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ORDER NO. R5-2015-0058 -3- SAN JOAQUIN COUNTY DEPARTMENT OF PUBLIC WORKS FOOTHILL SANITARY LANDFILL, INC. FOOTHILL LANDFILL SAN JOAQUIN COUNTY station equipped with telemetry for wireless transmission of monitoring data. Test pad monitoring results for a required 5-year demonstration period indicated that the test pad area was allowing significantly less seepage than that indicated by design modelling results. In an 11 July 2014 letter, Water Board acknowledged that the landfill had been partially closed as required under CAO R5-2004-0706. Landfill Gas Controls The landfill gas (LFG) extraction system installed as part of the 2006 Site Improvement Project included the installation of 9 vertical extraction wells (GX-1 through GX-9) at LF-1; 5 horizontal extraction wells (HC-1 through HC-5) at LF-2, Module 1; and associated LFG collection and treatment facilities (i.e., lateral and header piping, condensate facilities, 2 blower motors, and a flare station). A gas-to-energy plant was subsequently installed in 2010 to generate electricity from the extracted landfill gas. In 2014, in response to a Water Board staff request, the Discharger submitted an amended Engineering Feasibility Study (EFS) proposing the installation of additional LFG controls and monitoring wells at the landfill as part of the corrective action program to address VOC impacts to groundwater at the site. The amended EFS has not yet been approved by Water Board staff. See WDR Finding 101. Revised WDRs These revised WDRs classify the unlined landfill LF-1 and Subtitle D lined expansion landfill LF-2 as separate units under Title 27 and prescribe appropriate requirements for each (e.g., construction, operation, closure, postclosure maintenance, and corrective action, as applicable). Closure and Postclosure Maintenance Specification E.2, for example, requires that LF-1 be completely closed by 15 October 2018, while Construction Specification D.5 specifies the Title 27 prescriptive standard and authorized engineered alternative designs for completing closure of LF-1, and Provision H.7 provides a schedule for submission of closure construction reports. Construction Specification D.1 similarly specifies the Title 27 prescriptive standards and authorized engineered alternative designs for the containment system components of new LF-2 expansion modules, including base liner, excavation side slopes, and areas of overlap between LF-1 and LF-2. Provision H.8 requires submission of an Operations and Maintenance (O&M) Plan for the LFG control system to ensure that LFG extracted from the landfill units is handled and disposed of in accordance with the requirements of the WDR requirements, including necessary modifications to discontinue discharges of LFG condensate from LF-1 to LF-2. The revised WDRs also include provisions requiring the Discharger to submit a revised Preliminary Closure and Postclosure Maintenance Plan (PC/PCMP) for LF-2 (Provision H.10) and a Water Quality Protection Standard Report describing the Water Quality Protection Standard for both units (Provision H.7) consistent with the requirements of this Order. Monitoring The monitoring and reporting program (MRP) in the WDRs requires regular facility maintenance inspections and semiannual monitoring of the unsaturated zone, groundwater, and surface water for representative monitoring parameters. Leachate, landfill gas, and solid waste monitoring is also required. Monitoring every five years is required for all landfill constituents of concern. The MRP also requires that the Discharger maintain coverage under the General Industrial Storm Water Permit.