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WASTE DISCHARGE REQUIREMENTS ORDER R5-2015-0058-01 -18- <br />SAN JOAQUIN COUNTY DEPARTMENT OF PUBLIC WORKS <br />FOOTHILL SANITARY LANDFILL, INC. <br />FOOTHILL LANDFILL <br />SAN JOAQUIN COUNTY <br /> <br />Following an indication of a release, verification testing must be conducted to <br />determine whether there has been a release from the landfill unit or the detection <br />was a false detection. The detection of two non-naturally occurring waste <br />constituents above the MDL as a trigger is appropriate due to the higher risk of <br />false-positive analytical results and the corresponding increase in sampling and <br />analytical expenses from the use of one non- naturally occurring waste constituent <br />above its MDL as a trigger. <br />75. For a naturally occurring constituent of concern, Title 27 requires concentration <br />limits for each constituent of concern be determined as follows: <br />a. By calculation in accordance with a statistical method pursuant to Title 27, <br />section 20415(e)(8); or <br />b. By an alternate statistical method meeting the requirements of Title 27, section <br />20415(e)(8)(E). <br />76. Title 27 specifies the prescriptive requirements and performance standards applicable <br />to monitoring data analysis and requires that such methods be implemented as <br />follows: <br />a. As specified in the existing MRP under the WDRs; or <br />b. In accordance with a technical report (certified by an appropriately registered <br />professional) documenting such methods, submitted to, and approved by, the <br />Central Valley Water Board; or <br />c. In accordance with any water quality data analysis software deemed appropriate <br />for such use by either the Central Valley Water Board or SWRCB. <br />The MRP of these WDRs requires that concentration limits for naturally-occurring <br />constituents be based on an interwell approach absent a satisfactory <br />demonstration that an intrawell approach is justified at the site (e.g., existence of <br />significant spatial variability not attributable to a release from the unit). Consistent <br />with monitoring reports submitted under previous WDRs, MRP No. R5-2015-0058 <br />specifies that the method of Interwell Tolerance Limits be used to calculate <br />concentration limits for naturally-occurring constituents at the site. For evaluation of <br />corrective action progress (i.e., trends), the monitoring program specifies an <br />intrawell statistical procedure (e.g., Sens Slope Method). See Section C.4, MRP. <br />77. To demonstrate that corrective action has been completed (i.e., concentrations along <br />Point of Compliance returned to compliance with the water quality protection <br />standard), Monitoring Specification G.7 specifies a four year “proof” period. During <br />this period, the Discharger must demonstrate that all constituents of the release have <br />been reduced to concentration limits for at least eight consecutive semiannual <br />monitoring events. <br />