying <br />LF-1, these WDRs require that LF-1 be closed given that it can no longer accept <br />wastes because it does not meet Class III containment standards. See Findings 30 <br />and 136; Closure and Postclosure Specification E.2. <br />30. A landfill’s containment system includes its base liner, and, after closure, its final <br />cover. Given that LF-1 was constructed and subsequently developed without a base <br />liner prior to the enactment of Chapter 15 regulations in 1984, retrofitting the unit <br />with a Class III level base liner is infeasible. These WDRs therefore require that the <br />Discharger complete closure of LF-1 in accordance with Title 27 performance <br />standards (i.e., to provide the unit with that portion of a Class III level containment <br />system that is feasible to construct on the top deck and side slopes). See Title 27, <br />section 20950(a)(2)(A)(1). <br />31. Given that these WDRs classify LF-1 and LF-2 as separate landfill units (see Finding <br />27), the Closure and Postclosure Specifications of this Order require that the <br />Discharger submit separate closure plans for each unit. A revised Partial Final <br />Closure and Postclosure Maintenance Plan (Partial FCP/PCMP) is required for LF-1 <br />to complete closure of that unit and a revised Preliminary Closure and Postclosure <br />Maintenance Plan (PC/PCMP) is required for LF-2. <br />32. The proposed Class II surface impoundment (see Finding 9) is regulated under <br />authority given in Water Code section 13000 et seq. and Title 27 section 20005 et <br />seq. <br />33. Water Code section 13173 defines “designated waste” as either of the following: <br />a. Hazardous waste that has been granted a variance from hazardous waste <br />management requirements pursuant to Health and Safety Code section 25143. <br />b. Nonhazardous waste that consists of, or contains, pollutants that, under ambient <br />environmental conditions at a WMU, could be released in concentrations <br />exceeding applicable WQOs or that could reasonably be expected to affect <br />beneficial uses of the waters of the state as contained in the appropriate state <br />water quality control plan. <br />The Discharger proposes to discharge certain designated wastes—specifically, <br />landfill leachate and other wastes—to a proposed Class II surface impoundment at <br />the Facility. This Order authorizes the discharge of such wastes to the WMUs <br />specified in Section B.9. <br />1. Previous WDRs Order R5-2003-0020 (Finding 15), for example, stated, in part, “The site characteristics <br />where the Unit is located . . . are not suitable for a new Class III landfill contained in §20260(a) and (b)(1) of <br />Title 27 without the construction of additional waste containment features in accordance with §20260(b)(2) of <br />Title 27 and State Water Resources Control Board Resolution No. 93-62”. <br />