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Foothill Landfill <br />Storm Water Pollution Prevention Plan <br /> <br /> <br /> <br /> Page 31 <br />7.0 Assessment of Potential Pollutant Sources <br />San Joaquin County periodically reviews storm water observation and analytical data from <br />each outfall of the Foothill Landfill in order to evaluate the effectiveness of existing BMPs and <br />monitor operational changes that may affect the quality of the facility’s storm water discharge. <br />A formal assessment is done at the end of each storm water year in conjunction with the annual <br />evaluation, and the preparation of the annual report. <br />7.1 Narrative Assessments <br />San Joaquin County annually reviews and evaluates <br />its activities in light of the storm water discharge <br />observations and analytical data from each outfall. <br />7.1.1 Sampling Parameters <br />The General Permit in Section XI.B outlines storm <br />water sampling parameters that are to be analyzed. <br />The sampling parameters are to be analyzed using <br />sufficiently sensitive test methods in compliance <br />with 40 CFR Part 136, or 40 CFR Chapter I, <br />subchapters N and O in order “to detect and quantify <br />pollutants at or below the applicable water quality <br />criteria, action levels, or effluent limitations” for any <br />applicable NPDES permit.1 <br />7.1.1.1 Universal Sampling Parameters <br />All storm water discharges are to be sampled for <br />Total suspended solids (TSS), oil and grease <br />(O&G), and pH. <br />7.1.1.2 Facility-Specific Sampling Parameters <br />The General Permit requires in Section X.G.2.a.ii to <br />assess “pollutants likely to be present in industrial <br />storm water discharges and authorized NSWDs.” <br />Then in Section XI.B.6.c the General Permit also <br />requires that dischargers are to include in their <br />monitoring programs other parameters that are <br />facility-specific (based on the General Permit Section X.G.2.a.ii assessment) and are <br />indicators of the presence of potential pollutants present in storm water from the facility’s <br />industrial pollutant sources. <br />In addition, the General Permit requires dischargers to include in their monitoring programs <br />other parameters that are facility-specific and are indicators of the presence of potential <br />pollutants present in storm water from the facility’s industrial pollutant sources. Since paper <br /> <br />1 see 2018 Industrial Storm Water General Permit Amendment Fact Sheet at <br />https://www.waterboards.ca.gov/water_issues/programs/stormwater/docs/industrial/igp_factsheet_final.pdf or Amended General Permit <br />Section I.K.69 <br />When do Federal Sub-chapter N Effluent <br />Limits Guidelines (ELGs) Apply? <br />Section 445 of Sub-chapter N states that the <br />effluent limits apply to landfill wastewater, which <br />is defined as all wastewater associated with, or <br />produced by, landfilling activities except for <br />sanitary wastewater, non-contaminated storm <br />water, contaminated ground water, and <br />wastewater from recovery pumping wells. <br />Landfill wastewater includes, but is not limited to, <br />leachate, gas collection condensate, drained free <br />liquids, laboratory derived wastewater, <br />contaminated storm water and contact wash water <br />from washing truck, equipment, and railcar <br />exteriors and surface areas which have come in <br />direct contact with solid waste at the landfill <br />facility. Contaminated storm water means storm <br />water which comes in direct contact with landfill <br />wastes, the waste handling and treatment areas, or <br />landfill wastewater. Therefore, if the storm water <br />runoff is from non-contaminated storm water (as <br />defined above), the ELGs do not apply. At the <br />Foothill Landfill, discharge from the northeast <br />retention basin (ST-5) and the landfill gas <br />energy plant (ST-4) is applicable to the ELGs, <br />while the other outfalls are not applicable to <br />ELGs because water at these discharge points <br />does not come into contact with landfill wastes <br />or wastewater.