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DRAFT [TENTATIVE] WASTE DISCHARGE REQUIREMENTS ORDER R5-2023-OOXX 24 FORWARD, INC. FORWARD LANDFILL SAN JOAQUIN COUNTY leachate from solid waste management units. An engineered alternative to the prescriptive liner requirements of Title 27 is proposed for the Class 11 Surface Impoundments. The engineered alternative is outlined in Attachment E. 79. The Discharger has adequately demonstrated that construction of a liner in accordance with the Title 27 prescriptive standard would be unreasonably and unnecessarily burdensome in comparison to the proposed engineered alternative. The Discharger has further demonstrated that the proposed engineered alternative(s), as described in Attachment E, are not only consistent with the performance goals of the prescriptive standard, as described above, and will afford at least equivalent water quality protections. 80. New WMUs will incorporate the leachate collection and removal systems (LCRS) described in further detail on Attachment E. The proposed LCRS comply with Title 27 prescriptive standards (see Title 27, section 20340). Collected leachate is either recirculated to composite-lined landfill units or discharged to one of the on-site Class 11 impoundments. Recirculated leachate may be discharged by spraying from a tanker truck or by subsurface injection. 81. The unsaturated zone monitoring system for future modules shall be implemented in accordance with the operative MRP. 82. A pan Iysimeters will be installed beneath the LCRS sump in each new landfill cell/module for the purpose of vadose zone monitoring. The design for pan Iysimeters are described in Attachment E. 83. The Discharger proposed to install an intermediate liner where modules are constructed over the existing Class III waste, unlined or non-Subtitle D lined, from adjacent Class II WMUs. The design for intermediate liners is described in Attachment E. An intermediate liner was constructed for WMU D-94, WMU D- 97, WMU D-98, WMU D-99, WMU D-00, WMU Art-03, WMU FU-04 North, WMU FU-05 North, WMU FU-06 North, and WMU FU-08 North. 84. According to the submitted seismic analysis, the proposed new WMUs will be able to withstand MCE and MPE seismic events described in Finding 43 (Title 27, section 20370). 85. New and existing LCRS shall be fitted with an automated pumping system and operated to prevent buildup of head on the liner. The depth of leachate in any LCRS sump shall be kept at or below the minimum needed to ensure safe pump operation, but shall be no greater than 30 centimeters (12 inches) unless the Discharger demonstrates that it is infeasible to maintain less than 12 inches in the LCRS sump area. If leachate depths exceed these levels or if liquid is detected in the underlying leak detection layer then the Discharger shall immediately notify the Regional Water Board in writing within seven days.