1. LEA inspection report documented correlation between Newby Island and Odor complaints. BAAQMD has issued multiple public nuisance violations during the past 2 weeks to Newby Island following a surge of confirmed odor complaints. LEA November 2014 inspection report included odor complaint correlation. Date Inspection Program 11/25/2014 LEA ** Follow Periodic link to read reports Concern/ Violations Areas of Concern Remarks Regulation PRC 44014(b)Operator Complies with Terms & Conditions A records check found that the Odor Complaint log contained information on complaints and the wind direction at the time of the complaint. Many showed a correlation between Newby Island, the ESE afternoon prevailing winds and the complaints. 2. Repeated Landfill Perimeter Gas Monitoring Violations after EIR study period (Title 27 §20919, 20921) NISL has a record of 5 recurring Gas Control and Monitoring Violations logged by LEA monthly inspections after the EIR study period. In Dec 2009, 6 perimeter gas probes exceeded the 5% Methane concentration compliance level, with one as high as 85.6%. On 2/18/11, a revised monitoring plan was implemented where only 3 probes were retained and 17 probes were exempted (including all 6 probes with high readings). Date Inspection Concern/ Program Violations Remarks Regulation 01/29/2010 ** Follow link to read reports LEA Periodic Areas of Concern 20919-Gas Control 20921-Gas Monitoring and Control 6 perimeter gas probes >5% methane concentration. 07/20/2010 LEA Periodic Violation 20921-Gas Monitoring and Control Violation for Sec. 20937 Gas Control Program – Corrective action developed (22 new gas extraction wells) and implemented for methane gas exceeding acceptable levels 08/31/2010 LEA Periodic Areas of Concern 20921-Gas Monitoring and Control AOC sec 20937 Gas Control Program. 2 probes >5% methane compliance level 09/23/2010 LEA Periodic Areas of Concern 20921-Gas Monitoring and Control AOC sec 20937 Gas Control Program. 2 probes >5% methane compliance level 10/26/2010 LEA Periodic Violation 20921-Gas Monitoring and Control Violation Sec 20937 Gas Control Measures. 2 probes >5% methane compliance level 11/29/2010 LEA Periodic Violation 20921-Gas Monitoring and Control Violation Sec 20937 Gas Control Measures. 2 probes >5% methane compliance level 12/20/2010 LEA Periodic Violation 20921-Gas Monitoring and Control Violation Sec 20937 Gas Control Measures. 3 probes >5% methane compliance level 01/28/2011 LEA Periodic Violation 20921-Gas Monitoring and Control Violation Sec 20937 Gas Control Measures. 3 probes >5% methane compliance level 02/22/2011 LEA Periodic Areas of Concern 20790Leachate Control The operator has worked with Calrecycle on the gas monitoring issue and it has been determined that due to the barriers (levee, creeks, etc.) surrounding the site, the section of the landfill that had previously had high gas readings could be exempt 04/21/2011 CalRecycl e Periodic None Probes GP-1, GP-3, GP-5, and MP-12 had elevated levels of methane above 5% but are exempt from being compliance points. CalRecycle Closure staff determined that perimeter landfill gas probes surrounding the site along the bay/marshland are exempt from staying below 5% methane by volume requirement. This was due to Coyote Creek and tidal marshlands acting as a physical barrier for landfill gas migration. A letter dated February 18, 2011 sent from CalRecycle summarizes the changes made to the monitoring requirements. Source: http://www.calrecycle.ca.gov/SWFacilities/Directory/43-AN-0003/Inspection/ Revised Monitoring Plan letter: http://www.calrecycle.ca.gov/SWFacilities/Directory/43-AN0003/Documents/Closure/51557.pdf Regulations: http://www.calrecycle.ca.gov/Laws/Regulations/Title27/ch3sb4b.htm#Article6 Section 20921. CIWMB - Gas Monitoring and Control. (a) To provide for the protection of public health and safety and the environment, the operator shall ensure that landfill gas generated at a disposal site is controlled in such a manner as to satisfy the following requirements: (1) The concentration of methane gas must not exceed 1.25 percent by volume in air within any portion of any on-site structures. (2) The concentration of methane gas migrating from the disposal site must not exceed 5 percent by volume in air at the disposal site permitted facility boundary or an alternative boundary approved in accordance with Section 20925. (3) Trace gases shall be controlled to prevent adverse acute and chronic exposure to toxic and/or carcinogenic compounds. 3. Other violations 11/25/2014 CalRecycle Violation Focused 21600-Report The facility began storing unprocessed mixed recyclables and of Disposal Site organic material for the past 12 Information months, harvests cover material from active face and use blended materials as ADC without formal 20510-Disposal approval/documentation. Site Records