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WASTE DISCHARGE REQUIREMENTS ORDER R5-2015-0058-01 -17- SAN JOAQUIN COUNTY DEPARTMENT OF PUBLIC WORKS FOOTHILL SANITARY LANDFILL, INC. FOOTHILL LANDFILL SAN JOAQUIN COUNTY 70. A review of the files indicates that no Water Quality Protection Standard (WQPS) Report has ever been submitted for this site. Previous WDRs specified concentration limits for organic constituents and some inorganic constituents, while concentration limits for certain other inorganic constituents were left to be determined based on future monitoring results. A Water Quality Protection Standard (WQPS) is the analytical framework through which WMUs are individually monitored for releases and impacts to water quality. (Title 27, § 20390, subd. (a)). These WDRs require that the Discharger develop a complete list of concentration limits for each landfill unit and submit a WQPS Report describing the WQPS for each unit consistent with the requirements of this Order. See Provision H.7 and MRP Section C.4. 71. In accordance with Title 27, this Order, by virtue of its incorporation of the operative MRP and subsequent revisions thereto, establishes a WQPS for Calaveras SI. 72. As of this date of this Order, the Discharger submitted a complete WQPS on 10 March 2016. However, an updated WQPS for the proposed SI unit would need to be submitted. The remaining WQPS elements must be provided prior to the placement of leachate in the Calaveras SI, as specified in Provision H.9.m. Monitoring Data Analysis Methods 73. Volatile organic compounds (VOCs) are often detected in a release from a MSW landfill and are often associated with releases of landfill gas rather than leachate. Since volatile organic compounds are not naturally occurring and thus have no background value, they are not amenable to the statistical analysis procedures contained in Title 27 for the determination of a release of wastes from a landfill unit. Title 27, sections 20415(e)(8) and (9) allow the use of a non-statistical evaluation of monitoring data that will provide the best assurance of the earliest possible detection of a release from a landfill unit in accordance with Title 27, sections 20415(b)(1)(B)(2- 4). However, Title 27 does not specify a specific method for non- statistical evaluation of monitoring data. 74. The Central Valley Water Board may specify a non-statistical data analysis method pursuant to Title 27, section 20080(a)(1). Water Code section 13360(a)(1) allows the Central Valley Water Board to specify requirements to protect groundwater or surface waters from leakage from a solid waste site, which includes a method to provide the best assurance of determining the earliest possible detection of a release. In order to provide the best assurance of the earliest possible detection of a release of non- naturally occurring waste constituents from a landfill unit, the SPRRs specify a non- statistical method for the evaluation of monitoring data for non-naturally occurring compounds. The specified non-statistical method for evaluation of monitoring data provides two criteria (or triggers) for making the determination that there has been a release of non-naturally occurring waste constituents from a landfill unit. The presence of two non-naturally occurring waste constituents above their respective method detection limit (MDL), or one non-naturally occurring waste constituent detected above its practical quantitation limit (PQL) [a.k.a, laboratory reporting limit (RL)], indicates that a release of waste from a Unit has occurred.