COMPLIANCE INFO_1996-2003 - Laserfiche WebLink

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response to comments, the CVRWQCB: 1) approved the liner system, as proposed,but limited its deployment to a single landfill cell,rather than approving the entire expansion; and 2) at its regular September 15, 2000, meeting adopted Resolution No. 5-00-213 requesting the SWRCB to determine if Regional Water Quality Control Boards should continue to consider the single- composite liner system as adequate in the majority of instances. POINTS TO CONSIDER 1. The SWRCB's containment standards [27CCR203 1 0(a&c)] do not apply to only the liner. They apply to the entire waste management unit (or to its "containment structures"), including both its liner and cover systems. There is no standard requiring the liner system, in and of itself, to provide such containment except prior to the installation of the final cover. 2. Regarding the discharge of MSW to a landfill, the RWQCB is required to issue waste discharge requirements (WDRs) that implement all of the regulations and policies governing such discharges. 3. The applicable performance standard for containment of MSW is that the MSW landfill not leak. We know of no liner design or scheme that will provide perfect certainty of achieving this goal. The RWQCB can approve any liner and final cover system that at least meets applicable minimum design standards and that provides reasonable assurance of meeting this performance standard. There are situations (e.g., landfill overlies a sole-source aquifer) where prudence dictates a more stringent design. The RWQCB must consider all relevant design-, site-, and operation-specific factors in establishing the appropriate liner and final cover design for a given landfill. 4. Dr. G. Fred Lee, in his submittals, implies that a double-composite liner can be used to protect against leakage for as long as the waste in the landfill could pose a threat to underlying ground water. However, each plastic membrane in a multi-composite design is subject to the same aging problems as is the uppermost plastic membrane. A double--- composite ouble composite design might achieve Dr. Lee's declared goal if the lower liner and LCRS act primarily as a leak detection system, rather than a containment function, and the RWQCB responds to a leak by taking appropriate regulatory action. 5. Since 1984, the SWRCB's conceptual waste containment strategy has included the idea that the final cover must be at least as resistant to throughflow as is the liner [27CCR21090(a)(2)]. In 1997, the SWRCB added a clarifying performance standard at 27CCR20950(a)(2)(A)1., to wit: "For [landfills], after closure,the final cover constitutes the Unit's principal waste containment feature." 6. The plastic membrane portion of the composite liner, when properly installed, has a design life expectancy of at least several hundred years, a duration long enough to allow its function to be replaced by a well-designed, -installed, -monitored, and-maintained final cover. 7. The final cover is accessible and reparable, whereas the liner is not. The regulations require that the discharger monitor and repair the final cover as necessary to assure that it will continue to minimize the through-flow of precipitation to the underlying waste [27CCR21090(a)(4)].